1. PURPOSE OF THE PRIVACY POLICY

"The purpose of ATELIER CAPITAL, S.L. (hereinafter, “Eric Vökel”) through the website with the domain https://ericvokel.com/ (hereinafter, the “Website”) is to provide the user (hereinafter, the “User”) with a safe and reliable browsing experience and service through the Website and the information displayed or collected through it. Through the Website, Eric Vökel makes detailed information about the services offered available to Users.

For this reason, we have implemented this Privacy Policy, which complies with the guidelines and security measures required by Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter, the “LOPDGDD”), and by Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, the “GDPR”), all with the purpose of ensuring User privacy and transparency in the use of their data."

2. DATA CONTROLLER AND CONTACT INFORMATION

"The Data Controller and the owner of the Website is:

ATELIER CAPITAL, S.L.

Tax ID (NIF): B64867781

Registered office: Calle Vizcaya, No. 9, 28045 Madrid (Spain)

Contact email: ericvokel@ericvokel.com

Email for data protection inquiries: reclamacion@ericvokel.com

Contact phone: +34 934 334 631

Commercial registration: Barcelona Mercantile Registry, Volume 40518, Folio 0037, Sheet B-365799

Social media: Instagram, LinkedIn, and Facebook

For any matters related to this Privacy Policy, Users may contact us through any of the channels indicated above."

3. WHAT PERSONAL DATA DO WE COLLECT?

"The personal information we may collect will depend on the channel through which such information is received. Generally, given the nature of the services, this will include identification data such as first and last names, email address, and phone number.

In any case, we will collect personal information to be able to assist the User or interested party, or to meet the needs of the company, as described in the following sections, always respecting the rights of clients and users.

We also inform you that Eric Vökel may, on occasion, collect personal data from publicly available sources and from third parties.

Personal data is understood as any information relating to an identified or identifiable natural person.

An identifiable natural person is any individual whose identity can be determined, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person."

4. TIPOS DE USUARIO DE LA PÁGINA WEB 

"User: Any person who visits the Website, whether for informational, consultation, or limited interaction purposes, without necessarily making a reservation.

Registered User: A User who has created an account on the Website to join the Eric Vökel Loyalty Club and gain access to exclusive benefits, such as additional discounts on accommodation rates.

Interested Party: A person who, through any of the enabled online means or channels, contacts us to request information about Eric Vökel’s services.

Client: A person or entity who makes a reservation through the channels provided by Eric Vökel and with whom the Contract is formalized."

5. DATA COLLECTION CHANNELS

5.1. Through the Website itself

"At Eric Vökel we collect personal data through the following channels:

5.1.1. Contact form for services and general inquiries

The User may contact us through the form available on the Website to make general inquiries or request information about our services.

5.1.2. Accommodation booking form

To confirm the booking of a tourist apartment, the User must complete a specific form in which the data necessary to manage the reservation will be collected.

5.1.3. Group request contact form

This form allows Users to send requests related to group bookings or services.

5.1.4. Loyalty Club

Users who wish to join the Loyalty Club must register through the form provided on the Website.

5.1.5. Email and telephone support

The User may contact our team via email or telephone (see Section 2 of this Policy).

In addition, each section of the Website related to a specific apartment provides the relevant contact information for that apartment.

5.1.6. Social media

Eric Vökel may interact with the User through its official social media profiles (see Section 12). In this context, we may collect the data the User chooses to share via messages, comments, “likes,” or other interactions, in accordance with the privacy policy of each social network.

5.1.7. Newsletter subscription

The User may voluntarily subscribe to our newsletter to receive information about promotions, updates, offers, and news from Eric Vökel.

5.1.8. Electronic communications

The User may receive commercial or informational electronic communications provided they have given their express consent. These communications may be sent via email and/or text messages.

Exception for Riverfront: In Riverfront apartments, WhatsApp may also be used to communicate with Guests.

5.1.9. Cookies and similar technologies

We use cookies and similar technologies to collect information about the User’s browsing on our Website, with the aim of improving the user experience, personalizing content, and conducting statistical analysis. For further details, please consult our Cookie Policy.

5.1.10. Satisfaction surveys

After their stay, Guests may be invited to participate in Eric Vökel’s own satisfaction surveys to evaluate their experience and the quality of the services provided. They may also receive messages encouraging them to share reviews on external platforms such as Google or TripAdvisor. Participation in such surveys and reviews is always voluntary, and the data collected will be processed in an aggregated and confidential manner.

5.1.11. Incorrect contact through available channels

If the User communicates via an inappropriate channel, their message will be internally redirected to the corresponding department to ensure a proper response to their request, while guaranteeing the confidentiality and security of their data at all times.

