Privacy Policy

1.1. USER DATA COLLECTION AND TREATMENT

Within the scope of the website hosted at www.eaglearuba.com, www.eaglearuba.com/timeshare, detailed information on how the entities of the EAGLE ARUBA RESORT, represented here by EAGLE ARUBA RESORT OPERATING CORPORATION., a public limited company with head office at J.E. IRAUSQUIN BLVD. #248, EAGLE BEACH, ARUBA, registered at the Chamber of Commerce of Aruba with the id/person/tax number 5034562 (EAGLE ARUBA RESORT process their personal data.

As a rule, Personal Data is requested when the User registers on the Site, requests a contact and/or sending newsletters, subscribes to a certain service, provides or requests information, acquires a product or establishes a contractual relationship with EAGLE ARUBA RESORT, namely when he/she makes a reservation on one of our hotels.

The Personal Data collected and processed is generally the following: name, gender, date of birth, telephone, mobile phone, email, address, identification number, credit card data (collected for billing purposes only), although other Personal Data may be collected if necessary or appropriate for the provision of services by EAGLE ARUBA RESORT.

After the collection of Personal Data, EAGLE ARUBA RESORT provides the User with detailed information about the nature of the data collected and about the purpose and processing that will be performed on the Personal Data, as well as the information mentioned in clause 8. EAGLE ARUBA RESORT also collects and processes information about the characteristics of the user’s hardware device, your IP and browser/software features, as well as information about the pages visited by the User within the Site. This information may include browser type, domain name, access times and links by which the User has accessed the Site (“Usability Information”). We only use this information to improve the quality of the user’s visit to our Site and, when you give your consent, we will send you commercial and marketing information adapted to your profile.

Usability Information and Personal Data are designated in this Privacy Policy as “User Data”. For the purposes of this Privacy Policy, a contractual relationship means any contract established between EAGLE ARUBA RESORT and its related entities, regardless of their purpose.

1.2. PERSONAL DATA TRANSFER TO THE THIRD PARTIES

The User Data collected by EAGLE ARUBA RESORT is not shared with third parties without the User’s consent, except in the situations mentioned in the following paragraph. However, in the event of the User contracting services with EAGLE ARUBA RESORT that are provided by other entities responsible for the processing of personal data, User Data may be consulted or accessed by such entities, to the extent that it is necessary for the provision of such data services.

EAGLE ARUBA RESORT may transmit or communicate the User Data to other entities in the event of such transmission or communication being necessary for the implementation of the contract established between the User and EAGLE ARUBA RESORT or for pre-contractual procedures at the request of the User, if necessary for the fulfilment of a legal obligation to which EAGLE ARUBA RESORT is subject or, if it is necessary, to obtain them in the legitimate interests of EAGLE ARUBA RESORT or of a third party. In the event of the transmission of User Data to third parties, reasonable efforts will be made to ensure that the transmitting entity employs the User Data transmitted in a manner appropriate to this Privacy Policy.

When a User reserves a stay in one of our hotels, his/ her personal data will be processed for accession and management of the assistance insurance available to all customers during their stay at EAGLE ARUBA RESORT hotels. For the present purposes, EAGLE ARUBA RESORT will transmit the following personal data to TravelClick iHotelier Amadeus Hospitality company PLEASE CHECK THEIR PRIVACY POLICY., which will act as Data Controller: full name, nationality, date of birth, passport or citizen card number, country of origin, check-in date, check-out date. For more information on how Travell Click processes your personal data, please consult their PRIVACY POLICY.

I) Data communication to the processors
As part of the processing of User Data, EAGLE ARUBA RESORT uses or may use processors who’s on its behalf, and in accordance with its instructions processes the User’s Data, in accordance with the law and this Privacy Policy.

These processors may not transmit the User Data to other entities without the prior written authorization.

EAGLE ARUBA RESORT undertakes to only subcontract the processors that have implemented the appropriate technical and organizational measures, in order to guarantee the defense of the User’s rights. All entities sub-contracted by EAGLE ARUBA RESORT shall be bound by EAGLE ARUBA RESORT by means of a written agreement which covers: the object and duration of the processing, the nature and purpose of the processing, the type of personal data, the categories of data subjects and the rights and obligations of the parties and other obligations provided by the article 28 of GDPR.

