1. DATA CONTROLLER IDENTIFICATION
- Legal name: CASA ESTRADA (Inmobiliaria Marnata S.A.S.)
- NIT: 901625523-1
- Registered address: Carrera 4 #35-28 Calle de la Iglesia. Centro Histórico de Cartagena. Colombia.
- Email 1: gerencia@casaestrada.com.co
- Email 2: casaestrada@gmail.com
- Mobile phone: +57 310 674 3599
CASA ESTRADA, in its capacity as Data Controller, adopts this Personal Data Processing Policy in accordance with Law 1581 of 2012, which establishes the general provisions for the protection of personal data in Colombia.
2. SCOPE
This policy applies to all personal data collected, stored, used, circulated, or deleted by CASA ESTRADA in relation to:
- Current and prospective guests
- Authorized accompanying guests and visitors
- Users of website and digital channels
- Participants in private events
- Corporate clients
3. RELEVANT DEFINITIONS
- Authorization: Prior, express, and informed consent given by the Data Subject for the processing of personal data.
- Database: An organized set of personal data that is subject to processing.
- Personal Data: Any information linked or that may be associated with one or more identified or identifiable natural persons.
- Sensitive Data: Information that affects the privacy of the Data Subject (health information, biometric data, medically related dietary preferences, etc.).
- Data Processor: A natural or legal person, public or private, who, by itself or in association with others, processes personal data on behalf of the Data Controller.
- Data Controller: A natural or legal person, public or private, who, by itself or in association with others determines the purposes and means of the processing of personal data.
- Data Subject: Natural person whose personal data is subject to processing.
- Processing: Any operation or set of operations performed on personal data, such as collection, storage, use, circulation, or deletion.
4. DATA COLLECTED
CASA ESTRADA may collect, among others:
4.1 Identification Data
- Full name
- Identification number
- Nationality
- Date of birth
4.2 Contact Information
- Address
- Phone number
- Email address
4.3 Financial Information
- Credit or debit card information
- Payment history
4.4 Sensitive Data (when applicable and with explicit authorization)
- Dietary restrictions due to medical reasons
- Information regarding reduced mobility
- Biometric data (video surveillance)
5. PURPOSES OF DATA PROCESSING
The data will be processed for the following purposes:
1. To manage reservations and check-in/check-out processes.
2. To comply with legal obligations to the competent immigration, tax, and tourism authorities.
3. To ensure the safety and security of guests and the property (video surveillance).
4. To personalize the guest experience (gastronomic preferences, room preferences, etc.).
5. Billing and accounting management.
6. Sending commercial information, loyalty programs, and exclusive experiences (subject to prior authorization).
7. Management of private events and personalized premium services.
6. GOVERNING PRINCIPLES
CASA ESTRADA shall apply the following principles:
- Legality: The processing referred to in this policy is a regulated activity and must comply with the provisions set forth herein and with the applicable legal regulations governing personal data protection.
- Purpose: Processing must be carried out for legitimate purposes in accordance with Section 5 of this document.
- Freedom: Processing may only be carried out with prior, express, and informed consent of the Data Subject. Personal data may not be obtained or disclosed without prior authorization, unless a legal or judicial mandate waives such consent.
- Accuracy: Information subject to processing must be truthful, complete, accurate, up to date, verifiable, and understandable.
- Transparency: Processing must guarantee the right of the Data Subject to obtain from the Data Controller, at any time and without restrictions, information regarding the existence of data concerning them.
- Limited Access and Disclosure: Processing shall be subject to the limits derived from the use of personal data.
- Security: All information shall be handled with the technical, human, and administrative measures necessary to ensure the security of records and to prevent their alteration, loss, consultation, use, or unauthorized or fraudulent access.
- Confidentiality: All individuals involved in the processing of non-public personal data are obligated to guarantee the confidentiality of such information.
7. RIGHTS OF DATA SUBJECTS
Guests may exercise the following rights:
- To know, update, and rectify their personal data.
- To request proof of the authorization granted for the processing of their personal data.
- To revoke such authorization and/or request the deletion of their personal data when there is no legal or contractual obligation preventing it.
- To file complaints with the Superintendencia de Industria y Comercio.
8. AUTHORIZATION
CASA ESTRADA will obtain prior, explicit, and informed authorization from the Data Subject for the processing of personal data, which may be obtained through, including but not limited to:
- Physical registration forms
- Digital platforms
- Electronic confirmation
- Recorded telephone calls
When sensitive data is requested, the Data Subject will be informed that providing such data is optional.
9. SECURITY MEASURES
CASA ESTRADA implements the following measures:
- Restricted access protocols for databases
- Secure passwords and encryption
- Confidentiality clauses with employees and service providers
- Video surveillance systems with controlled access
- Security incident response procedures
10. DATA TRANSFER AND SHARING
Personal data may be shared, disclosed with (third-party):
- Payment service providers
- International booking platforms
- Competent authorities
- Technology service providers
Always subject to confidentiality agreements and in compliance with applicable legal and regulatory requirements.
11. DATA RETENTION PERIOD
Personal data will be retained only for as long as necessary to fulfill the purposes described in this Policy and to comply with applicable legal and regulatory obligations, including those related to accounting, tax, and hospitality matters.
12. PROCEDURE FOR EXERCISING RIGHTS
Requests shall be submitted to:
CASA ESTRADA shall respond within the timeframes established by applicable Colombian law.
13. EFFECTIVE DATE AND UPDATES
This Policy shall enter into force as of its publication and may be modified at any time. Any updates will be made available on CASA ESTRADA’s website.
.