5.1.12. Promotional campaigns and social media contests

During occasional activities such as sweepstakes, contests, or promotions, Eric Vökel may organize them exclusively through its official social media profiles. Participation will take place according to the mechanics indicated in each post (for example, “liking” the post and/or sharing content).

In all cases, each post will include a link to the specific terms and conditions, where the User may consult all information related to the promotion, the processing of their data, and other applicable aspects. For the management of these social media sweepstakes, only the participant’s username on the corresponding social network may be collected.

5.1.13. Use of video surveillance

Users are informed that, in order to ensure the safety of individuals and facilities, Eric Vökel operates video surveillance systems only in the common areas of the apartments, such as entrances, reception areas, hallways, and parking facilities (where available). There are no cameras inside rooms. The recorded images may include employees, visitors, or suppliers, and will be processed in compliance with the applicable data protection and security legislation."

5.2. Through other tourism intermediation platforms

"Your personal data may be processed by tourism intermediation platforms or similar entities, exclusively for the purposes of managing bookings, customer service, and other objectives related to the performance of the contracted service.

Depending on the platform and the service provided, data may be processed in different ways:

(i) As data processors:

The platform will process the data in accordance with our instructions and under the terms of the data processing agreements signed with each company, thereby ensuring compliance with data protection regulations.

(ii) As independent controllers:

In certain cases, the platform may process the data on its own behalf—for example, to send its own marketing communications or to create user profiles. In such cases, the platform itself shall be responsible for informing the User and, where applicable, obtaining consent.

(iii) As joint controllers:

In specific situations, the platform and Eric Vökel may act jointly as joint controllers of the data, solely for the purpose of executing the contract and managing the apartment reservation. In this case, both parties shall ensure the joint processing of the data in compliance with the applicable regulations, with the ultimate aim of delivering the services contracted by the User."

6. OBJECTIVE AND/OR PURPOSES OF DATA COLLECTION

The purpose of processing personal data will depend on the type of User, the channel through which the data is collected, and the relationship established with Eric Vökel. The specific purposes, according to the activity carried out, are detailed below:

6.1. General objectives and purposes

"Personal data may be processed for the following purposes:

(i) To maintain smooth communication with Users through the designated channels, in order to address inquiries, comments, or requests for information, ensuring quality service and a satisfactory experience.

(ii) To manage and respond to complaints, suggestions, or claims.

(iii) To handle requests related to the exercise of data protection rights."

6.2. Provision of services and management of the contractual relationship

"In relation to the contracted services, the User’s personal data will be processed for the following purposes:

(i) To formalize and manage the contractual relationship arising from the booking, rental, and management of tourist apartments.

(ii) To handle requests for assistance or support related to the booking or stay, including the provision of customer service.

(iii) To coordinate, where applicable, participation in events, activities, or sessions organized by Eric Vökel, providing the necessary information for each occasion.

(iv) To manage interactions carried out through automated tools (e.g., the WhatsApp channel), which may provide automatic responses. In any case, human supervision and the possibility to contact through other communication channels will be ensured."

6.3. Commercial and marketing purposes

"Whenever we have the User’s express consent, their data may be processed for the following purposes:

(i) To send commercial, informational, or promotional communications regarding Eric Vökel’s services, via electronic or conventional means.

(ii) To manage participation in sweepstakes, contests, or promotional campaigns carried out through Eric Vökel’s official social media profiles, to contact winners, and to send communications related to the campaign.

(iii) To conduct post-stay satisfaction surveys, as well as to invite Guests to leave reviews on external platforms such as Google or TripAdvisor. Participation will always be voluntary.

(iv) To carry out satisfaction studies, statistical analyses, and segmentations to improve services, preferably using aggregated or anonymized data.

(v) To interact with Users through social media, respond to inquiries, and promote services and content.

(vi) To analyze browsing habits through cookies and similar technologies, for the purposes of content and advertising personalization, in accordance with the Cookie Policy.

(vii) To conduct internal research aimed at improving processes, developing new services, and optimizing the User experience, using aggregated or anonymized data whenever possible."

6.4. Use of video surveillance

"In the event of access to the apartments, data may be processed to ensure the safety of individuals and facilities:

(i) Images may be captured through video surveillance systems located exclusively in common areas (entrances, reception, hallways, and, where applicable, parking areas).

(ii) The purpose of this processing is (i) to ensure the safety of persons, property, and assets, (ii) to control access and prevent risky or unlawful situations, and (iii) to comply with legal obligations regarding security."

