Privacy Policy

OUR PRIVACY POLICY AT A GLANCE

Who are we?
We are TENOHOMES VACATIONAL, and we handle your data as the Data Controller. This means that we are responsible for how we use and protect your personal data.

What do we use your data for?
We use the data you have provided online or through any other means to respond to your queries and suggestions, provide the requested services or products, register you as a user if you are the account holder, send you personalized communications you have subscribed to, and process your reservation.

Why do we have your data?
We are legally allowed to process your data for different reasons. When you fill out a form or send us an email with a query or suggestion, we have a legitimate interest in responding. When you register on our website as a property owner or make a reservation, we must execute the contract you accept with us, as well as the legal obligation to issue an invoice containing your data. We are also authorized to process your data when you give us permission to send you personalized offers.

Who do we share your data with?
We will only share data with collaborating companies to respond to requests and provide our services or products, banks, and government bodies as required by law. Under no circumstances will we sell your data to third parties.

What rights do you have?
You have the right to access, rectify, or delete your personal data. You also have the right to object to the use of the data you previously authorized, to have it transferred, and to not be subject to automated individual decisions. When processing your personal data, we apply the following principles to ensure maximum protection:

• Lawfulness, fairness, and transparency principle: We will always require your consent to process your personal data for one or more specific purposes, which we will inform you of transparently in advance.
• Data minimization principle: We will only request data strictly necessary for the purposes we need them for—minimizing to the absolute minimum.
• Data retention limitation principle: Data will be kept no longer than necessary for the processing purposes, and depending on the purpose, we will inform you of the corresponding retention period. For subscriptions, we periodically review our lists and delete inactive records for a significant period.
• Integrity and confidentiality principle: Your data will be processed in a way that guarantees adequate security and confidentiality. You should know that we take all necessary precautions to prevent unauthorized access or misuse of user data by third parties.

In this privacy policy, you will find more detailed information on how we use the personal data of our customers, suppliers, users, and all individuals who communicate with us, regardless of the means used (online form, phone, email, in person).
We aim to be transparent about what we do with your personal data, so you understand the implications of its use and your rights concerning your data. Therefore, we keep our Privacy Policy, Legal Notice, and Cookie Policy up to date, which you can consult on this website.

If you have any questions or want to know more about the privacy policy, you can continue reading the document.

TENOHOMES VACATIONAL is committed to complying with the applicable laws regarding the processing of personal data. Through this privacy policy, TENOHOMES VACATIONAL, in accordance with the requirements of the GDPR and LOPDGDD, informs users and the individuals whose data it processes of the following:

WHO IS THE DATA CONTROLLER?

The data controller is TENOHOMES VACATIONAL:

• Identity
  TENOHOMES VACATIONAL

• Address
  Calle Ajoque 4, 38480 – Buenavista del Norte

• Phone
  638216205

• Website
  www.tenohomes.com

• Email
  tenohomes@gmail.com

TENOHOMES VACATIONAL informs the user that the data provided through navigation on our website, various data collection forms, or email submissions will be processed by TENOHOMES VACATIONAL, and such processing is included in the Record of Processing Activities managed by TENOHOMES VACATIONAL in compliance with the GDPR.

WHAT ARE YOUR PERSONAL DATA USED FOR?

On www.tenohomes.com, we process data both from users of our website and third parties who maintain relationships with us. To make it easier for you to understand how we process your data, we have differentiated the purpose for which we use the data, the types of data, and the legal basis based on the category of people from whom we process data. Below, we classify the people from whom we process data based on the type of relationship they maintain with TENOHOMES VACATIONAL.

2.1 Website Users
What data do we collect from users of our website?

1. Data from users who complete any of the available forms: The personal data that TENOHOMES VACATIONAL requests includes:

   • Identifying data: Name and surname, phone number, email address, locality, and province.
   • Data related to the request.

2. Data from users who wish to receive information, commercial communications, and notifications:

   • Identifying data: Name and surname, phone number, email address, locality, and province.

3. Data from property owners who register on our platform:

   • Identifying data: Name and surname, postal and email address, phone number, billing address.

4. Data from users who browse our website: Data provided by cookies and Google Analytics.

What purposes will we use your personal data for?
When you accept our privacy policy, you authorize us to use the personal data you provided for the following purposes:

• To send you information and provide the service you request through the various forms available on our website.
• To send you commercial communications about offers, activities, and promotions from TENOHOMES VACATIONAL and the sector that may interest you via conventional or electronic means when you have marked the box to receive information.