We are listing below the processor’s categories to which the personal data of the EAGLE ARUBA RESORT website users and guests is communicated:

Processors Categories
Processing of Personal Data Purposes

• Licensing, maintenance, support and technical software and systems technical support
• Management / maintenance / systems and software support to the EAGLE ARUBA RESORT's activity
• Payment service processing, EDI and electronic billing services, accounting, tax and administrative management companies and business support software
• Economic and accounting management of the invoicing of the guests, suppliers and service providers
• Commercial Promoters Promotion / Sale of EAGLE ARUBA RESORT services
• Direct marketing support companies / digital marketing partners
• E-mail marketing sending assistance, performances' analysis and disclosure of publicity
• Guest Intelligence solutions providers
• Sending of the guest satisfaction surveys
• Security companies and preventive and corrective maintenance of security systems companies
• Video surveillance and surveillance for the security of people and properties
• Guest stay management companies
• Services provision related to the stay of guests in the establishments of EAGLE ARUBA RESORT
• Provision of guest services companies
• Guests contact and support

II) Data communication of other recipients
EAGLE ARUBA RESORT can further communicate to other third parties not qualified as processors pursuant to the article 4 (8) of the GDPR. This entities are subject to confidentiality and may not transmit the User’s and guests’ Data to other entities without prior written authorization of EAGLE ARUBA RESORT to do it , ensuring that they process personal data in accordance with the provisions of the GDPR. EAGLE ARUBA RESORT communicates the data to other recipients, in detail: Recipientes Categories Processing of Personal Data Purposes Temporary-work agencies Temporary transfer of workers Companies that explore commercial establishments inside EAGLE ARUBA RESORT Hotels Supplementary services provided to guests Insurance Companies Customer Service Insurance Companies providing various services during the guest's stay at the EAGLE ARUBA RESORT facilities Parking, car rental and garden maintenance services Travel agencies and tour operators Reservations Advisers or Lawyers Provision of consultancy services and legal services Different companies of additional services requested by guests Taxi service / Transfers to the airport, car parking services, car rental, restaurants reservations and other activities requested by guests

1.3. DATA COLLECTION CHANNELS

EAGLE ARUBA RESORT may collect data directly (i.e., directly from the User) or indirectly (i.e. via partner entities or third parties).

Such collection may be done through the following channels:
        • Direct collection: in person, by telephone, e-mail and through the Site;
        • Indirect collection: through partners or group companies and official entities.

2. GENERAL PRINCIPLES APPLICABLE TO THE PROCESSING OF USER DATA

In terms of general principles regarding the processing of personal data, EAGLE ARUBA RESORT undertakes to ensure that the User Data processed by it is:

• Subject to processing in accordance with the law, as well as being fair and transparent in relation to the User;
• Collected for specific purposes that are objective and legitimate, not being processed subsequently in any way that runs contrary to these purposes;
• Appropriate, justified and limited to what is necessary in relation to the purposes for which these data are processed;
• Accurate and updated whenever necessary with all necessary measures being taken to ensure that inaccurate data, taking into account the purposes for which they are processed, are erased or corrected without delay;
• Kept in a manner that allows the identification of the User only for the period necessary for the purposes for which the data are to be processed;
• Handled in a manner that ensures data security, including protection against their unauthorized or illegal treatment and against their loss, destruction or unforeseen damage, with appropriate technical or organizational measures being taken. Data processing carried out by EAGLE ARUBA RESORT is permitted and legitimate when at least one of the following situations occurs:
• The User has given his/her free, positive, explicit and unequivocal consent to the processing of his/her for one or more specific purpose;
• The processing is necessary for the implementation of a contract in which the User is a party, or for pre-contractual procedures at the request of the User; • The processing is necessary for the fulfilment of a legal obligation to which EAGLE ARUBA RESORT is subject;
• Processing is necessary for the defense of the vital interests of the User or another individual;
• The processing is necessary for legitimate interests pursued by EAGLE ARUBA RESORT or by third parties (unless the interests or fundamental rights and freedoms of the User requiring the protection of personal data prevail).

EAGLE ARUBA RESORT undertakes to ensure that the processing of User Data is only done under the conditions cited above and respecting the principles mentioned above.