6.5. Other uses

Eric Vökel will not use personal data for purposes other than those described in this Privacy Policy. If data is intended to be processed for different purposes, the User will be informed in advance and, where applicable, their explicit consent will be obtained.

7. LEGAL BASIS

The processing of personal data by Eric Vökel is carried out in accordance with the legal bases established in the GDPR, the LOPDGDD, and other applicable legislation.

7.1. User Consent

"In cases where the legal basis is consent, such consent must be free, specific, informed, and unambiguous. It applies in the following situations:

(i) Voluntary submission of forms: When the User voluntarily completes forms on the Website to make contact, request information, or make reservations, they must expressly accept the Privacy Policy.

(ii) Commercial or promotional purposes: In subscriptions to newsletters, sending commercial, informational, or promotional communications, or participation in campaigns, surveys, raffles, or contests, always following the prior obtaining of specific and verifiable consent from the User.

The User guarantees the accuracy of the data provided and undertakes to communicate any changes thereto.

Consent may be withdrawn at any time, without retroactive effect, using the means provided in section 10 of this Policy. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to its withdrawal."

7.2. Legitimate Interest

"In accordance with Article 6(1)(f) of the GDPR, Eric Vökel may process personal data when necessary for the purposes of legitimate interests, provided that the fundamental rights and freedoms of the User do not prevail.

In particular:

(i) Handling general or professional inquiries received via email or forms, where no prior contractual relationship exists.

(ii) Conducting non-intrusive statistical analyses aimed at improving our services, internal processes, and the User experience.

In all cases, processing will be carried out in a manner that is proportional, transparent, and respectful of the rights of the data subjects."

7.3. Performance of a Contract

"Under Article 6(1)(b) of the GDPR, personal data may be processed when necessary for the performance of a contract to which the User is a party, or for the implementation of pre-contractual measures at the User’s request. This includes:

(i) Management of bookings for tourist apartments and provision of the contracted accommodation services.

(ii) Relationships with suppliers and collaborators, when necessary to formalize or execute the provision of services.

(iii) Formalization and management of employment or internship contracts, including the processing of data from candidates, employees, and interns, in accordance with the applicable legal and contractual obligations."

7.4. Public Interest

"Pursuant to Article 6(1)(e) of the GDPR, certain processing activities may be based on public interest, in particular:

(i) Access control and video surveillance systems in the apartments and spaces managed by Eric Vökel, with the purpose of protecting employees, guests, visitors, property, and assets, as well as ensuring compliance with legally required security measures."

7.5. Compliance with legal obligations

"Pursuant to Article 6(1)(c) of the GDPR, personal data will be processed when necessary to comply with legal obligations applicable to Eric Vökel, such as:

(i) Fraud prevention and transaction monitoring, to ensure security and transparency in contractual relationships.

(ii) Cooperation with public, judicial, tax, or police authorities in the context of requests, investigations, inspections, or administrative or judicial proceedings.

(iii) Compliance with sector-specific regulations applicable to tourism, accommodation, consumer protection, taxation, and anti-money laundering.

Where permitted by law, the User will be informed in advance about the transfer of their data to competent authorities, except when such disclosure could compromise the investigation or detection of illegal activities."

8. TO WHOM CAN WE COMMUNICATE AND/OR TRANSFER YOUR DATA?

8.1. Transfer of data to third parties

"As a general rule, Eric Vökel will not disclose Users’ personal data to third parties, except when there is a legal basis supporting such disclosure or when it is strictly necessary for the proper provision of the contracted services.

The following are the cases in which data disclosure may occur:

8.1.1. Mandatory disclosures for legal compliance

Data may be communicated to third parties when required by applicable law, including but not limited to:

(i) Public administrations and competent authorities, including tax, tourism, or consumer protection agencies.

(ii) Courts and tribunals, within the framework of judicial proceedings.

(iii) State Security Forces and Corps, as well as other police authorities, when necessary for the prevention, investigation, or prosecution of offenses.

(iv) Tourism authorities, in compliance with sector-specific regulations requiring the disclosure of guest data as a measure for control, security, and public order.

8.1.2. Disclosure to collaborators or external companies

In certain cases, personal data may be shared with collaborators, technology service providers, or trusted external companies, always in a limited manner and solely for legitimate purposes related to the contractual relationship with the User. In particular:

(i) Reservation management and customer service: Intermediary and management platforms such as Siteminder or Mews (PMS), used to centralize reservations, coordinate availability, and ensure the contracted service.

(ii) Pricing and revenue management: Providers such as Beonprice and revenue agencies that access the PMS, booking engine, and channel manager to optimize rates and availability.

