This Privacy Statement applies to the personal data of owners, employees, representatives, or other individuals acting on behalf of a (potential, existing, or former) business partner which Borjapartments.com may process in any form. Business partners and the related individuals are hereafter together or individually referred to as “Business Partners” or “you.”

A Business Partner within the context of this Privacy Statement may be:

• A Trip Provider (including providers of accommodation, attractions, parks, museums, etc.),
• Business Partners enabling the reservations of Trips through their websites and / or apps or other means,
• Travel agencies,
• Third-party vendors,
• And any other Business Partners maintaining a business relationship with Borjapartments.com.

For a better understanding of what we mean by “Trip,” “Trip Provider,” and “Trip Reservation,” read the Borjapartments.com Terms and Conditions.

The privacy statement applies to any Borjapartments.com group company responsible for the processing of the personal data within the scope of this Privacy Statement (hereafter referred to, as applicable, as “Borjapartments.com” or “we” or “our”).

Borjapartments.com located in Tanger, Morocco , is responsible for the processing of Trip Provider data.

For information about privacy and the use of cookies at Borjapartments.com, see the separate Privacy and Cookie Statement. This statement describes how Borjapartments.com processes personal data collected about customers finding and booking Trips through Booking.com’s services, and how Borjapartments.com uses cookies on customer-facing websites and apps. Companies using Borjapartments.com for Business services to enable Trip reservations for their staff members are subject to this Privacy and Cookie Statement for customers.

You can jump straight to the Cookie Statement for more info about how Borjapartments.com uses cookies on dedicated Business Partner websites and apps.

Data Collection

The personal data Borjapartments.com collects in regards to Business Partners depends on the context of the business relationship and interaction with Borjapartments.com, the choices made by a Business Partner and the products, services and features used. The personal data Borjapartments.com collects about a Business Partner can include the following – depending on the specific situation, not all of the following data items may be considered personal data because they can relate to a business instead of an individual:

Personal Data You Give to Us

• Contact DetailsWe collect contact data of Business Partners, like their first name/last name, date of birth (as required), business email, business address, telephone, and fax number.
• Financial DataWe collect data necessary for payment and invoicing purposes, including your bank details, bank account number, VAT number, credit slips.
• Verification DetailsBorjapartments.com can ask (representatives of) Business Partners to provide a copy of their ID card or passport, or a photo, video, or other relevant information to verify the authenticity of the Business Partner, which may also include licenses or tax information.
• OthersWhen communicating with Borjapartments.com, Borjapartments.com collects and processes communications. During calls with our support center, live listening can be done or calls might be recorded for quality control and training purposes, which includes the use of the recordings for the handling of claims and fraud detection purposes. Recordings are kept for a limited amount of time and automatically deleted, unless Booking.com has a legitimate interest to keep such recording for a longer period, including for fraud investigation and legal purposes.

Information we collect automatically

Depending on the business relationship, when using the Borjapartments.com online services, such as an online registration form, an online user account (e.g., extranet or partner center), or when using a Borjapartments.com app (e.g., Pulse app), Borjapartments.com also collects information automatically, some of which may be personal data. This includes data such as language settings, IP address, location, device settings, device OS, log information, time of usage, URL requested, status report, user agent (information about the browser version), operating system, result (viewer or booker), browsing history, user Borjapartments ID, and type of data viewed.

Personal data you give to us about others

By sharing other individuals’ personal data in relation to your business (for example of your staff members), you confirm that these individuals have been informed about the use of their personal data by Borjapartments.com in accordance with this Privacy Statement and provided any necessary consents.

Other Information We Receive from Other Sources

• Information on InsolvenciesIn insolvency matters, Borjapartments.com can receive information from insolvency administrators, courts or other public authorities relating to a Business Partner.
• Data Related to Law Enforcement and Tax Authority RequestsLaw enforcement or tax authorities can contact Borjapartments.com with additional information about Business Partners in case they are affected by an investigation.
• Fraud DetectionIn certain instances, and as permitted by applicable law, Borjapartments.com may need to collect data through third party sources for fraud detection and prevention purposes.

Processing Purposes

Borjapartments.com uses the previously described Business Partner information, some of which may be personal data, as relevant, for the following purposes:

A. Registration and administration

Borjapartments.com uses account details, financial data, and contact details to manage the business relationship with the Business Partner, including for registrations with Borjapartments.com and verification purposes.

Note that certain information, including the name and address of the Business Partner, can be used in accordance with the agreement entered into between the Business Partner and Borjapartments.com. An example of this would be to display their accommodation on third-party websites in order to enable Trip Reservations to be made.