How do we obtain your data?
We obtain your data through:

• The form completed by the user on our website for the intended purpose. The form is subject to acceptance of this privacy policy via the indicated checkbox.
• We obtain browsing data from the different cookies that the user accepts when accessing www.tenohomes.com for the first time.

What is the legal basis for processing your data?
The user’s express consent (Article 6.1.a. GDPR), provided by completing the different forms and marking the box to receive commercial communications/information about offers, activities, and promotions from TENOHOMES VACATIONAL and the sector that may be of interest, legitimizes the processing by TENOHOMES VACATIONAL. The user can revoke their consent at any time; however, revoking the consent will not affect the processing of data that was carried out before the revocation of consent.

• Legitimate interest in profiling navigation and detecting preferences through the installation of cookies.
• Execution of a contract or adoption of pre-contractual measures when the client makes a request through the available forms on our website or requests information about the services provided by TENOHOMES VACATIONAL.

2.2. Suppliers
What data do we collect from our suppliers?

Identifying data from the supplier: The personal data that TENOHOMES VACATIONAL requests includes:

• Identifying data: Name and surname, phone number, postal and email address.
• Employment and professional data: Activities and business.

How do we obtain your data?
We obtain your data through:

• The signing of the contract that binds us, the acceptance of the quoted price, the receipt of invoices from the supplier, and the signing of the Data Processor Agreement, where applicable, for the service provided.

What purposes will we use your personal data for?

• Manage information related to our suppliers of goods and services, as well as their representatives.
• Maintain the contractual relationship with our suppliers.
• Manage payments and collections related to the contracts that bind us.

What is the legal basis for processing your data?

• Execution of a pre-contract/contract to send the information and carry out the proper management of the service provided, which would not be possible otherwise.
• Legitimate interest in managing data related to representatives of TENOHOMES VACATIONAL’s suppliers.

2.3. Clients
What data do we collect from our clients?

1. Data from clients who complete any of the forms available on www.tenohomes.com and in the physical establishment of TENOHOMES VACATIONAL.

   • Identifying data: Name and surname, phone number, email address, locality, and province.
   • Data related to the request.

2. Data from property owners who register on our platform:

   • Identifying data: Name and surname, postal and email address, phone number, billing address.

3. Data from our clients obtained through our contracts and quotations:

   • Identifying data: Title, name, surname, email address, phone number, billing address, country, ID number.
   • Transaction data: Products, services provided, payment method, invoice or purchase receipt.

How do we obtain your data?
If you are an online client, we obtain your data through:

• The form that the user fills out to request information and/or a quote, or to make a reservation, which is subject to acceptance of this privacy policy via the indicated checkbox.
• We obtain browsing data from the different cookies that the client accepts when accessing www.tenohomes.com for the first time.

If you are an in-person client, we obtain your data through:

• The customer registration form.
• Acceptance of the presented quote.
• The signed contract.

What purposes will we use your personal data for?

• Generate and manage the documentation associated with your requests and reservations.
• Provide you with information about offers, products, and services related to your reservation.
• Process your reservation online through our platform.

What is the legal basis for processing your data?

• Execution of a pre-contract/contract to send the information and carry out the proper management of the service provided, which would not be possible otherwise.
• User consent to send commercial communications about offers, activities, and promotions from TENOHOMES VACATIONAL and the sector that may interest you. The user can revoke their consent at any time.
• Legitimate interest in sending information about exclusive promotions, the latest updates, personalized information tailored to the user’s profile, and for sending satisfaction surveys regarding the products or services purchased.

2.4. Social Media Contacts
What data do we collect?
Identifying data on the social media platform: TENOHOMES SL will not request data beyond what you have included in your user profile.

What purposes will we use your personal data for?

• To respond to and manage your inquiries, requests, or demands.
• Interact with you while you are part of our community of followers.

What is the legal basis for processing your data?

• Execution of a pre-contract/contract that binds you with the corresponding social media platform, in accordance with their privacy policies:
  • Facebook: http://www.facebook.com/policy.php?ref=pf
  • Instagram: https://help.instagram.com/155833707900388

www.tenohomes.com will always strive to establish appropriate mechanisms to obtain the User’s consent for the installation of cookies that require it. When a user accesses our website, a pop-up appears informing them of the existence of cookies and that by continuing to browse our page, they give consent for their installation. Accepting the installation of cookies means accepting the retention of the IP address in the records of www.tenohomes.com, along with the acceptance date, for a period of one year, in order to demonstrate the consent given. You can find more information in our “Cookie Policy.”