(iii) Electronic payment processing: Platforms such as Paynopain and other certified providers for secure transaction processing, in compliance with payment services regulations and fraud prevention.

(iv) Marketing and digital communication: Digital marketing agencies with limited access to tools such as PMS, Google Analytics, and booking engines for campaign management, performance analysis, and improvement of the User experience.

(v) Social networks: Communication and social media agencies that access User profile data within the platforms used, always in accordance with the privacy policies of each social network.

In all cases, Eric Vökel will ensure that these third parties act as processors, joint controllers, or independent controllers as appropriate, always in accordance with processing contracts, joint responsibility agreements, or data protection clauses that guarantee confidentiality, security, and limited use of personal data for the purposes previously indicated.

8.1.3. Providers and data processors

For the proper development of its activities, Eric Vökel relies on external providers that act as data processors, i.e., service providers who may access personal data solely for the purpose of carrying out the assigned tasks. These include:

(i) Cloud service providers and web hosting services.

(ii) Reservation management platforms and payment systems.

(iii) Technical support services, customer service tools, CRM, digital marketing, or web analytics services.

(iv) IT service providers, with limited access to employees’ corporate email and other internal tools, solely to ensure system maintenance and security.

In all cases, these providers act only under Eric Vökel’s instructions and under a data processing agreement pursuant to Article 28 of the GDPR, ensuring that personal data is processed securely, confidentially, and in compliance with applicable regulations."

8.2. International data transfers

"As a general rule, Eric Vökel does not carry out international transfers of personal data. However, in the event that any of our providers or technological tools involve the processing of data outside the European Economic Area (EEA), it will be ensured that appropriate safeguards are applied as established in Articles 44 to 49 of the GDPR, such as the Standard Contractual Clauses approved by the European Commission, or that the destination country has an adequacy decision from the European Commission, or that additional technical and organizational measures are adopted to ensure a level of protection equivalent to that required within the European Union.

8.2.1. Transfers related to social network providers and technological services

The User is informed that international data transfers are carried out with the following entities, all of which are adherent to the EU–US Data Privacy Framework of 10 July 2023, ensuring an adequate level of protection:

(i) Google LLC, when using services such as Gmail.

(ii) Meta Platforms, Inc. (Facebook, Instagram).

(iii) LinkedIn Corporation.

More information is available in the official Data Privacy Framework Program list: www.dataprivacyframework.gov/list.

8.2.2. Collaborations with third parties

When collaboration with third parties is necessary that involves the transfer or access to data from outside the EEA, Eric Vökel will enter into the corresponding data processing agreements, incorporating the Standard Contractual Clauses approved by the European Commission’s Implementing Decision (EU) 2021/914 of 4 June 2021.

8.2.3. Server location

Except as mentioned above, all servers used by Eric Vökel for the provision of its services are located within the European Economic Area (EEA), specifically in Spain."

9. DATA RETENTION PERIOD

"Personal data will be retained only for as long as necessary to fulfill the purpose for which it was collected, as well as to determine any potential liabilities arising from the processing, and for the limitation periods established by applicable law.

In particular:

(i) Video surveillance footage: Footage will be retained for a maximum of one (1) month from the date of capture, unless it needs to be kept for a longer period to provide evidence of acts that threaten the integrity of persons, property, or facilities.

(ii) Other processing activities: Data will be retained for the duration of the service or contractual relationship and, subsequently, for the applicable legal limitation periods. Once these periods have elapsed, the data will be securely deleted in accordance with applicable regulations."

10. EXERCISE OF RIGHTS

10.1. What rights does the User have?

"The User may withdraw any consents granted at any time, as well as exercise the following rights recognized under data protection law:

(i) Access: To know which personal data is being processed, its origin, purposes, and any disclosures made.

(ii) Rectification: To request the correction of inaccurate or incomplete data.

(iii) Erasure (“right to be forgotten”): To request the deletion of personal data when one of the legally established grounds applies (e.g., unlawful processing or disappearance of the purpose).

(iv) Objection: To object to the processing of their data in certain cases, such as for advertising purposes or decisions based solely on automated processing.

(v) Data portability: To receive the data in a structured, commonly used, and machine-readable format and transmit it to another controller, whenever technically feasible.

(vi) Restriction of processing: To request the limitation of processing of their data in legally established cases (e.g., contesting accuracy or while an objection is being resolved).

(vii) Not to be subject to automated individual decisions: The right not to be subject to decisions based solely on automated processing, including profiling, which produce legal effects or similarly significantly affect them."