When the processing of the User Data is performed by EAGLE ARUBA RESORT is based on the User’s consent, the User has the right to withdraw his consent at any time. Such withdrawal of the consent, however, does not jeopardize the legality of the processing carried out by EAGLE ARUBA RESORT, based on the consent previously given by the User.

The length of time during which the data is filed and stored varies according to the purpose for which the information is being processed, being stored only for the necessary time for the fulfilment of the purposes for which they are processed, taking into account the Data Retention Policy approved by EAGLE ARUBA RESORT.

Effectively, there are legal requirements that require the data to be preserved for a minimum period. Thus, and where there is no specific legal obligation, the data will be stored and kept only for the minimum period necessary for the purposes that led to their collection or subsequent processing, which at the end of the period will be eliminated.

3. USE AND PURPOSES OF THE DATA PROCESSING

In general, EAGLE ARUBA RESORT uses the User Data for the following purposes:

• Provision of hotel services and associated services (restaurants, bars, spa, etc.);
• Billing and invoicing the User;
• Registration of users on the Site;
• Providing information to the User, who has requested it, on new products and services that have been made available on the Site and/or at the hotel units, special offers and campaigns, updated information on EAGLE ARUBA RESORT’s business operations and, generally, for the purpose of marketing EAGLE ARUBA RESORT and its hotel units, using any means of communication, including electronic media;
• Allowing access to restricted areas of the Site, in accordance with previously established terms;
• Ensuring that the Site meets the User’s needs by developing and publishing content that is best adapted to the requests made and the type of User, improving the search capabilities and functionalities of the Site and obtaining associated or statistical information regarding to the user’s profile (analysis of consumption profiles)
• Providing services, and other peripherals, such as newsletters, opinion surveys, or other information or products requested or purchased by the User;
• Accessing and management of the assistance insurance available to all clients during their stay at the EAGLE ARUBA RESORT units;
• Sending Satisfaction Surveys;
• Recording of telephone calls that may be made in connection with the solicitation or provision of information about reservations, vouchers and other products or services and their commercial conditions of use and the establishment of any contractual relationship, either during the formation phase of the contract or while it is in force.

EAGLE ARUBA RESORT may combine Usability information with anonymous demographic information for research purposes, and we can use the result of this combination to provide relevant content on the Site. In certain restricted areas of the Site, EAGLE ARUBA RESORT can combine Personal Data with Usability information to provide the User a more personalized content.

4. TECHNICAL, ORGANIZATIONAL AND SECURITY MEASURES IMPLEMENTED

In order to guarantee the security of the User Data and maximum confidentiality, EAGLE ARUBA RESORT treats the information you provided to us in an absolutely confidential manner, in accordance with its internal security, and confidentiality policies and procedures, which are updated periodically as required, as well as the terms and conditions legally set out.

As a function of the nature, scope, context and purpose of data processing, as well as the risks arising from the treatment of the rights and freedoms of the User, EAGLE ARUBA RESORT undertakes to apply, both when defining the method and timing of handling the data, the technical and organizational measures necessary and appropriate for the protection of User Data and compliance with legal requirements.

It also undertakes to ensure that, by default, only data that are necessary for each specific handling purpose are processed and that such data are not made available without human intervention to an indeterminate number of people. Communication between the user’s device and the EAGLE ARUBA RESORT Site is done through secure channels and communications using the HTTPS protocol and the SSL security standard. Nevertheless, in terms of general measures, EAGLE ARUBA RESORT adopts the following:

• Regular audits to identify the effectiveness of the technical and organizational measures implemented;
• Sensitization and training of personnel involved in data processing operations;
• Pseudonymization and coding of personal data;
• Mechanisms capable of ensuring the permanent confidentiality, availability and resilience of information systems; Mechanisms to ensure the restoration of information systems and access to personal data in a timely manner in the event of a physical or technical incident;

5. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

EAGLE ARUBA RESORT will not transfer your personal data to recipients in countries inside or outside the European Union, which may have different levels of personal data protection.

Consequently, EAGLE ARUBA RESORT is concerned to adopt appropriate measures to ensure the secure storage your personal data and from your personal data are collected.

