This Policy applies to individuals 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.

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

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

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

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

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

• Your voice and/or your image, when eventually collected by our video surveillance cameras.
• Photographs of events we organize or participate in, and in which you may appear.
• Photographs uploaded to the website by visitors, in accordance with the corresponding terms and conditions, and therefore, with your consent.

• Images corresponding to news items in which we consider that the public interest and the right to information prevail over the possible interests of the persons 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 a beneficiary).
• Personal data about you that may appear in emails and instant messaging we receive, or through the forms on our website.
• Cookies on this website, about which you will find more information in our Cookies Policy.

To manage your stay at our facilities

We collect your data for the purpose of:

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

The bases that legitimize us to process your data in relation to each of the above purposes are the fact that it is necessary for the execution of the purchase contract for your stay at our facilities or our legal obligations (for example, regarding the collection of identity documents or the issuance of invoices), the consent you express by indicating your dietary preferences, and our legitimate interest in respecting your preferences.

To manage your reservations online or by phone

We process the data you provide in relation to reservations, products, or promotions that combine our services and products with those of our partners, to formalize your reservation and communicate any related information to you by email or telephone, as well as to manage and issue documents proving the reservation and any related communication necessary for its formalization.

The basis that legitimizes these treatments is the purchase contract or the reservation agreement for the product or service that you sign upon completing the reservation.

To analyze your assessment of our services and the interest generated by our marketing campaigns for improvement

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

We may also extract aggregated statistics (i.e., statistical results that do not include personal information of any kind) regarding 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 interest to you

We collect your email when you subscribe to our commercial communications service to send you our catalogs by email and inform you about news, discounts or promotions, and contests or giveaways so that you make the most of our facilities and services.

Additionally, we process the email address you provide when you register or purchase our services to inform you about news, events, exclusive content, discounts or promotions, and contests or giveaways, so that you make the most of the services of interest to you.

If you have subscribed through our Website, the legal basis for this processing 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 bottom of each email.

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

If you receive information because you have purchased one of our services, the legal basis for this processing 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, by exercising your right as indicated later in this policy or through the link provided for this purpose at the bottom of all our emails.

To attend to your requests, inquiries, or complaints

We collect the personal data you provide in your emails, by phone, 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 basis for this processing is the consent you manifest by sending or giving us this data, our legal obligation to attend to your requests for rights, and our legitimate interest in serving you. The provision of your personal data is, therefore, voluntary, although if you do not provide it, we will not be able to process your request, inquiry, or complaint. You can revoke your consent whenever you wish, although such revocation will also make it impossible to continue processing your request, inquiry, or complaint.

To manage potential future claims

We retain data that may be necessary to manage your possible claims, or ours, based on 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 your reservation data, and sometimes those of your identity document, to authorize or deny your access to restricted areas of our events, facilities, or services, to analyze and control occupancy and logistics in different areas, and to ensure your health and safety.

The legal basis for this processing is the service contract to which you are a party and our legitimate interest in avoiding unnecessary crowds.

To safeguard and return objects you lose at our facilities

If you have lost a mobile phone or any other object containing personal data and we find it or it is handed to us, we will safeguard these personal data until the legitimate owner of the lost object successfully claims it at our customer service point or, after a reasonable time, we will hand it over to the police authorities so that they can manage its custody and eventual return.

The basis that legitimizes us to process personal data from mobile phones, wallets, backpacks, and other objects that may contain personal data is our legitimate interest in preventing their theft and returning them to you.

To provide media coverage for events

If you participate in person in our events or award ceremonies, the independent press and our own professionals may record your image and, on previously agreed occasions, your voice, in the context of the event or the award ceremony.

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 our promotional materials, including our Website and our social media accounts.

You are not obliged to appear in a recording. If you wish, you have the right to object to our legitimate interest and request the removal of the material where you are identified. In order to evaluate your objection to our legitimate interest, and if applicable immediately remove the images that identify you, we will ask you to indicate where you have seen them.

To promote our facilities, products, and services
If you have signed a contract or a consent for the assignment of image rights with 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 media such as the national or international press, our website, or our social networks. If you have signed a consent for the assignment of image rights, we inform you that you can revoke it at any time so that we remove your image from our website and/or our networks, without the revocation having effects on the dissemination of your image that took place before processing it.

