Privacy Policy

With this Privacy Policy, La Borda del Pi, S.A. (hereinafter, "we" or Borda del Pi) informs you of the personal data we collect through the services we offer and are reflected through this website, how we treat the data and the rights you have in relation to your personal data and our treatments are governed by the Personal Data Protection regulations that apply to us.

 

Applicable regulations
  1. Law 29/2021, of October 28, Qualified Protection of Personal Data of the Principality of Andorra - ‘Llei Qualificada de Protecció de Dades Personals’ (hereinafter, the “LQPD”) and the regulations that develop from it, and
  2. Regulation (EU) 679/2016 of the European Parliament and of the Council, of April 27, 2016, relating to the protection of the personal data of natural persons with respect to the processing of personal data and the free movement thereof (hereinafter, the “GDPR" – General Data Protection Regulation).

In the following table you will find links to facilitate access to the points of this policy that are of interest to you, however, please, you must read all the sections of the Legal Advice document, the Cookies Policy and this Privacy Policy before using this website:

 

  1. To whom does this Privacy Policy apply?
  2. Who is responsible for the processing of your personal data?
  3. How do we obtain your personal data?
  4. What do we use your data for and on what legal basis do we do it?
  5. Who can we share your personal data with?
  6. How long do we keep your personal data?
  7. What rights do you have?
  8. What are your responsibilities?
  9. How do we protect your personal data?
  10. Modifications to this Privacy Policy

 

1. To whom does this Privacy Policy apply?

This policy applies to people who interact with Borda del Pi through this website, to users of the services that Borda del Pi offers for the purposes described in Section 4 of this policy (the services), and to all persons whose personal data (for example, their images) may appear on our website or in the context of the services.

 

2. Who is responsible for the processing of your personal data?

The sole person responsible for the processing of your personal data in accordance with what is indicated in this policy is:

Borda del Pi, with NRT F-043042-V and registered office at Carretera de Montaup, km 5.5, AD100 Canillo (Principality of Andorra).

We have a Data Protection Officer who you can contact via the email info@bordapi.ad.

La Borda del Pi is not responsible for the activities carried out by other websites, even if you access them through links on our website. That is why we strongly recommend that you carefully read the information provided by these other responsible parties before giving them your personal data (especially the privacy and cookies policies of each website you visit), and that you communicate with these responsible parties if you have any concerns or questions.

 

3. How do we obtain your personal data?

In general, it is you who, directly, provides us with personal data – for example, through the forms on this website. The only exceptions to this rule are:

  • Your voice and/or your image, when it is eventually collected by our video surveillance cameras.
  • Photographs of events we organize or participate in, and in which you may appear.
  • The photographs that visitors upload to the website, in accordance with the corresponding terms and conditions, and therefore, with your consent.
  • The images that correspond to some news in which we consider that the public interest and the right to information prevail over the possible interests of the people whose image or other personal data are published on our website.
  • Personal data provided to us by third parties who reserve or purchase services on your behalf (as the beneficiary).
  • Personal data about you that may appear in the emails and instant messages we receive, or through the forms on our website.
  • The cookies of this website, about which you will find more information in our Cookies Policy.

 

4. What do we use your data for and on what legal basis do we do it?

To manage your stay in our facilities

We collect your data for the purpose of:

  • Completing the arrival and departure registration.
  • Collecting a copy of the identity documents of all the guests for the police authorities.
  • Processing your promotional codes and your payments.
  • Providing you with a consistent and personalized service, advising you on the services you can enjoy in our facilities (based on the use you have previously made of them or on the preferences you have communicated to us).
  • Facilitating the catering service (which includes respecting dietary restrictions, health or any other type of personal needs that you communicate to us).
  • Managing the rest of your requests and queries, or your complaints and suggestions.
  • Determining if you meet the requirements to enjoy products and services with age restrictions (such as alcohol).

The bases that legitimise us to treat your data in relation to each of the above purposes are the fact that it is necessary for the execution of the contract of sale of your stay in our facilities or, our legal obligations (for example, regarding the collection of identity documents or the issuing of invoices), the consent you express by telling us your food preferences, and our legitimate interest in respecting your preferences.