B. Customer service

Borjapartments.com uses the information provided, which may include personal data, to provide support services, such as to respond to Business Partners’ or customers’ requests, questions, and concerns.

C. Other activities, including marketing

If a Business Partner is making use of an online registration facility and has not finalized the registration, Borjapartments.com may send a reminder to carry on with the registration. We believe that this additional service is useful to our (future) Business Partners because it allows us to carry on with the registration without having to fill in all the registration details from scratch.

Borjapartments.com may invite Business Partners to attend and host events that Borjapartments.com believes may be of relevance to a Business Partner, or use personal data to offer and host online forums to enable Business Partners to find answers to commonly asked questions on the usage of the Borjapartments.com services and the offering of their products and services.

As relevant for the business relationship, Borjapartments.com uses personal data, such as contact data, to also inform about system / product updates, to send the Borjapartments.com newsletter, to invite a Business Partner to participate in referral programs or competitions (such as Booking Hero) or for other marketing communications. When we use personal data for direct marketing messages in electronic form, Borjapartments.com will offer appropriate opt-out options.

D. Messaging tools

Borjapartments.com may offer certain Business Partners different means to communicate with its (prospective or existing) guests. Business Partners can contact Borjapartments.com to forward information or questions about reservations to guests, or communicate by use of alias emails, for example, which always include Borjapartments.com as a recipient. Borjapartments.com may access communications and uses automated systems to review, scan, and analyze communications for security purposes; fraud prevention; compliance with legal and regulatory requirements; investigations of potential misconduct; product development and improvement; research; customer engagement, including to provide guests with information and offers that we believe may be of interest to them; and customer or technical support. Note, all communications sent or received using Borjapartments.com communication tools will be received and stored by Borjapartments.com.

E. Analytics, improvement, and research:

Borjapartments.com uses the information provided, which can include personal data, for analytical purposes. This is part of our drive to improve the Borjapartments.com services and enhance user experience, but can also be used for testing purposes, troubleshooting, and to improve the functionality and quality of the Borjapartments.com online services. Borjapartments.com also invites Business Partners regularly to participate in surveys or conducts other market research. Certain Business Partners might be invited to join a dedicated online platform to interact with Borjapartments.com and/or exchange experiences with other Business Partners. Please consult the information provided when invited to participate in surveys, market research or join the online platform to understand how personal data can be treated differently from this Privacy Statement.

F. Security, fraud detection, and prevention

We process the information provided, which can include personal data, in order to investigate, prevent, and detect fraud and other illegal or violating activities. This might be personal data a Business Partner has provided to Borjapartments.com, e.g. for verification purposes as part of the registration process, personal data collected automatically, or personal data obtained from third party sources (including from guests). Borjapartments.com can also use personal data to facilitate prosecution where necessary. For these purposes, personal data can be shared with law enforcement authorities and external advisers. Borjapartments.com can use personal data for risk assessment and security purposes, including the authentication of users.

G. Legal and compliance

In certain cases, Borjapartment.com needs to use the information provided, which can include personal data, to handle and resolve legal disputes, for regulatory investigations and compliance, or to enforce the agreement(s) with Business Partners or solve a complaint with a booker as reasonably expected.

Note that accommodation information, including the name and address of the accommodations, will be used in accordance with the General Delivery Terms as part of the separately executed Accommodation Agreement (e.g. to display on third party websites to enable the making of a Trip Reservation).

If we use automated means to process personal data that produces legal effects or significantly affects you, we will implement suitable measures to safeguard your rights and freedoms, including the right to obtain human intervention.

Legal Bases: As applicable for purposes A and B, Borjapartments.com relies on the legal basis that the processing of the personal data is necessary for the performance of the agreement between the Business Partner and Borjapartments.com. If the required info isn’t provided, Borjapartments.com can’t register a Trip Provider or otherwise work with a Business Partner, nor can we provide customer service. In view of purposes C to G, Borjapartments.com relies on its legitimate interest to provide its services or obtain services from Business Partners, to prevent fraud, and to improve its services. When using personal data to serve Borjapartments.com’s or a third party’s legitimate interest, Borjapartments.com will always balance the Business Partners’ rights and interests in the protection of their information against Borjapartments.com’s rights and interests or those of the third party.

For purposes F and G, Borjapartments.com relies also where applicable on compliance with legal obligations (such as lawful law enforcement requests). Finally, where needed under applicable law, Borjapartments.com will obtain your consent prior to processing personal data, including for marketing purposes or as otherwise required by law.

