PRIVACY POLICY - MasterHome Granada
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PRIVACY POLICY

**PRIVACY POLICY**

In compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (**General Data Protection Regulation** or **GDPR**) and Organic Law 3/2018 of December 5 on the Protection of Personal Data and Guarantee of Digital Rights (**LOPDGDD**), **RESIDENCIA MH GRANADA S.L. (COLEGIO MAYOR MONTAIGNE)**, hereinafter referred to as the **data controller**, hereby presents its policy regarding the processing and protection of personal data, which shall apply to those individuals who voluntarily communicate through email with the data controller, fill out data collection forms, enter into a contractual relationship with the data controller, or use any other service available on the website that involves the communication of data to the data controller. The acceptance and use of the data controller’s services implies the express acceptance of this policy.

Furthermore, these conditions shall be subsidiary to any other conditions established specifically on the same subject matter, which shall be communicated, without limitation, through registration forms, contracts, and/or conditions of particular services. The present policies shall be supplementary to the aforementioned conditions in those matters not expressly provided for and not contradictory.

Sending an email to the data controller or communicating any personal data to the data controller through any means implies the provision of free, unequivocal, specific, informed, and express consent for the processing of personal data by the data controller, which shall be carried out for the purpose of addressing the received communications.

**RESIDENCIA MH GRANADA S.L. (COLEGIO MAYOR MONTAIGNE)** informs the website user of the existence of personal data processing, the characteristics of which are detailed below:

**Who is the data controller?**

– **Identity:** RESIDENCIA MH GRANADA S.L. (COLEGIO MAYOR MONTAIGNE)
– **Tax Identification Number (NIF):** B13852553
– **Postal Address:** Avd. de Andalucia nº 4 – 18014 – Granada
– **Phone:** 672404267
– **Email:** mar.jimenez@grupomastereducacion.com

**For what purpose do we process your data?**

At **RESIDENCIA MH GRANADA S.L. (COLEGIO MAYOR MONTAIGNE)**, we process your data for the purpose of providing accommodation services oriented towards university students, master’s students, civil service exam candidates, and professionals. The processing includes:

– Managing the contracted service
– Creating, maintaining, and managing information to fulfill the lawful objectives of the activity, as well as to receive a satisfactory provision of the requested services by the client
– Issuing and sending sales invoices
– Managing the collection of services rendered
– Preparing accounting and other obligations necessary to comply with tax regulations
– Access control to facilities through the use of residents’ fingerprint to ensure Residence security
– Using the telephone, electronic, and postal contact methods provided by the client for the notification of matters related to the service provided and its administrative management.

**Social Media Management:** The data controller may have a presence on social media. The processing of data from individuals who become followers on the social media pages of the data controller shall be governed by this section, as well as by any terms of use, privacy policies, and access regulations belonging to the respective social network, previously accepted by the data controller’s user. The data controller shall process their data for the purpose of managing their presence on the social network, informing about activities, products, or services provided by the data controller, as well as for any other purpose permitted by the social network regulations. Under no circumstances shall follower profiles on social networks be used to individually send advertisements.

**What categories of data do we process?**

The data we process are of basic and specially protected levels. Specifically, we handle the following personal data:

– **Identifiers:** name, surname, ID / DNI, postal address, email address, phone number
– **Economic-financial:** bank accounts
– **Health data:** dietary restrictions

**Are there automated decisions made?**

No automated decisions are made, nor are profiles automatically created.

**How long will we keep your data?**

As long as a contractual relationship is maintained and the deletion of data is not requested. Once the contractual relationship ends, the data will be deleted with appropriate security measures to ensure data pseudonymization or total destruction.

**What is the legal basis for processing your data?**

The legal bases for the processing of personal data are the data subject’s own consent or that of their legal representative, as well as the execution of a contract. The data subject is not obliged to provide their personal data, but failure to provide the required and necessary information for processing will result in the inability to provide the service. The data subject may revoke consent for the collection and processing of their personal data at any time, through the procedure established for this purpose, without affecting the lawfulness of processing based on prior consent withdrawal. Withdrawal of consent shall not condition the execution of other purposes.

**Who will receive your data as third-party recipients?**

Data will not be communicated to third parties, except by legal obligation.

**To which data processors will your data be communicated?**

To provide strictly necessary services for the development of the activity, **RESIDENCIA MH GRANADA S.L. (COLEGIO MAYOR MONTAIGNE)** shares data with the following service providers:

– Processor located in Zaragoza for tax, accounting, and labor advisory services.
– Processor located in Leganés (Madrid) for the provision of dining services at the residence.
– Processor located in Madrid (Madrid) for the maintenance of the website www.masterhomegranada.com

All data processors comply with current data protection regulations.

**Are there international transfers of your data?**

International transfers of data are considered the transfer of data to data processors, joint controllers, or third-country recipients or international organizations not established in the European Union.

In the case of social networks, your image or other personal data will never be published without your signed consent through the corresponding document provided to you.

Your personal data may be transferred to the following organizations not established in the European Union:

[Table with service, company, and guarantee details provided.]

**What security measures do we implement to protect your data?**

We shall treat the data confidentially at all times, observing the corresponding duty of secrecy regarding them, in accordance with the provisions of the applicable regulations, adopting the necessary technical and organizational measures to guarantee the security of your data and prevent its alteration, loss, treatment, or unauthorized access, taking into account the state of technology, the nature of the data stored, and the risks to which they are exposed.

**What are your rights when you provide us with your data?**

1) **Right of access:** You may consult your personal data processed by the organization.
2) **Right of rectification:** You may modify your personal data when they are inaccurate.
3) **Right of opposition:** You may request that your personal data not be processed.
4) **Right to erasure:** You may request the total or partial deletion of your personal data. This does not mean that your data will be completely deleted, but rather that your data will

be kept blocked in a way that prevents their processing, without prejudice to their availability to public administrations, courts, and tribunals, for the attention of possible responsibilities arising from the processing during its statute of limitations. Once this period has elapsed, your data will be duly deleted or anonymized.
5) **Right to data portability:** You have the right to transfer the data you have provided to us and those obtained from your contractual relationship to another data controller. This right can only be exercised when the processing is based on the execution of a contract or your consent and the processing is carried out by automated means.
6) **Right to limit processing:** You may request the limitation of processing of your data in the following cases:
– While the accuracy of your data is being contested
– When the processing is lawful, but you oppose the deletion of your data.
– When the organization no longer needs to process your data, but you need them for the exercise or defense of claims.
– When you have objected to the processing of your data, for the fulfillment of a mission of public interest or for the satisfaction of a legitimate interest, while it is verified whether the legitimate reasons for processing prevail over yours.

You may exercise your rights free of charge, proving your identity by providing a copy of your ID card or equivalent document, by sending us your request by email or by post to the data provided in the section regarding the data controller.

However, you may file a complaint with the Spanish Data Protection Agency (www.agpd.es).

**Accuracy and truthfulness of the data**

The data subject or their legal representative is solely responsible for the truthfulness and correctness of the data provided, relieving RESIDENCIA MH GRANADA S.L. (COLEGIO MAYOR MONTAIGNE) of any responsibility in this regard. Data subjects guarantee and respond, in any case, for the accuracy, validity, and authenticity of the personal data provided, and undertake to keep them duly updated. The data subject agrees to provide complete and correct information to the data controller.

**Modifications**

RESIDENCIA MH GRANADA S.L. (COLEGIO MAYOR MONTAIGNE) reserves the right to modify this information to adapt it to legislative developments that may arise or to new data processing that may be carried out in the future. In these cases, the changes introduced shall be communicated to the interested parties with reasonable advance notice before their implementation.