6. USE OF COOKIES

When you visit the Site, a small text file (Cookie) is created and recorded on your computer disc. These text files will allow a more personalized and efficient navigation experience. Each time you visit the Site, your internet browser sends these cookies back to the Site, allowing the recognition and the identification of the Users, as well as their usage preferences. These Cookies will only be installed with your express consent, except in cases where they are necessary for the operation of the Site.

As to the necessary cookies, you can delete or block them in the "Help" menu on your browser, where you will find how to do it. However, if you do not allow the use of cookies, there may be some functionality of the Site that you will not be able to use.

I- What are Cookies?
Cookies are small software files, which are stored on your device through the browser, and that hold a certain amount of data, namely, regarding the state of the navigation, and the activity during you are browsing. These cookies data can then be retrieved and can allow us to customize our web pages and services accordingly, through the information previously introduced on the Website.

II- What cookies do we use?
    Necessary Cookies to:

• (i) Allow the navigation on the website;
• (ii) Use website’s features, such as accessing secure areas and exclusive contents for registered Users.

    Functionality Cookies to:

• (i) Record information about our Users options;
• (ii) Memorize what is in your shopping cart and, when applicable, remind you by email that there are unfinished reservations in the shopping cart;
• (iii) Allow the customization of our Website accordingly with your needs, namely, to memorize the language.

    Performance Cookies to:

• (i) Monitor how is your access to our Website and the regularity of this access.
• Session cookies to:
• (i) The reservation process, since this type of cookies are safer and can not be manipulated by third parties.
• (ii) We also use direct or indirect analytical services to assess the effectiveness of our content and the Users’ preferences, which help us with the optimization of the functioning of this Website.

We also use web beacons or tracking pixels to count the number of visitors to our Website, anonymously and without identifying any particular User. However, for registered Users who are connected to the Website we will combine this information with the data collected through cookies to analyze how Users navigate in this Website in more detail.

III- How to control cookies:
All recent versions of popular browsers give Users a level of control over cookies. Users can set their browsers to accept or reject all, or certain, cookies. Additionally, all Cookies, except the necessary Cookies, are subject to the User's consent.

Please note that, when you delete or block cookies, some functionalities of the website may be affected.

If you want to know more about how Cookies work, you can check the AboutCookies.org or Cookiecentral.com Websites.

IV- Cookies Security:
Since Cookies can be intercepted or changed, we take the following security measures:

• (i) Sensitive information – such as passwords or personal data such as the guest's address or telephone number – is not stored;
• (ii) Non-secure requests (HTTP) are not sent where cookies are sent to the browser in plain text and can be intercepted.

7. TOOLS USED FOR ANALYTICS AND USER BEHAVIOR

Google Analytics

In this Site is used Google Analytics, a web analysis service provided by Google Inc., (hereinafter “Google”).

The cookies are being recorded in order to provide information on the Site’s use. This data, including the user’s IP address, is transmitted to Google servers, but the data collected by Google Analytics is not related to any other data held by Google.

You may also deactivate the tool by downloading and installing a browser add-on available from Google: https://tools.google.com/dlpage/gaoptout?hl=en.

Facebook and Instagram

In the Site there is an interactivity with Facebook and Instagram through a connection with these social networks’ servers is established. This allows the social networks to identify the Site that the User is visiting, and potentially store other data such as the IP address.

If the user is also connected in these social networks, may also be associated the data with the User’s account. If the user wants to prevent this, should done log out from Facebook and/ or Instagram before visiting the webpage.

You can find more information about how Facebook and Instagram process data on their Sites: https://www.facebook.com/about/privacy/ and https://help.instagram.com/519522125107875.

Twitter

The Site has an interactivity with Twitter Inc.(hereinafter “Twitter”). When you access a webpage using such buttons, a connection with Twitter’s servers is established. This allows Twitter to identify the Site that the User is visiting, and potentially store other data such as the IP address.

You can find more information about how Twitter processes data on Twitter Site: https://twitter.com/privacy.

Youtube

The Site has an interactivity with Youtube through a connection with this website servers is established. This allows Youtube to identify the Site that the User is visiting, and potentially store other data such as the IP address.

If the user is also connected in Youtube, may also be associated the data with the user’s account. If the user wants to prevent this, should done log out from your Youtube account before visiting the webpage.

You can find more information about how Youtube processes in the following link: https://www.youtube.com/intl/en-GB/yt/about/policies/#community-guidelines.