HOW LONG DO WE KEEP YOUR DATA?

3.1 Website Users

The data processed based on the user’s consent will be kept as long as it is relevant to the purpose for which it was collected and the consent is not revoked.
For data processed based on legitimate interest, the retention period will be linked to the purpose that motivated the data collection, always ensuring adequate guarantees and respect for the rights and freedoms of the data subjects.
For data processed based on the execution of a contract or pre-contractual measures, the retention period will be as long as the contractual relationship remains valid, as well as any additional time required for legal obligations.
The IP address obtained through cookies will be kept for one year, in order to demonstrate the user’s consent.
For more information on cookie retention, please refer to our “Cookie Policy” on our website.

3.2. Suppliers

For data processed based on legitimate interest, the retention period will be linked to the purpose that motivated the data collection, ensuring adequate guarantees and respect for the rights and freedoms of the data subjects.
For data processed based on a contract or if part of the processing is justified by a legal obligation, the data will be retained for as long as the contractual relationship is valid. Once the relationship ends, or if the processing is linked to a legal obligation, the retention period will be as legally required, and the data subject will not be able to revoke the processing of the data, except in cases of legal provisions for blocking.

3.3. Clients

Data processed based on the customer’s consent will be kept as long as it is relevant to the purpose for which it was collected and the consent is not revoked.
For data processed based on legitimate interest, the retention period will be linked to the purpose that motivated the data collection, always ensuring adequate guarantees and respect for the rights and freedoms of the data subjects.
For data processed based on a contract or if part of the processing is justified by a legal obligation, the data will be retained for as long as the contractual relationship is valid. Once the relationship ends, or if the processing is linked to a legal obligation, the retention period will be as legally required, and the data subject will not be able to revoke the processing of the data except as provided by law.

3.4. Social Media Contacts

Data processed from social media contacts will be kept as long as the user and TENOHOMES VACATIONAL maintain a connection on the social network. As the processing of data is not directly dependent on TENOHOMES VACATIONAL, we can only view or delete your data in a restricted manner. We will process your data while the user is linked to TENOHOMES VACATIONAL through ‘friends,’ ‘likes,’ ‘follow,’ or similar actions.
To rectify your data, restrict the information, or change shared posts, the user must make the changes through their social media profile settings in accordance with the platform’s privacy policy.
Regardless of the legal basis for collecting the data, it may be processed for scientific, historical, or statistical research purposes, always implementing adequate safeguards and respecting the rights and freedoms of the data subjects.

ADDITIONAL INFORMATION ABOUT DATA PROCESSING

Only individuals over the age of 14 may provide data through our website and email. If you are underage, you must have the consent of your parents or legal guardians.
The user guarantees the authenticity and accuracy of all the data communicated to TENOHOMES VACATIONAL and declares that they are over 14 years old, and will be solely responsible for any false or inaccurate statements made.
When making a booking or an online purchase, the interested party must be over 18 years old, the legal age to acquire majority and the capacity to act according to the Civil Code.

Personal data processed by TENOHOMES VACATIONAL may be mandatory or voluntary. We will not ask for special category data through the website forms to ensure your privacy. If a service requires special category data, it will be requested through other means. The data we request in the forms are:

• Identifying data: name, surname, phone number, email address, locality, and province.
• Data related to the request.
• Data from users wishing to receive information, commercial communications, and updates.
• Data from property owners registering on our platform.

Voluntary information is data that the user is not required to provide in order to contact us.
Fields marked with an asterisk (*) or “required” are mandatory, and failure to provide them will prevent us from offering the service or addressing your request.
If you provide us with third-party data, you represent that you have their consent and agree to share this privacy information with them, relieving TENOHOMES VACATIONAL of any obligation. However, TENOHOMES VACATIONAL may carry out checks to verify that the third party has been informed, adopting the necessary diligence measures as established by data protection regulations.

TO WHOM WILL YOUR DATA BE COMMUNICATED?