10.2. How can you exercise these rights?

"The User may exercise these rights by submitting a request along with a copy of an official identification document to:

(i) Email: reclamacion@ericvokel.com

(ii) Postal address: Calle Vizcaya, No. 9, 28045 Madrid, Spain.

The request must expressly indicate which right the User wishes to exercise.

Furthermore, the User has the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) if they consider that the processing of their personal data violates applicable law, without prejudice to any other administrative or judicial remedies that may be available."

11. SECURITY MEASURES IN DATA COLLECTION

11.1. Security measures implemented by Eric Vökel

"To ensure the protection of personal data on the Website, Eric Vökel has implemented a security system that guarantees the confidentiality, integrity, and availability of information submitted or collected through the designated channels. In particular, secure independent servers and technologies designed to reduce the risks of loss, alteration, unauthorized access, or misuse of data are used.

Eric Vökel maintains the levels of security required by the GDPR and the LOPDGDD, having implemented all reasonable technical and organizational measures within its reach to protect Users’ personal data.

However, the User acknowledges and accepts that no Internet system is completely impenetrable. Therefore, the User undertakes to adopt the necessary security measures to ensure the reliability of the Website when entering their data. Eric Vökel, for its part, will always act with the utmost diligence to safeguard personal information but shall not be liable for:

(i) situations arising from the User’s failure to adopt the corresponding security measures, and

(ii) consequences of actions by third parties outside the company, including cases of force majeure or unforeseeable events.

In this regard, Eric Vökel cannot guarantee that unauthorized third parties will remain unaware of the type, conditions, characteristics, and circumstances of the use made by Users of the Website and its services. Nevertheless, complementary measures have been established, including the terms of use set forth in the Legal Notice."

11.2. User Measures and Obligations

"Any User who provides personal data of third parties must have the prior and explicit authorization of the data subjects concerned. For this purpose, the corresponding forms include a checkbox through which the User declares that they have obtained such consent.

In the event of non-compliance with this obligation, the User shall release Eric Vökel from any liability arising from such improper processing or from any legal consequences that may result."

12. SOCIAL NETWORKS AND OTHER PLATFORMS

12.1. Social Networks

"Eric Vökel maintains corporate profiles on Instagram, LinkedIn, and Facebook.

In accordance with personal data protection regulations, Eric Vökel acts as the Data Controller regarding the data of Users who choose to interact with our profiles, whether by following us, liking, or engaging with our posts.

By doing so, the User accepts the terms of this Privacy Policy, which provides information on the processing of their data and the rights they are entitled to. In all cases, Eric Vökel ensures confidentiality in data processing and respects these rights in accordance with applicable law.

The primary purpose of our social media profiles is to disseminate information and news related to our services, as well as content that may be of interest to the community. Consequently, the User may receive such publications on their feed or profile through the functionalities provided by each platform.

It should be noted that there is no affiliation between Eric Vökel and the social media platforms used. Therefore, the User is subject to the terms of use, policies, and conditions of each platform, which are beyond the responsibility of Eric Vökel."

12.2. Other Platforms

"Eric Vökel may collaborate with service providers or use external technological tools for the management of certain services.

In particular, during the processes of booking or payment for accommodations, the User is redirected to external providers who collect personal data under their own terms and conditions. In such cases, the User must accept the privacy policy and terms of the respective provider, and Eric Vökel shall be exempt from any liability arising from the processing of data carried out by these providers for their own purposes."

12.3. Links

"Eric Vökel’s Website may contain links to third-party websites.

Access to such sites is at the sole responsibility of the User, who should take into account that each third party has its own privacy policy and terms of use. Consequently, Eric Vökel assumes no liability for the processing of data that such third parties may carry out.

Users are advised to carefully review the relevant privacy policies before providing personal information on external websites."

13. COOKIES AND OTHER TRACKING TECHNOLOGIES

"Our Website uses cookies and other tracking technologies to improve the browsing experience, personalize content, and analyze website usage.

Users can find detailed information about the types of cookies used, their purpose, and how to manage them in the Cookie Policy available on our Website."

14. MODIFICATIONS AND UPDATES

"Eric Vökel reserves the right to modify or update this Privacy Policy at any time in order to adapt it to legal, regulatory, or technological changes.

Users are advised to review this Policy periodically each time they access the Website to stay informed of any changes regarding the processing of their personal data."

15. INTEGRATION WITH OTHER LEGAL TEXTS

This Privacy Policy is complemented by the Legal Notice, the Cookie Policy, the General Terms of Service and Contracting, and, where applicable, any other legal texts that may be relevant.