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Privacy policy

Hotel passage privacy policy

Please use the website of LORD® responsibly and, before continuing, read this privacy policy, cookies policy, legal notice and the general conditions for contracting of the website as its content is binding for you as a user of the website.

The owner of this website is LORD REAL ESTATE BV Sucursal en España, (henceforth, LORD®), a Spanish commercial company, established for an indefinite period. For more information about LORD® please read the Legal Notice.

LORD® respects the fundamental rights, public freedoms and interests of everyone it deals with. Thus, LORD® respects all legal requirements relating to data protection and safeguards, in accordance with them, the personal data that it collects and processes.

1.- Data collection

LORD® provides information about the purposes for which it is collecting personal data at the time of collecting it. In this regard, LORD® does not collect more data than is strictly necessary.

However, we wish to inform you that, as a general rule, the personal data you provide will be processed for the purpose of handling your information request, booking, contracting, payment, check in/out of the services contracted, and also to inform you about other LORD® products or services when you give your consent. LORD® will not disclose your data to third parties other than the entities where this is necessary for the management and implementation of commercial relationships that arise such as the booking and/or payment of the services contracted. 

The data compiled by LORD is as follows:

Identification data Name, surname, date of birth, National ID No., Foreigner Identification Number or passport, address, telephone number, email address. To carry out the booking, contracting, check in and check out, and to provide you with our support if necessary. Your personal identification details will also be used to manage and resolve claims and/or to fulfil the legal requirements of the governmental authorities.
Financial data Card number, expiry date, security number on the back of the card. To make the booking and pay for the services contracted.
Other data Telephone number To send you push notifications with information about the booking, check in and check out. Please read the instructions on your mobile device to find out how to change the settings and control the exchange of this category of data. In order to send you administrative notifications referring to: security alerts, improper behaviour and/or notifications or warnings. For promotion and marketing purposes to inform you about offers and promotions that you have expressly agreed to beforehand.
Other data Email address and IP address In order to send you administrative notifications referring to: security alerts, improper behaviour and/or notifications or warnings. For promotion and marketing purposes to inform you about offers and promotions that you have expressly agreed to beforehand. We also use personal data such as the IP address for analytical purposes and to improve the products and services of LORD. Please read our Cookies Policy to manage authorisations.

The services of LORD® are not targeted at people under the age of 16. Data from minors is not collected unless it is provided by a parent or legal guardian (and their consent is given). Please bear in mind that LORD® is obliged to collect personal data from minors under the age of 16 in specific circumstances, when they are part of a booking or check in and check out, or in other exceptional circumstances (as options targeted at families). 

In accordance with what is established in the legal regime of data protection, LORD® guarantees the right of interested parties to withdraw the consent granted for its use, to exercise the rights of access, rectification, limitation of processing, deletion, portability and opposition. For any of these actions, the interested party must send a written request to 

LORD® will indicate additional processing or processing different to that mentioned that the data collected in each case will be subjected to and the purpose for which it will be processed in each of the data collection forms. We remind you that you cannot enter the data of third parties. If you need to do so, please contact us via email at and we will help you.

We strongly recommend reading the information clauses located at the bottom of each of the forms before accepting them. We remind you that sending any of the forms entails unreservedly accepting the conditions outlined.

2.- Disclosure of data

LORD® does not disclose personal data to third parties without informing the holders beforehand about what data it is going to disclose, the identity of the assignees, their activity and the purposes for which the assignees may use the data and unless that, if necessary, it has also obtained the consent of the holders of the data.

For example: we use third parties to process payments, manage the refunds of charges or offer collection and billing services with payment platforms which in turn have agreements with the different financial entities. In this regard, we inform you that identification data will be collected about the holder of the credit or debit card, as will the number, the expiry date and the security code on the back of your card, and the transaction carried out, and they will be sent to your banking institution. 

3.- Cross-border data processing

LORD® does not carry out cross-border processing of data from its clients without adhering to one of the circumstances that allow it. 

4.- Security

LORD® has adopted all the necessary technical and organisational measures needed to guarantee the integrity, availability and confidentiality of the personal data it processes. Thus, LORD® applies the security measures required by the principle of security and only contracts -despite the higher cost- internet service providers (ISPs) that meet the strictest international standards for the management of information security.

5.- Commercial communications

LORD® sends commercial communications electronically to the email addresses and mobile telephone numbers provided during the contracting of services if they have been requested or agreed to beforehand by the holders. LORD® will request your consent for this purpose in all the data collection forms and will give you the option to revoke this consent in each of the communications that it sends to you.

In any case, LORD® provides the option to choose if you wish or do not wish to receive these types of communications; it enables you to withdraw consent for all the electronic commercial communications it sends; and it enables you to withdraw consent at any time you wish.

6.- Rights of the holders of data

LORD® allows the holders of personal data to exercise their rights of access, rectification, limitation, portability, opposition and deletion in the terms outlined in the General Data Protection Regulation and its implementing legislation. To do so, it is necessary to contact the Data Protection Officer of LORD® via email at: 

You can also obtain the protection of the control authority that you want (

7.- Validity and modification of this data protection policy 

This privacy policy is valid from 1 July 2022. LORD® reserves the right to unilaterally modify its privacy policy in the event that there is a change in current legislation, case law or internal criteria. Any change made to this policy will be published at this same address.

Current version: Privacy policy v1.0

Entry into force: 1 July 2022.

8.- Applicable law and jurisdiction

This website and its use by users is governed by Spanish and European legislation and any dispute that may arise regarding the application, compliance or interpretation of these conditions will be settled before the Courts of Donostia – San Sebastian. For that purpose, as a user, you freely and expressly waive any jurisdiction that may correspond to you. 

9.- Acceptance and legal contact

By browsing on the website of LORD® you state that you have read, understood, know and accept, unreservedly, all of its legal conditions.  To resolve any doubt regarding the content or scope of this privacy policy, contact us via

We will be delighted to assist you.

Many thanks for your attention!

10.- Related content

Legal Notice

Cookies Policy

General Contracting Conditions.

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