 

To manage your reservations online or by phone

We process the data you provide us in relation to reservations, products or promotions that combine our services and products with those of our collaborators, in order to formalise your reservation and communicate to you by email or telephone any information related to this, as well as to manage and issue documents certifying the reservation and any related communication that is necessary for the formalisation of this.

The basis that legitimises these treatments is the sales contract or the product or service reservation agreement that you sign when completing the reservation.

 

To analyse your assessment of our services and the interest our marketing campaigns generate in order to improve

We can process the data you provide us, for example during the reservation of products or services, to request your assessment of the care received.

We may also extract aggregate statistics (i.e. statistical results which do not include personal information of any kind) in relation to the interest generated by our marketing campaigns.

The basis that legitimizes these treatments is our legitimate interest in improving the quality of our services and the events we manage or promote, as well as our marketing campaigns.

 

To send you information, promotions and discounts of your interest

We collect your e-mail when you subscribe to our commercial communications service to send you our catalogues by e-mail and to inform you about news, discounts or promotions, and contests or raffles so that you can make the most of our facilities and our services.

Additionally, we process your email that you give us when you register or purchase our services and when we inform you about news, events, exclusive content, discounts or promotions and contests or draws, so that you can make the most of the services in which you are interested.

If you have subscribed through our website, the legal basis for this treatment is your consent, and you can withdraw it at any time by exercising your right as indicated later in this policy, or through the link at the foot of each email.

The only consequence of withdrawing consent is that you will no longer receive the information we have sent you by email, and you will no longer be able to participate in promotions reserved for our subscribers.

If you receive the information because you have purchased one of our services, the legal basis for this treatment is our legitimate interest in keeping you informed about our products and services related to those you have purchased, which you can object to at any time. as in the previous case and with identical consequences, exercising your right as indicated later in this policy or through the link to that effect at the foot of all our emails.

 

To attend to your requests, queries or complaints

We collect the personal data you provide us in your e-mails, by telephone, or through the form on the contact page, or through requests to exercise rights, to attend to your requests, inquiries or complaints in relation to our services or the rights you have over your personal data.

The legal bases for this treatment are the consent you express when sending or giving us this data, our legal obligation to attend to your rights requests, and our legitimate interest in attending to you. The supply of your personal data is therefore voluntary, although if you do not provide it, we will not be able to process your request, query, or claim. You can revoke your consent whenever you wish, although such revocation will also make it impossible to continue processing your request, inquiry or claim.

 

To manage any future claims

We retain the data that may be necessary to manage your possible claims, or ours, on the basis of our legitimate interest in defending ourselves to safeguard our rights.

 

To control access to our facilities, events or services through tickets or credentials

We use the data of your reservation, and sometimes that of your identity document, to authorise or deny your access to the restricted areas of our events, facilities or services, to analyse and control the occupancy and logistics of the different areas, and to ensure your health and safety.

The legal basis of this treatment is the agreed service contract to which you are a party, our legitimate interest in avoiding unnecessary accumulations of people.

 

To guard and return items you lose in our facilities

If you have lost a mobile phone or any other object containing personal data and it is found or delivered to us, we will hold that personal data until the rightful owner of the lost object successfully claims it at our customer service point or, after a reasonable period of time, we will hand it over to the police authorities so that they are the ones who manage its custody and eventual return.

The legal basis for our treatment of the personal data of mobile phones, wallets, backpacks and other objects that may contain personal data in this way is our legitimate interest in preventing their theft and returning them to you.

 

To give media coverage to events

If you participate in person at our events or awards, the independent press and our own professionals may record your image and, sometimes with prior arrangement, your voice, in the context of the event or award.

The legal basis for this processing of your image is our legitimate interest in the media coverage of the events we organize or sponsor for the purpose of using the recordings in their promotional materials, including our website and our social network accounts.

You are not obligated to appear in a recording. If you wish, you have the right to object to our legitimate interest and request the removal of material in which you are identified. To be able to evaluate your objection to our legitimate interest, and if necessary to immediately remove the images that identify you, we will ask you to tell us where you saw them.

