TERMS OF USE AND PRIVACY POLICY OF DISFRUTONES CLUB Andrei Gae 19 de March de 2025

TERMS OF USE AND PRIVACY POLICY OF THE DISFRUTONES CLUB

1. PRIOR INFORMATION

Before joining the Club, it is important that you read and accept the following terms and privacy policy. These terms govern the relationship between the Joint Controllers and the members of the Club (hereinafter, MEMBERS). These Terms of Use constitute a legally binding contract. If the user does not accept these Terms of Use, they will not be able to access and use the Service. Applicable regulations:
  • REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27th April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation).
  • Organic Law 3/2018, of 5th December, on Personal Data Protection and Guarantee of Digital Rights.
  • Law 34/2002, of 11th July, on Information Society Services and Electronic Commerce.

2. JOINT CONTROLLERS OF THE DATA PROCESSING

The Club is a joint initiative of the following entities:
  • Grupo Lar Inversiones Inmobiliarias, S.A, located at C/María de Molina 39, 10th Floor, 28007 Madrid.
  • Community of Property Owners of C.C. Portal de la Marina (C.C. Portal de la Marina), located at Avda. Costa Blanca, 1, 03760 Ondara (Alicante).
  • Le Retail Lagoh, S.L.U, located at Avda. de Palmas Altas, 1, 41012 Seville.
  • Community of Property Owners of C.C. Albacenter (C.C. Albacenter), located at C/Alcalde de Conangla, s/n, 02006 Albacete.
  • Le Retail Ànecblau, S.L, located at Avda. Canal Olimpic, 24, 08860, Castelldefels (Barcelona).
  • Le Retail El Rosal, S.L. (C.C. El Rosal), located at Avda. Constitución, 2, 24404 Ponferrada.
  • Community of Property Owners of C.C. As Termas (C.C. As Termas), located at Avda. Infanta Elena, Duquesa de Lugo, 213, Lugo.
  • Le Retail Gran Vía de Vigo, S.L. (C.C. Gran Vía de Vigo), located at Rúa Miradoiro, 2, 36210 Vigo (Pontevedra).
All these entities are considered Joint Controllers of the data processing (you can access the summary of the joint responsibility agreement by clicking here).

3. MAIN OBJECTIVE OF THE CLUB AND ITS BENEFITS

Keeping Members informed about all the news, activities, and services carried out by the joint controlling entities. Additionally, membership provides access to the following benefits, exclusive to Club members:
  • Access to Wi-Fi networks in the designated shopping centers.
  • Participation in giveaways and events organized by these entities.
  • Discounts at stores in shopping centers affiliated with the Club.
  • Use of children’s playrooms in shopping centers that have this service.
  • Shopping from operators in the Marketplace with discounts.
  • Enjoying exclusive experiences.
  • Discounts with external partners of the shopping center in the locations offering this service.