Data will not be shared with third parties unless legally required or necessary to meet your request.
Recipients of your data may include:

• Group companies.
• Public administrations and agencies when required by tax, labor, Social Security, or other applicable laws.
• Data processors (fraud detection and prevention service providers, technology providers, customer service providers, advertising, and marketing services, and third-party service providers needed for the services offered by TENOHOMES VACATIONAL, such as messaging and transport services, etc.).

DO I TRANSFER DATA INTERNATIONALLY?

www.tenohomes.com is hosted in Spain, which is in the European Union, within the European Economic Area, or complies with the guidelines established in Articles 46 and 47 of the GDPR. Therefore, no international data transfers will occur for data provided by users on the website.
Our website only accesses user data in the following ways:

• Through contact forms available on the website.
• Through cookies that the user has previously accepted.

International data transfers may occur at the location of the above-mentioned transfers/communications, for which TENOHOMES VACATIONAL will use the tools provided in Articles 46 and 49 of the GDPR as guarantees for transfers to countries without an adequacy decision from the European Commission.

In any case, third parties with whom certain personal data is shared will have previously demonstrated the adoption of adequate technical and organizational measures to ensure proper data protection, and transfers to third countries will only occur when a binding legal instrument is in place, in accordance with Articles 46 and onwards of the GDPR. By accepting this privacy policy, you agree to the possibility of international data transfers under the specified guarantees.

If the requirements of the GDPR are not met, the interested party may consent to the international transfer or a contract may be concluded in the interest of the interested party. Otherwise, authorization must be sought from the Control Authority.

Additionally, some services provided by or for TENOHOMES VACATIONAL may involve the transfer of personal data to a third country outside the EU, for example, to cloud services provided by major international providers (such as Google, Microsoft). Compliance will be confirmed for these services.

TENOHOMES VACATIONAL does not sell user data to third parties under any circumstances.

WHAT RIGHTS DO YOU HAVE AND HOW CAN YOU EXERCISE THEM?

Users may exercise the following rights before TENOHOMES VACATIONAL:

• Access to their personal data.
• Rectify inaccurate or incomplete data.
• Request deletion or cancellation of data when, among other reasons, it is no longer necessary for the purposes for which it was collected.
• Object to its processing.
• Request limitation of the processing of their data when certain conditions are met under the law.
• Request the portability of their data under the conditions provided by law.
• Avoid being subject to automated decisions.
• Revoke the consents given.

To exercise their rights, the user must send a written request specifying the right they wish to exercise, along with proof of identity and a postal or electronic address for notifications. This request may be made by post to: TENOHOMES VACATIONAL Calle Ajoque 4 38480 – Buenavista del Norte, or by email to: tenohomes@gmail.com.
TENOHOMES VACATIONAL must respond to the request within one month from the receipt of the request. This period may be extended by two months if necessary, depending on the complexity and number of requests. You will be informed of any extension within one month from receiving the request, explaining the reasons for the delay.

Additionally, interested parties have the right to file a complaint with the competent Control Authority (Spanish Data Protection Agency) if they believe TENOHOMES VACATIONAL has violated their data protection rights. For more information: www.aepd.es.

ARE MY DATA SECURE?

TENOHOMES VACATIONAL has an active contract with AIRE NETWORKS DEL MEDITERRANEO SL for hosting its website. It is a European company with the latest security measures in place.

In any case, TENOHOMES VACATIONAL guarantees the adoption of appropriate measures to ensure the confidential processing of your data given its confidential nature and commits to keeping such data secret, processing it with the utmost confidentiality. It also declares that it has implemented security policies in its information system in accordance with the GDPR (EU) 2016/679, regarding the protection of individuals with respect to the processing of personal data and the free movement of such data.

All data provided through our platform is collected via a secure protocol. Our website has an SSL certificate, which allows encrypted connections when a user visits our site and exchanges information with us.

DO YOU NEED A USER ACCOUNT AND/OR PASSWORD?

The user may register on our website by creating an account. It is the user’s responsibility to maintain the confidentiality of account information, including the password, and all activities that occur under it.

The user is obliged to immediately inform TENOHOMES VACATIONAL of any unauthorized use of their account or password or if any security issues arise, by sending an email to tenohomes@gmail.com.

LINKS TO OTHER WEBSITES

If you choose to leave our website via links to other websites not belonging to our organization, TENOHOMES VACATIONAL is not responsible for the privacy policies of those websites or the cookies they may store on your computer.

Date: February 23, 2025 Version: V.1.0