 

To promote our facilities, products and services

If you have entered into a contract or an agreement to cede image rights to us, we may collect photographs or videos of our facilities, products, or services in which you are identified, and perhaps heard, to then use them in promotional campaigns or publish them in the media such as the national or international press, our website, or our social networks. If you have signed an authorisation to give us the rights to use your image, we inform you that you can revoke it at any time, as a result of which we will remove your image from our website and/or our networks, without the revocation having any effect on the dissemination of your image that took place before it was processed.

Additionally, we may graphically record the atmosphere of our facilities to promote our premises, and its products and services and, eventually, your image may appear in this graphic material. Contrary to what is indicated in the previous paragraph, in this case the legal basis for the treatment of your images is our legitimate interest, which you can oppose at any time if you consider that it is contrary to your own interests. In order to be able to evaluate your opposition to our legitimate interest, and, in your case, to immediately remove the images that identify you, we will ask you to tell us where you saw them.

 

To preserve security through video surveillance

We collect your image through our video surveillance systems in order to preserve the safety of people, property and the facilities themselves.

The bases of legitimacy for the aforementioned treatment are the public interest in public safety, our legitimate interest in the security of our establishments, and the legitimate interest of third parties who wish to seek judicial protection for a crime that may be proven by minutes of a recording.

 

To select and hire our staff

We process the CV data that you voluntarily send us to manage the relationship with candidates for a job at Borda del Pi, including the process of searching, filtering and storing the CVs. of potential candidates, the selection process of personnel and the recruitment process.

The legal bases for the aforementioned treatments are your consent, which you express when you send us your CV, the execution of pre-contractual measures, and if we do not have an open recruitment process or you are not selected and we consider that you can fit in future selection processes, our legitimate interest in keeping your CV to include it in these future processes.

 

To guarantee the operation of our website (functional cookies)

We use functional cookies to guarantee the correct operation of our website.

Since these are cookies necessary for the proper functioning of the website, their use does not require you to give us your express consent, and the basis that legitimizes us to use them is our legitimate interest in being able to offer you the services of our website.

You can find more information about these cookies in our Cookies Policy.

 

To extract aggregate statistics of the use of our website (analytical cookies)

We use analytical or statistical cookies to identify the most and least visited pages, analyse which content is of greatest interest to our visitors, and measure the success of our information campaigns, all with the aim of improving the services that we offer you through the Web. All these purposes provide aggregated results, in which it is not possible to identify the interests of any particular person.

In the treatment of analytical cookies, we will not use them until we have your consent, and not giving it to us, or withdrawing it, will have no more effect than hindering our goal of improving the website through the analysis of the aggregate statistics of our visitors' browsing.

You can find more information about these cookies in our Cookies Policy.

 

To improve the interest of the advertising you receive (advertising cookies)

We download advertising cookies from third parties. These files help them infer your interests based on the pages you visit, the content you click on, and other actions you take online.

In dealing with non-necessary cookies, we will not use them until we have your consent, and not giving it to us, or withdrawing it from us, will have no effect, apart from the fact that your visit to our website cannot be used to improve the interest of the advertising you receive.

You can find more information about these cookies in our Cookies Policy.

 

To be able to use Google services

Additionally, as an obligation that Google LLC, the company of which Google Ireland Ltd is a subsidiary, imposes on entities like us that use the Google Analytics and Google Ads tools, we inform you that these two services are operated by Google Inc., domiciled at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and that Google Inc. is a beneficiary of these.

The information generated by the cookies about your use of this website and your advertising preferences is generally transmitted to a Google server in the USA and stored there. If you wish to obtain more information, you can consult how Google uses the information on our website and/or Google's Privacy Policy regarding the aforementioned services.

We inform you that we have enabled the IP anonymisation feature on our website to add additional safeguards in the standard contractual clauses that protect this international transfer of data to the US. With this, Google will shorten your IP address before transmitting it to the USA (the process of obfuscating its identity). Only in exceptional cases is the full IP address sent to a Google server in the USA and shortened there. Google guarantees that the IP address transmitted by your browser to Google Analytics will not be processed together with any other data held by Google.

You can consult the categories of personal data processed by these services at:

privacy.google.com/businesses/adsservices

 

To notify you of security breaches

At Borda del Pi we take security measures appropriate to the level of risk to protect personal information against loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information; however, if we determine that your data has been misused (even by an employee or former employee of Borda del Pi), has been exposed through a security breach, or has been improperly acquired by a third party, exposing you to a high risk, we will immediately inform you about this security breach, misappropriation or acquisition, and about the measures we have taken and those we recommend you take, so that the breach does not affect you.

