This privacy notice provides information about how DFrost Almugar Surf & Yoga and Pure Travel GmbH uses the personal data we collect when you make an enquiry or reservation for one of our services (hotel accommodation at DFrost Almugar Surf & Yoga and/or its sister property Villa Surya Yoga & Meditation) as well as during and after the delivery of any contracted services.
The EU General Data Protection Regulation 2016/679 (GDPR) and the Data Protection Act 2018 (which supplements the GDPR) came into force on 25 May 2018. We refer to these as “data protection law”.
Once in force, data protection law will regulate the processing of “personal data” relating to individuals by organisations (known as “data controllers”).
On this page, and the pages which it links to, we have used some words and phrases, and these are explained below.
“Personal data” means any information which relates to a living, identifiable person. It can include names, addresses, telephone numbers, email addresses etc but it is wider than that and includes any other information relating to that person or a combination of information which, if put together, means that the person can be identified.
“Special category data” means personal data about a person’s race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation.
“Processing” covers all activities relating to the use of personal data by an organisation, from its collection through to its storage and disposal and everything in between.
“Data subject” means the person whose personal data is being processed.
“Data controller” means the organisation which is responsible for processing data and ensuring that personal data is processed in accordance with data protection law.
Personal data must be processed in accordance with specific principles set out in Data Protection Law. These include the principle that personal data should be processed ‘lawfully, fairly and in a transparent manner’. In order to comply with this principle, DFrost Almugar Surf & Yoga and Pure Travel GmbH will advise you on how it will process your information at the time we collect it. This information is normally set out in a “privacy notice” which we publish on our website.
DFrost Almugar Surf & Yoga and Pure Travel GmbH is the data controller for any personal data that we process in relation to you.
Occasionally, DFrost Almugar Surf & Yoga and Pure Travel GmbH may be a joint data controller with other organisations, or we may be processing data about you on behalf of another organisation, but when this is the case, we will make you aware of this when the information is collected.
Any personal details provided to us at the point of enquiry or reservation are stored in our database, along with any subsequent relevant data provided to us at a later stage during the reservation process or during your stay.
Information is gathered through our web-based enquiry forms, during telephone or face to face communications with us, and by email or post.
Personal data collected includes: your name, home address, business address (if booking on behalf of an organisation), a contact telephone number (landline and mobile where possible), email address, or any other personal information that you disclose to us at the point of your enquiry, reservation or during your stay.
In addition to this, we may need to process some data about you that is classed as ‘special category’ or sensitive personal data. We will usually ask you for consent to do this. This includes any relevant health and disability information you provide us. We will make sure that access to, and the sharing of, your special category personal data is controlled very carefully.
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DFrost Almugar Surf & Yoga and Pure Travel GmbH will process your personal data for a range of purposes. These include the following:
If we require your consent for any use of your specific data, we will collect it at the appropriate time, explaining why we are collecting the data and how we will use it, and you can withdraw this consent at any time. In other cases, we consider the processing of your personal data for these purposes to be necessary for:
We usually process your special category data with your explicit consent. In other cases, we do so because we consider it necessary:
Your personal data may be shared, on a considered and confidential basis, with a range of external organisations as is necessary for the purposes set out above and as permitted or required by law, including the following:
Except as we have explained above, we will not normally publish or disclose any personal data about you to other external enquirers or organisations unless you have asked us to do or have consented to it, or unless it is in your vital interests to do so (e.g. in an emergency situation).
Personal data relating to an accommodation or event booking with us will be kept on our systems for seven years after the stay is completed or the event is held.
Personal data collected as part of a customer enquiry which did not result in a booking will be stored on our systems for a shorter period of time, as permitted by law.
We do this to ensure we can respond to any queries you or any third parties raise regarding current, future or past events or accommodation bookings held with us.
DFrost Almugar Surf & Yoga and Pure Travel GmbH handles a substantial amount of information about individuals. It is important that they have trust and confidence that DFrost Almugar Surf & Yoga and Pure Travel GmbHwill protect their privacy, and we take great care to ensure that personal data is handled, stored and disposed of confidentially and securely. Our staff receive regular data protection training, and we have put in place organisational and technical measures to ensure that personal data is processed in accordance with the 6 data protection principles set out in Data Protection Law.
DFrost Almugar Surf & Yoga and Pure Travel GmbH has an Information Security Management System with a range of controls covering the protection of personal information and is accredited under the Payment Card Industry Data Security Standard.
Your personal data is collected, stored and transmitted securely in a variety of paper and electronic formats. Only relevant staff that require access to your personal data for the purpose for delivering our services will be able to access this data. Our use of your data will be strictly limited to the purpose and legal basis outlined below.
As a data subject, you have the following rights in relation to your personal data which is processed by DFrost Almugar Surf & Yoga and Pure Travel GmbH:
The Data Protection Officer
Pure Travel GmbH
Bauhallengasse 11, 8004 Zürich, Switzerland
You also have a right to complain to the Information Commissioner’s Office (ICO) about the way in which we process your personal data. You can make a complaint using the ICO’s website
This webpage is effective from 15 March 2019. It is reviewed when necessary and at least annually. Any changes will be published here and you may also be notified by email.