Additionally, we may graphically record the atmosphere of our facilities to promote our venue and its products and services and, eventually, your image may appear in this graphic material. Unlike what is indicated in the previous paragraph, in this case the legal basis for the processing of your images is our legitimate interest, which you can object to at any time if you consider it contrary to your own interests. In order to evaluate your objection to our legitimate interest, and if applicable immediately remove the images that identify you, we will ask you to indicate where you have seen them.

To preserve security through video surveillance

We collect your image through our video surveillance systems for the purpose of preserving the safety of people, property, and the facilities themselves.

The basis of legitimation for the aforementioned processing is 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 regarding a crime that may be proven by a few minutes of a recording.

To select and hire our staff

We process the data from the CV 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 personnel selection process, and the hiring process.

The basis of legitimation for the aforementioned processing is your consent, which you manifest by sending us your CV, the execution of pre-contractual measures and, if we do not have an open hiring process or you are not selected and we consider that you may fit in future selection processes, our legitimate interest in retaining your CV to include it in those future processes.

To guarantee the functioning of our website (functional cookies)

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

As these are cookies necessary for the correct 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 aggregated statistics on the use of our website (analytical cookies)

We use analytical or statistical cookies to identify the most and least visited pages, analyze 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 we offer you through the Website. All these purposes provide aggregated results, in which it is not possible to identify the interests of any specific person.

As these are analytical cookies, we will not use them until we have your consent, and not giving it to us or withdrawing it will have no effect other than hindering our goal of improving the website through the analysis of aggregated statistics of our visitors’ navigation.
You can find more information about these cookies in our Cookies Policy.

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

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

As these are non-necessary cookies, we will not use them until we have your consent, and not giving it to us or withdrawing it will have no effect except that your visit to our website cannot be used to improve the relevance 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, a company of which Google Ireland Ltd is a subsidiary, imposes on entities that, like us, use the Google Analytics and Google Ads tools, we inform you that these two services are operated by Google Inc., located at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and that Google Inc. is a beneficiary party of these.

The information generated by cookies about your use of this website and your general advertising preferences is usually transmitted to a Google server in the USA and stored there. If you wish to obtain more information, you can consult how Google uses information from our website and/or Google’s privacy policy regarding the aforementioned services.

We inform you that we have activated the IP anonymization function on our website to add additional safeguards to the standard contractual clauses that protect this international transfer of data to the USA. With this, Google will shorten your IP address before transmitting it to the USA (a process of obfuscating your 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 communicate security breaches to you

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

The basis that legitimizes this processing is 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 previously indicated (such as archiving purposes for reasons of public interest, scientific or historical research purposes, or statistical purposes) provided that it is permitted by current regulations on personal data protection and, of course, acting in accordance with these and other applicable regulations.

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

• You yourself request it from us.
• We have a legal obligation to do so.
• We act as intermediaries, for example, when we have to make a reservation in your name (for example, for an activity).
• We are joint controllers for the collection of data, because, always with your consent, other entities process them in their own name. This is the case for:
  • Google Ireland Ltd, with registered office at 4 Gordon House, Barrow Street, Dublin, Ireland, to whom we have entrusted the processing of data from the cookies necessary to use its reCAPTCHA, Analytics, and Ads services. Google Ireland Ltd acts as an independent controller for all processing it carries out in its name according to its privacy policy. We transfer data to Google Ireland Ltd based on the data protection agreement that this company located in the EU includes in the addendum to the standard contract for countries suitable for the GDPR, as is the case of Andorra, to which we add the additional safeguard of activating the anonymization of the IPs collected by the cookies. In our Cookies Policy you will see which analytical and advertising cookies we offer you and how to configure them.
• We need to protect your rights, ours, those of our employees, or those of third parties (which may require transfer to the police for security reasons or to health authorities to prevent the spread of diseases, for example, for contact tracing purposes). For example:
  • If our video surveillance cameras record a theft at our facilities, or
  • If a third party requests video surveillance images from us based on their legitimate interest in seeking effective judicial protection regarding the commission of a crime or compensation for damages proven by the transferred images, and with the commitment of said third party to use them exclusively for reporting that crime or for claiming damages suffered, and reducing the transfer of images to the minimum and indispensable to fulfill the pursued purpose.

