ADDITIONAL INFORMATION ABOUT DATA PROTECTION
DATA CONTROLLER
Contact Details for the Data Controller 1, 2, 3 and 4
CASINO NUEVA ANDALUCÍA MARBELLA, S.A.U.
Edificio Hotel Hard Rock Marbella s/n, 29600 Puerto Banús (Málaga)
Contact Telephone: 952814000
protecciondedatos@cirsa.com
Contact Details for the Joint Data Controller of Process 3
CIRSA SERVICIOS CORPORATIVOS, S.L.
Ctra. De Castellar, 298. 08226 Terrassa (Barcelona)
Contact Telephone: 937396700
protecciondedatos@cirsa.com
PROCESSING OF PRIVATE DATA
Data processing and purposes
1. Managing the client subscription to the loyalty programme CIRSA WINNER CLUB to:
• Process the registration of clients in the loyalty programme CIRSA WINNER CLUB.
• Handle their registration in CIRSA WINNER CLUB correctly and offer exclusive benefits and advantages derived from the same when appropriate, including accumulating points for visits and playing the slot machines in the Casino, winning prizes, etc.
• Prevent fraud, identity theft or any illicit use contrary to the membership conditions of the loyalty programme.
• Handle any process, request or query from members in relation with their subscription to the loyalty programme.
Legitimacy
Activation of the member’s subscription to the contract regulating the loyalty programme CIRSA WINNER CLUB.
What GDPR rights do you have?
• You have the right for us to confirm that we are processing your data.
• The right of access to your data, to rectify it if it is inaccurate or delete it, especially if it is no longer necessary to process it.
• In some cases you may request that processing be limited, in which case we shall use it only to exercise or defend against claims.
• In some cases, you may object to us processing your data, and we shall stop processing it unless there are legitimate overriding reasons, or to exercise or defend against possible claims.
• Right to revoke consent.
• Right of data portability, if relevant. You have the right to copy and transfer data from our database to another data controller. You may only exercise this right when the processing is based on the performance of a contract or on your consent and the processing is performed by automatic means.
For more information about these rights, please contact
protecciondedatos@cirsa.com
How can you exercise your rights?
To exercise these rights you must present a document in admission at the Casino, or to the postal address indicated above. You may also contact us at the e-mail address protecciondedatos@cirsa.com.
This written document must specify which right you are seeking to exercise and accompany it with a photocopy of your identification document.
If you require a form for this purpose you may:
• Use the official form of the Spanish Data Protection Agency: https://www.aepd.es/reglamento/derechos/index.html; o
• Request a form from us: protecciondedatos@cirsa.com
We hereby also inform you that when you have been unsuccessful in exercising your rights or your way of exercising them, you may submit a complaint to the Supervisory Authority. If you want more information about this right and how to exercise it, you can contact AEPD:
http://www.aepd.es/
Phone. 901 100 099 y 91.266.35.17. C/Jorge Juan 6, 28001-Madrid.
Period for maintaining the data
Your private data shall be processed by the Data Controller while you are subscribed to the loyalty programme CIRSA WINNER CLUB, unless you exercise your right to oppose or suppression.
Your private data will be retained for the legally stipulated period. Your data shall be deleted when the maximum conservation period expires.
2. Analysis, segmentation and profiling of the private data of the members of the CIRSA WINNER CLUB loyalty programme to:
• Analyse and classify by interests, tastes, gambling activity and activity in the Casino, preferences and use of the CIRSA WINNER CLUB programme by members to provide them with personal treatment, rewarding their loyalty, their visits and enhancing their experience in our Casino.
• Create Client templates for their tastes, preferences, gambling, frequency of visits, volume of bets, consumption in the café and restaurant, to improve the quality of our services and make their time in our Casino an excellent experience.
• Design promotions and personalised commercial messages based on the member profile resulting from the analysis and classification processes.
• Send personalised commercial messages via electronic media based on their tastes, interests, habits and gambling activity in the Casino, etc. Legitimate interest in accordance with recitals 47 and 70 and articles 21 and successive of the Data Protection Law GDPR.
The Casino has a legitimate interest in processing your data to elaborate customer service patterns, improving the quality of our services and making your stay in our Casino an excellent experience.