The bases that legitimise this treatment are the legal obligation set out in Article 37 of the LQPD (34 of the GDPR), and our legitimate interest in preventing this security breach from harming you.

 

For other purposes that are not incompatible with the above

We may use your personal data for other purposes that are not incompatible with those indicated above (such as archival purposes for reasons of public interest, scientific or historical research purposes, or statistical purposes) whenever permitted by the current law concerning personal data protection, and, of course, while acting in accordance with this and the rest of the applicable regulations.

 

5. Who can we share your personal data with?

We do not give your personal data to anyone, unless:

  • You yourself request it.
  • We have a legal obligation to do so.
  • We act as intermediaries, for example, when we need to make a booking on your behalf (for example, for an activity).
  • We are co-responsible for the collection of data, so that, always with your consent, other entities treat the data in their name.

This is the case of:

Google Ireland Ltd, with registered office at 4 Gordon House Street, Barrow, Dublin, Ireland, to whom we have entrusted the processing of the data of the cookies necessary to use its reCAPTCHA, Analytics and Ads services. Google Ireland Ltd acts as an independent controller for all processing carried out on its behalf in accordance with its privacy policy. We transfer data to Google Ireland Ltd on the basis of the data protection agreement that this company located in the EU includes in the addendum to the standard contract for countries suitable for GDPR, as is the case of Andorra, in which we add the additional safeguard of activating the anonymisation of the IPs that collect the cookies. In our Cookies Policy you will see which analytical and advertising cookies are offered to you by us and how to configure them.

  • We need to protect your rights, our rights, those of our employees, or those of third parties (which may require disclosure to the police for security reasons or to health authorities to prevent the spread of disease, such as for the purpose of tracing contacts). For example:

o If our video surveillance cameras record a theft on our premises, or

o If a third party requests video surveillance images from us on the basis of their legitimate interest in requesting effective judicial protection when a crime has been perpetrated or compensation for damages is evidenced by the images provided, with the commitment of the said third party to use the images exclusively for the reporting of this crime or for the claim for the damages suffered, and reducing the transfer of images to the minimum that are indispensable to fulfil the purpose pursued.

Any international transfer that we eventually need to carry out will comply with what is established by the regulations in force that apply to us at any given time.

 

6. How long do we keep your personal data?

Borda del Pi keeps your personal data exclusively for as long as the treatments that require them last and, then, for as long as it takes to deal with the legal responsibilities that apply to us at any given time, derived from the treatment in question (including the obligation to be able to demonstrate that we have responded to your request for the destruction of personal data).

For example, we will retain video surveillance recordings for a maximum of 30 days when they are incident-free, and, exceptionally, if a security incident has occurred during this period or there are indications that a crime has been committed (for example, a theft ), we will extract a copy of the part of the recording that records the incident and it will be kept until it is handed over to the police or to the interested party involved who requires it from us to prove their request for judicial protection.

We will destroy your CV when it is more than five years old, in consideration that it is out-of-date in relation to the purpose for which it is dedicated.

When we do not have a legitimate purpose for processing some of your personal data, we will delete or anonymise it, and if this is not possible (for example, because it is found in backup copies), we will store it securely and block it to isolate it from any further processing until its removal is possible.

 

7. What rights do you have?

You have the right to obtain confirmation as to whether or not we have any of your personal data.

We remind you that, when we share personal data with other responsible parties, you will have to exercise your rights directly against these responsible parties following the instructions provided in their own privacy policies. Specifically, in relation to the data that our cookies share with Google, we inform you that you can install in your browser Chrome, Internet Explorer, Safari, Firefox and/or Opera, the add-on to not send Google Analytics data or Google Ads at Google Inc.

Below, we explain what other rights you have and how to exercise them.

Your rights

In accordance with the provisions of the LQPD, you can request us to enforce the following rights:

  • Access to your personal data.
  • Rectification of some of your personal data, specifying the reason.
  • Deletion of some, or all, of your personal data.
  • Limitation of the processing of your data, specifying the reason for the limitation.
  • Opposition to the processing of your personal data.
  • The portability of your data when the basis of the legitimacy for the data collection has been consent or a contract.
  • The right not to be subject to automated individual decisions.