4. CLUB OPERATION AND DATA PROCESSING

  • Minimum Age.
To join the Club, you must be at least 18 years old, and the user is responsible for the accuracy of the data provided at registration.
  • Club Registration/Joining.
Membership can be obtained through the website of one of the specified shopping centers, by connecting to the Wi-Fi network (in one of the centers), or by downloading the App. Please note that only one membership account can be registered per user. If it is detected that a user has registered more than one account, the duplicate account will be canceled, and the personal data entered in the second account will be immediately deleted. The data provided for registration, as well as the data added by the Member via the My Account section, will be incorporated into a database to manage the Club’s services. These data will only be accessible and managed by the shopping center where the Member registers and by Grupo Lar Inversiones Inmobiliarias, S.A. If a member visits another shopping center (from the list above) and wants to use the benefits, they only need to log in using their Club username and password (as a registered user). The system will automatically identify the user using these credentials and enable the center to access their data.
  • Management of the My Account section: personal data.
The My Account area is a private section where Members can complete and edit the general data of their profile:
  • Full name.
  • Postal address.
  • Phone number.
  • Password.
Additionally, specific data can be completed and edited:
  • Access data.
  • Preferred communication channel.
For more information about managing My Account, you can check the frequently asked questions in My Account.
  • Other personal data collected by the system.
When in the Shopping Center where you are registered, Wi-Fi access points may collect parameters from your device, such as IP, MAC, and radiofrequency identifier. These parameters will help provide information relevant to promotions, activities, services happening near the Wi-Fi access point where you are. These data will only be collected if your Wi-Fi interface is enabled. No data will be collected if your device has a low battery level during that time or if you have not stayed near a Wi-Fi access point long enough.
  • Main use and purpose of the collected data.
The collected data (general, specific, and device identification at a shopping center) will be used for the main purpose of your Club membership: to provide you with information about activities, promotions, campaigns, etc., from the organizations promoting the Club (Grupo Lar Inversiones Inmobiliarias, S.A. and the shopping center you joined, including others where you decide to activate membership later). This will be carried out in two ways:
  • Segmentation: using general and specific data to categorize members and send information relevant to those categories (e.g., communications for people with kids; communications to individuals aged between 30-40, etc.).
  • Profile Building: a) by combining device identification data collected at Wi-Fi access points, we can build profiles based on location to send you more relevant information; b) by analyzing your interactions with our emails and communications, we will better understand your behavior, responses, and assign scores regarding the likelihood of your interest in the sent content, optimizing future communications and meeting your preferences without implementing automated decision-making processes that could have legal or similarly significant effects on you (you can find more details at https://resources.docs.salesforce.com/latest/latest/en-us/sfdc/pdf/salesforce_ai_model_cards.pdf).
The ultimate goal is to avoid overloading members with irrelevant information and focus it on content that truly offers advantages and satisfies their personal interests.
  • Data use for security purposes.
The Member’s identification data (email) will be used to prevent any security incidents associated with identity theft and ensure the safety of the data. Similarly, contact data may be used to notify members of any security incident in the system where their data is processed.
  • Unsubscribing from the Club.
Unsubscribing from the Club can be done directly through the My Account area. Once the Member requests to unsubscribe, they will receive a confirmation (via email or message), and their access to My Account will be automatically removed. Unsubscribing can also be requested by sending an email, providing identification details, to hola@elclubdelosdisfrutones.com. Once the request is received and processed, a confirmation (via email or message) will be sent, and access to My Account will be automatically removed.

5. LEGITIMACY OF DATA PROCESSING

The legitimacy of data processing is based on the contractual relationship in the case of Club membership. For the communication of data to other entities within Lar España (LE Retail Hiper Ondara, S.L.U, LE Retail As Termas, S.L.U. LE Retail Albacenter, S.L.U.), the legitimacy will be based on the Member’s consent, if granted. Consent can be withdrawn at any time, although the processing performed up to that date will remain valid. To withdraw this consent, the Member can request it by sending an email to hola@elclubdelosdisfrutones.com, stating “Withdrawal of Consent” in the subject line and including their identification details in the message body.

6. DATA RETENTION PERIOD

The data will be retained as long as the Member’s relationship with the Club persists. If a Member unsubscribes, their data may be stored, appropriately blocked, for a maximum of one year unless there is a legal claim that requires their retention until the legal process concludes. For authorizations related to the communication of data to other Lar España entities (LE Retail Hiper Ondara, S.L.U, LE Retail As Termas, S.L.U. LE Retail Albacenter, S.L.U.), the data will be retained until consent is withdrawn.

7. DATA COMMUNICATION TO THIRD PARTIES AND INTERNATIONAL DATA TRANSFERS

8. EXERCISING MEMBER RIGHTS

  • Access: the right to obtain confirmation of whether your personal data is being processed and, if so, the right to know which data, for what purpose, how long they will be stored, their origin, and whether they have been or will be disclosed to third parties.
  • Correction: the right to request the rectification of inaccurate data and complete incomplete personal data.
  • Erasure: the right to request the deletion of personal data when they are inappropriate, excessive, or no longer necessary for the purposes for which they were collected, including the right to be forgotten.
  • Objection: the right to object, in certain circumstances, to the processing of your personal data or request that it stops.
  • Restriction of Processing: the right to request, under legally established circumstances, that your data be limited to mere storage.
  • Portability: the right to receive personal data in a structured, commonly used, and machine-readable format and to transfer them to another controller, whenever technically feasible.
  • The right to withdraw consent for the communication of data to other Lar España entities (LE Retail Hiper Ondara, S.L.U, LE Retail As Termas, S.L.U. LE Retail Albacenter, S.L.U.), without affecting any processing performed before the withdrawal.
The exercise of rights must be made in writing, addressed to hola@elclubdelosdisfrutones.com, or via the My Account section. The data controllers provide templates for exercising these rights, which can be requested through the mentioned email address. For more information: www.aepd.es. If your rights are not respected, you can file a complaint by writing to the Spanish Data Protection Agency at Calle Jorge Juan, 6-28001-Madrid or using the electronic headquarters: https://sedeagpd.gob.es. In both cases, relevant documentation must be included.
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