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

Borda del Pi retains your personal data exclusively for the duration of the processing that requires them and, thereafter, for as long as it takes for the legal responsibilities that apply to us at any given time, derived from the processing in question, to expire (including the obligation to be able to demonstrate that we have attended to your request for the destruction of personal data).

For example, we will keep video surveillance recordings for a maximum of 30 days when they do not contain incidents, and, if exceptionally a security incident has occurred during this period or if there were indications of the commission of a crime (for example, a theft), we will extract a copy of the part of the recording that captures the incident, which will be kept until its delivery 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, as it is considered outdated 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 anonymize them, and if this is not possible (for example, because they are in backup copies), we will store them securely and block them to isolate them from any further processing until their deletion is possible.

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

We remind you that when we share personal data with other controllers, you must exercise your rights directly against those controllers 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 the add-on to not send Google Analytics or Google Ads data to Google Inc in your Chrome, Internet Explorer, Safari, Firefox and/or Opera browser.

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 the execution of the following rights from us:

• Access to your personal data.
• Rectification of any of your personal data, specifying the reason.
• Erasure of any or all of your personal data.
• Restriction of the processing of your data, specifying the reason for the restriction.
• Objection to the processing of your personal data.
• Portability of your data when the basis of legitimation for the collection was consent or a contract.
• Right not to be subject to automated individual decisions.

The consent provided, both for the processing and for the transfer of the data of the interested parties, is revocable 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.

Where and how you can exercise your rights

You can exercise your rights:

1. By sending a written request to Borda del Pi, at our postal address, indicated in section 2 of this policy, indicating a means of contact with you so we can respond to your request, or ask for more information if necessary. We would appreciate it if you mark the envelope “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 same 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, to ensure in this way that we respond only to the interested party or their legal representative.
However, and especially if you consider that you have not obtained full satisfaction from the attention to the exercise of your rights, we inform you that you may file a claim before the national supervisory authority of your country, or by contacting the Andorran Data Protection Agency (APDA) for this purpose.

Forms for the exercise of your rights

In order to facilitate the exercise of your rights, we recommend using the corresponding request forms among the following:

• Form for exercising the right of access
• Form for exercising the right of rectification
• Form for exercising the right of objection (model A, and model B)
• Form for exercising the right of erasure
• Form for exercising the right to restriction of processing
• Form for exercising the right to portability
• Form for exercising the right not to be subject to automated individual decisions

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

You cannot provide us with personal data of other people unless it is justified in relation to the services you request from us. In any case, if you provide us with the personal data of third parties, you assume the responsibility of informing said third parties prior to providing us with their personal data. This information that you must provide to the third parties whose data you supply must include all the provisions provided for in this privacy policy, and it is you who is responsible for the lawfulness of these personal data and for transmitting to their owners the rights they have in relation to their personal data.

In cases where you must provide us with personal data of a minor under 16 years of age or a person who has their rights limited, by doing so you undertake to have the authorization of the holders of their parental authority or guardianship. Without this authorization, it is prohibited for you to provide us with any personal data of these persons.

We are fully committed to the protection of your privacy and your personal data. We have prepared a record of all the personal data processing activities we carry out, we have analyzed the risk that each of these activities may pose to you, and we have implemented the appropriate legal, technical, and organizational safeguards to avoid, as far as possible, the alteration of your personal data, their misuse, loss, theft, unauthorized access, or unauthorized processing. We keep our policies conveniently updated to ensure that we provide you with all the information we have about the processing of your personal data, and to guarantee that our staff receives the appropriate guidelines regarding how they should process your personal data. We have signed data protection clauses and data processor contracts with all our service providers, addressing the need each of them has when processing personal data.

We restrict access to personal data to those employees who really need to know them to perform any of the processing 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 the disciplinary measures that any eventual infringement in this matter would imply.

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

We will update this policy when necessary to reflect any changes that occur in the regulations or in our processing. If the changes are substantial, we will notify you before they take effect by sending you a notification or posting 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 know how we protect your personal data.

If you have any questions about this policy, do not hesitate to let us know by sending us an email at info@bordapi.com.