Privacy Policy
- Data Controller
VIVENIO RESIDENCIAL SOCIMI, S.A., with registered office in Madrid, Calle María de Molina 54, 3rd floor, postcode 28006, and Tax Identification Number A-87805768, as well as the companies within its Group (hereinafter, collectively, “Vivenio”), shall be joint data controllers for the processing of personal data collected via the Plenora website, as well as for any data that may be processed in the context of managing bookings, stays and the operation of the properties and associated services offered under that brand.
These entities jointly determine the purposes and essential means of the personal data processing described in this Privacy Policy and have entered into the corresponding joint controller agreement, in accordance with the provisions of Article 26 of Regulation (EU) 2016/679 (GDPR), which transparently sets out their respective roles and obligations regarding the protection of personal data.
Below, we provide detailed information on (i) how we will use the personal data you provide to us or that we may collect in the course of Plenora’s operations and the stays managed under this brand, and (ii) the rights you have as the data subject.
- Data Protection Officer
Vivenio has appointed a Data Protection Officer (DPO), whom you may contact regarding any matter relating to the processing of your personal data or the exercise of the rights recognised by data protection legislation.
You can contact the Data Protection Officer via the following email address: compliance@vivenio.com
- Why do we process your data?
Personal data provided via the Plenora website will be processed by Vivenio for the following purposes:
- Management of bookings and stays
If you make an accommodation booking via the Plenora website, we will process your personal identification and contact details, as well as any data necessary for managing the booking and your stay, for the purpose of processing, managing and fulfilling the contractual relationship, as well as carrying out the administrative and operational tasks associated with it.
The legal basis for the processing of such data is the performance of the contract and the implementation of pre-contractual measures at your request, in accordance with Article 6(1)(b) of the GDPR.
The data retention period for this purpose will be for as long as necessary during the term of the contractual relationship and, once the stay has ended, for the statutory retention periods and limitation periods for potential liabilities, which, generally speaking, may extend up to six (6) years, unless other periods apply.
- Compliance with legal obligations
We will process the personal data necessary to comply with the legal obligations applicable to Vivenio in relation to the management of stays and the services offered under the Plenora brand.
The legal basis for the processing is compliance with a legal obligation, in accordance with the provisions of Article 6(1)(c) of the GDPR.
The data retention period shall be that provided for in the applicable regulations in each case and, once that period has elapsed, for the applicable statutory limitation periods.
- Operational communications relating to the booking and stay
We will use your personal contact details to send you communications necessary for the proper management of the booking and stay, such as confirmations, operational notices or relevant information before, during or after your stay.
The legal basis for this processing is the performance of the contract (Article 6(1)(b) of the GDPR).
The data retention period for this purpose will be the same as that indicated for the management of the booking and stay, unless other periods apply.
- Customer service and complaint handling
If you contact Vivenio to make enquiries, report incidents or lodge complaints or claims, we will process the personal data you provide for the purpose of addressing your request and managing its processing and resolution, including, where applicable, the formulation, exercise or defence of claims.
The legal basis for the processing will be:
- the performance of the contract, where the request or complaint relates to a booking or stay (Article 6(1)(b) GDPR), and
- Vivenio’s legitimate interest in providing appropriate service to its customers and users and managing any claims (Article 6(1)(f) of the GDPR).
The data retention period for this purpose will be for as long as necessary to handle and resolve the request or complaint and, once closed, for the applicable statutory limitation periods, which, generally speaking, may extend up to five (5) years, unless other periods apply.
- What data do we process?
Vivenio will process, depending on each case, the following categories of data:
Identifying data (first name, surname, identification document, postal address in the country of origin).
Contact details (email address, telephone number).
Data relating to the booking and the stay.
Data necessary for compliance with legal obligations.
Any other data necessary for the proper management of the contractual relationship.
- Who do we share your data with?
Your personal data may be processed by suppliers acting on behalf of Vivenio as data processors, in particular technology providers necessary for the management of the website and bookings, such as the Lavanda management platform, with which Vivenio has entered into the relevant contract in accordance with Article 28 of the GDPR.
Likewise, data may be disclosed to public authorities, courts and tribunals where necessary to comply with a legal obligation or for the establishment, exercise or defence of legal claims.
Your data will not be disclosed to third parties for purposes other than those described in this policy.
- International data transfers
Should it be necessary to carry out international data transfers in order to provide the services correctly, Vivenio will ensure that such transfers are carried out in accordance with the safeguards required by current data protection legislation.
- Necessary and up-to-date information
When you provide us with your data, you declare that the information and data submitted for the purposes described above are accurate and truthful. To ensure that the information provided is always up to date and free from errors, please remember to notify us as soon as possible of any changes or corrections to your personal data that may arise. You can do so by emailing compliance@vivenio.com
- Rights of data subjects
We would like to inform you that you may exercise your data protection rights, specifically the rights of access, rectification, erasure, restriction, objection and data portability, as well as the right to withdraw your consent, at any time by sending an email to compliance@vivenio.com or by writing to Vivenio’s postal address, specifying which right you wish to exercise. Should we have any doubts regarding your identity, we may ask you to verify it by means of an official document, for example, to prevent unauthorised access to your data by third parties.
Furthermore, we remind you that you have the right to lodge a complaint with the Spanish Data Protection Agency if you consider that has committed a breach regarding the processing of your personal data.
- Confidentiality and security
At Vivenio, we strive to maintain the confidentiality of the personal information you provide to us via the platform.
We maintain strict security standards to protect the personal data we process against accidental loss and unauthorized access, processing or disclosure, taking into account the state of technology, the nature of the data and the risks to which it is exposed. However, we cannot be held responsible for the use you make of the data in connection with the services offered by Vivenio outside our technological environment.
- Changes to the Privacy Policy
Vivenio reserves the right to amend its privacy policy at any time, in accordance with current data protection legislation and following due notification to data subjects.
- Language applicable to this Privacy Policy
The language applicable to this Privacy Policy is Spanish. Any version of this Policy in a different language is provided by Vivenio for your convenience and to facilitate understanding. However, this Privacy Policy shall always be governed by its Spanish version.
In the event of any contradiction between the Privacy Policy in any language and its Spanish version, the Spanish version shall prevail.