If you do not agree and do not want your data to be used for the aforementioned purposes, you may object to this processing at any time:
• By notifying the reception at the Casino
• Contacting the following e-mail address: protecciondedatos@cirsa.com
To exercise your other rights, you must submit a written request in admission at the Casino, or to the address indicated above. You may also contact us at the e-mail address protecciondedatos@cirsa.com
This written document must specify which right you are seeking to exercise and accompany it with a photocopy of your identification document.
If you require a form for this purpose you may:
• Use the official form provided by the Spanish Data Protection Agency: https://www.aepd.es/reglamento/derechos/index.html
• Or request a form from us: protecciondedatos@cirsa.com
We hereby also inform you that when you have been unsuccessful in exercising your rights or your way of exercising them, you may submit a complaint to the Supervisory Authority. If you want more information about this right and how to exercise it, you can contact the Spanish Data Protection Agency:
http://www.aepd.es/
Phone. 901 100 099 y 91.266.35.17. C/Jorge Juan 6, 28001-Madrid.
3. Data analysis for business management and statistics for the purpose of:
• Making business analysis and statistics on the frequency of visits, gambling history data, preferences, consumption, behaviour and use of the loyalty programme and the promotions and advantages arising from the member’s subscription to this programme.
• Obtaining economic values and of profitability, the quality and improvement of the services.
• Improving our services and client support to enhance their experience in our Casino, respecting at all times their fundamental rights and privacy. Legitimate interest. In accordance with recitals 47 and 70 and articles 21 and related provisions of the GDPR.
4. Maintaining suppression lists for the purpose of:
• Keeping an updated list of members who have requested at some time that their data be suppressed or who have opposed any process that we perform.
Legal obligation. Article 24 of the GDPR obliges the Data Controller to retain evidence of compliance with the law. GDPR rights are limited because this processing is founded on a legal obligation. The private data shall be retained for the period legally stipulated for the presentation of any claim in relation with an effective or deficient response on our part to the right to suppression or objection exercised.
Your data will be deleted when the maximum period for conservation has expired.
RECIPIENTS
By legal requirement when legally required to do so by the Administration, the Police, Inspection bodies, judicial authorities, the Executive Service of the Committee for Prevention of Money Laundering and Monetary Offences. Compliance of a legal obligation applicable to the Data Controller.
Grupo CIRSA – Our Casino forms part of the CIRSA business group. The activity of the Casino is carried out under the control and supervision policies of the CIRSA group by the central corporate services through the company CIRSA SERVICES CORPORATIVOS, S.L.U., in Ctra. De Castellar 298, 08226 Terrassa (Barcelona). The data can therefore be communicated and processed for administrative purposes and for internal management purposes.
Also, if you have not opposed the processing, your data shall also be processed to carry out information and statistical analysis to obtain economic and profitability values, for quality and improvement of the services of the CIRSA group. In accordance with recital 48 of the GDPR: “Data Controllers that are part of a business group or institutions affiliated to a central body may have a legitimate interest in transmitting personal data within the Business group for internal administrative purposes, including the processing of clients’ or employees’ personal data”.
International data movement
Does not apply
International data transfer
Does not apply
Data controllers
The data may be transferred to suppliers with access to data when they have accepted their obligations and responsibilities for data processing as Data Controllers.
The Casino has the corresponding data processing contracts signed by both parties that contain the proper guarantees for personal data processing, confidentiality and cancellation, destruction or return.
In accordance with the above, you are hereby informed that the Casino has signed a contract for data processing with CIRSA SERVICIONS CORPORATIVOS, S.L.U. so that it may access the personal data to provide related corporate services with the maintenance and management of IT services, among others. Existence of a contract for the Data Controller.
SOURCE OF THE DATA
Origin of the data category of the data.
The personal data come from the interested party.
The personal data collected are identity and contact data, such as name and surname, National ID/Passport, mobile phone number, e-mail address and signature.
Additionally, data regarding the frequency and dates of visits to the Casino, historical gambling data, points accumulated, amounts spent and gambled, data on consumer preferences, interests and tastes.
DETAILS OF THE DATA PROTECTION DELEGATE
Contact the Data Protection Delegate at:
• E-mail: protecciondedatos@cirsa.com
• Telephone: 93 739 67 00
• Postal address: Carretera de Castellar 298, 08226 Terrassa (Barcelona).