The consent given, both for the treatment and for the transfer of the data of the interested parties, can be revoked at any time by communicating it to us, just like any other right, as indicated in the following section. This revocation will in no case be retroactive.

How and where you can exercise your rights

You can exercise your rights:

  1. By sending a written request to Borda del Pi, to our postal address, indicated in Section ?2 of this policy, indicating a means of contacting you to be able to respond to your request, or to ask you for more information if necessary. We would appreciate it if you marked the envelope for us "Exercise of Personal Data Protection Rights".
  2. By sending the form associated with the right you wish to exercise to the email address info@bordapi.ad indicating in the subject "Exercise of Personal Data Protection Rights". You will find these forms later, in this very section of the privacy policy.

In both cases, if it is not possible for us to verify that you are who you say you are, we will ask you to please send us proof of your identity, and in this way ensure that we only respond to the interested party or their legal representative.

However, and especially if you consider that you have not obtained full satisfaction from the attention given to the exercise of your rights, we inform you that you can submit a claim to the national control authority of your country, or by contacting the Andorran Data Protection Agency (APDA).

Forms for exercising your rights

In order to make it easier for you to exercise your rights, we recommend that you use the application forms that correspond to the following:

 

8. What are your responsibilities?

By providing us with your data, you guarantee that it is accurate and complete. Likewise, you confirm to us that you are responsible for the veracity of the personal data that you have communicated to us and that you will keep them appropriately updated so that they respond to your actual circumstances, making yourself responsible for false or inaccurate personal data that you may provide us, as well as damages, direct or indirect, that could derive from your inaccuracy.

You cannot provide us with the personal data of other people unless it is justified in relation to the services you request from us. In whatever circumstances, if you provide us with the personal data of third parties, you assume the responsibility of informing the said third parties prior to providing us with their personal data. This information, which you must provide to the third parties whose data you supply to us, must include all the provisions provided for in this Privacy Policy, and it is you who are responsible for the lawfulness of this personal data and for transmitting to its holders the rights they have in relation to their personal data.

In cases where you have to provide us with the personal data of a person under the age of 16 or of a person with limited rights, in doing so you are obliged to have the authorisation of the holders of the parental authority or guardianship. Without this authorisation, it is forbidden to provide us with any of the personal data of these people.

 

9. How do we protect your personal data?

We are fully committed to the protection of your privacy and your personal data. We have drawn up a record of all the personal data processing activities that we carry out, we have analysed the risk that each of these activities may pose to you, and we have implemented the appropriate legal, technical and organisational safeguards to avoid, as far as possible, the alteration of your personal data, its misuse, loss, theft, unauthorised access, or unauthorised treatment. We keep our policies up-to-date appropriately to ensure that we provide you with all the information we have about the processing of your personal data, and to ensure that our staff receive appropriate guidance on how to handle your personal data. We have signed data protection clauses and data processing contracts with all our service providers, taking into account the need that each of them has to process personal data.

We restrict access to personal data to only those employees who really need to know it to carry out any of the treatments referred to in this policy, and we have trained and made them aware of the importance of confidentiality and maintaining the integrity and availability of information, as well as on the disciplinary measures that would be involved in any eventual infringement in this matter.

However, if Borda del Pi determines that your data has been misappropriated (even by an employee of La Borda del Pi), has been exposed through a security breach, or has been improperly acquired by a third party, Borda del Pi will immediately inform you of this security breach, misappropriation, or acquisition.

 

10. Modifications to this Privacy Policy

We will update this policy when necessary to reflect any changes in regulations or our treatments. If the changes are substantial, we will notify you before they become effective by sending you a notification or by publishing a prominent notice on this website, and you will have the option to exercise your rights as we informed you in a previous section. In any case, we recommend that you periodically review this Privacy Policy to learn how we protect your personal data.

If you have any questions about this policy, please feel free to let us know by emailing us at info@bordapi.com.

 

Last update: June 9, 2024

Location

Carretera de Montaup, km 5.5
AD100 Canillo
Principat d'Andorra

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