If you want to object to the processing set out under C to E and no opt-out mechanism is available to you directly (e.g. in your account settings), to the extent applicable, please contact borjapartments@gmail.com.

Data Sharing

• Sharing with affiliates. In order to support the use of the Borjapartments.com services, your information, which may include personal data.
• Sharing with third parties. We share Business Partners’ info, which may include personal data, with third parties, as permitted by law and as described below.
  • Service providers (incl. suppliers). We share personal data with third-party service providers to provide our products and services, to detect and prevent fraud, to store data, to otherwise support our business processes, or to conduct business on our behalf.
  • Payment Providers and other financial institutions. To process payments between a Business Partner and Borjapartments, or a booker and a Business Partner, personal data, as relevant, is shared with Payment Providers and other financial institutions.
  • Compelled disclosure. When legally required, strictly necessary for the performance of our services, in legal proceedings, or to protect our rights or the rights of users, we disclose personal data to law enforcement authorities, investigative organizations, or other group members.

Sharing and disclosure of aggregated data: we may share information in aggregate form and/or in a form which does not enable the recipient of such information to identify you, with third parties, e.g. for industry analysis and demographic profiling.

Booking.com relies on its legitimate interest to receive and share personal data to provide its services or obtain services from Business Partners, including to prevent fraud and improve services. When using personal data to serve Borjapartments.com’s or a third party’s legitimate interest, Borjapartments.com will always balance the Business Partners’ rights and interests in the protection of their information against Borjapartments.com’s rights and interests or those of the third party.

International Data Transfers

The transmission of personal data as described in this Privacy Statement may include overseas transfers of personal data to countries whose data protection laws are not as comprehensive as those of the countries within the European Union. Where required by European law, we shall only transfer personal data to recipients offering an adequate level of data protection. In these situations, as may be required, we make contractual arrangements to ensure that your personal data is still protected in line with European standards. You can ask us to see a copy of these contractual agreements using the contact details below.

Security

In accordance with European data protection laws, Borjapartments.com observes reasonable procedures to prevent unauthorized access to, and the misuse of, information including personal data.

We use appropriate business systems and procedures to protect and safeguard information including personal data. We also use security procedures and technical and physical restrictions for accessing and using the personal data on our servers. Only authorized personnel are permitted to access personal data in the course of their work.

Data Retention

We will retain personal data for as long as we deem it necessary to manage the business relationship with a Business Partner, to provide the Booking.com services to a Business Partner, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties, and as otherwise necessary to allow Borjapartments.com to conduct its business. All personal data we retain will be subject to this Privacy Statement and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal data we process about you, please contact us using the details included below.

Your Choices and Rights

Depending on where you are located or the Borjapartments.com entity processing your personal data, different rights may apply to the processing of personal data as set out in this Privacy Statement. As applicable:

• You can ask us for a copy of the personal data we hold about you;
• You can inform us of any changes to your personal data, or you can ask us to correct any of the personal data we hold about you;
• In certain situations, you can ask us to erase, block or restrict the personal data we hold about you, or object to particular ways in which we are using your personal data; and
• In certain situations, you can also ask us to send the personal data you have given us to a third party.

Where we are using your personal data on the basis of your consent, you are entitled to withdraw that consent at any time subject to applicable law. Moreover, where we process your personal data based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal data subject to applicable law.

Regardless of your location or the Borjapartments.com entity with which you are contracted, we rely on our Business Partners to ensure that personal data we hold in regards to Borjapartments.com’s Business Partners is complete, accurate, and current. Please always inform us promptly of any changes to or inaccuracies of your personal data.

If your business is contracted with a different entity to Borjapartments.com and you would like further info about the relationship between Borjapartments.com. and your contracting entity, feel free to contact Borjapartments.com at any time (as set out below). This includes to exercise your rights regarding your personal data processed as part of the business relationship.

Questions or Complaints

If you have questions or concerns about our processing of your personal data or want to exercise any of your rights you have under this Privacy Statement, please contact our data protection officer at borjapartments@gmail.com. All privacy related questions and complaints reported to Borjapartments.com will be investigated. Borjapartments.com will attempt to resolve complaints and questions in line with internal policies. You may also contact your local data protection authority with questions and complaints.

Changes to the Privacy Statement

Just as our business changes constantly, this Privacy Statement may also change. If we make material changes or changes that will have an impact on you (e.g. when we start processing your personal data for other purposes than set out above), we will contact you prior to starting that processing.

01/12/2021