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PRIVACY STATEMENT GOOD MOOD GROUP

This is the Privacy Statement of the Good Mood Group.

This statement applies to all personal data that Good Mood Group Global S.L. with NIF number B24968489, registered with the Commercial Registry of Alicante, trading under the commercial name “Good Mood Group”, with registered office at Calle Lluca 60, 03739 Jávea, Alicante, Spain, (hereinafter referred to as ‘we’, ‘our’ or ‘us’), processes of all persons (''you'' or ''user'') who accesses and/or uses our platforms, apps and/or websites, whether as a guest or a registered member, including any content, features, and services available on or through our websites, any webpages, and our (mobile) platforms and/or applications (both online and offline) that operate on smartphones, tablets, and other devices enabling non-browser-based interaction with our sites (collectively referred to as our "Platforms").

This statement will explain how we will use the data that we collect via our Platforms and which rights you have with respect to your personal data.

1. PERSONAL DATA

We collect and process your personal data through your use of any of our Platforms, including any personal data you may provide when you register or sign in on any of our Platforms, purchase a product or service, or take part in a competition. The types of personal data we collect depend on the products and/or services you use and how you interact with our Platforms.

Where the provision of personal data is required by law or necessary for the performance of a contract with you and you do not provide the requested data, we may be unable to enter into or fulfil the contract (for example, to supply products or services). In such cases, we may need to cancel the relevant product or service, and we will inform you if this occurs.

We process the following personal data of you for the purpose and on the legal basis as set out below. For as far as we collect personal data through cookies, please find more information in our Cookie Policy at www.goodmoodgroup.com.

  • Identity: name, address, title, date of birth, gender, marital status, profile photo, country of residence, nationality. • Contact information: delivery address, billing address, email address, telephone number.
  • Profile: username, password, profile photo, order history, preferences, interests, feedback, survey input.
  • Transactions: information about the transactions you have made, such as payments, and details regarding the products and/or services you have purchased.
  • Financial information: payment card information, payment history.
  • Technical information: IP address, login credentials, browser type and version, mobile phone device model, operating system, device settings, platform, file and software details, device identifiers, time zone and location settings, GPS, Bluetooth, Wi-Fi signals, browser plug-in types, network provider details, language preferences.
  • Usage data: information regarding how you interact with our Platforms, products and services, such as advantages/offers redeemed, pages visited and searches performed.
  • Aggregated data: such as statistics or demographic information, which we have aggregated such that it is not considered personal data (as it does not directly or indirectly is linked to your identity). If we however combine aggregated data with other personal data, we will treat the combined data as personal data and apply this Privacy Statement.
  • Marketing information: your preferences for receiving marketing communications from us and our partners, your communication preferences.
  • Guest information: Guest contact detail (name, email address, telephone number) received from our members and partners (e.g. property managers, rental agents, real estate agents). Members or partners may provide these details in order to invite guests to register for access to certain services available through our Platforms. Guests who accept such an invitation may create their own account on our Platforms, after which their personal data will be processed in accordance with this Privacy Statement.
  • Membership information: digital vouchers, QR codes (regarding membership or memberschip advantages).
  • Other (for improvement and relationship management):
    • Information from third-party partners regarding your use of their services, such as reviews of merchant partners or service providers.
    • Your networks and connections, depending on the permissions granted, including contacts from your address book on mobile and desktop devices, and social media platforms such as Facebook, Instagram, TikTok, Pinterest, and Twitter.
    • Communications with us via social media platforms, email, electronic messages and other communication channels.
    • Photos or other content uploaded by you to our Platforms or shared with other users of our Platforms.

 

We have set out below all the purposes for the processing of the specific personal data and lawful basis on which we rely. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data.

 

Type of personal data Purpose Lawful basis Retention period
Identity, contact, profile To register you as a new customer/user

Necessary for theperformance of a  contract with you Necessary to comply with a legal obligation

Stored for theduration of the contractual relationship and up to 2 years after termination, unless a longer period is required by law
Identity, contact, financial,  transaction, marketing To process and deliver your order including:
- Manage payments, fees and charges
- Collect and recover debts due to us
Necessary for the performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) 6 years  following the relevant transaction in order to comply with Spanish accounting and tax obligations
Identity, contact, profile, marketing To manage our relationship with you  which will include for example:
- notifying you about  changes to our terms or privacy policy
- asking you to leave a review or take a survey
- communicate with you about our products and services and respond to you when you contact us
Necessary for the  performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records
updated and to study
how customers use our
products/services)
Stored for theduration of the relationship  and up to 2years after the end of the contract
Identity, contact, profile, usage, marketing To enable you to partake in a prize draw, competition or complete a survey Necessary for the performance of a contract with you
Necessary for our legitimate interests (to study how customers
use our products/services, to develop them and grow our business)
Up to 1 year  after completion of the relevant campaign or activity
Identity, contact, technical To administer and protect our business and the Platforms (including troubleshooting, improvement, data analysis, testing, system maintenance, security, support, reporting and hosting of data) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
Up to 12 months for system logs and technical monitoring data
Identity, contact, profile, usage, marketing, technical To deliver relevant Platform content and advertisements to you and measure or  understand the effectiveness of the advertising we serve to you Necessary for our legitimate interests (to study how customers
use our products/services, to  develop them, to grow our business and to inform our marketing strategy)
Up to 24 months or until you withdraw consent, whichever occurs first
Identity, contact, profile, usage, marketing, technical To deliver better and more personalized Platform content so that you have beneficial and valuable experience when using our Platforms, products and/or services Necessary for the performance of a contract with you
Necessary for our legitimate interest (to optimize our service offerings and improve customer experience)
Stored during  the relationship
and up to 2 years after the last user activity
Identity, contact, profile To enable you to utilize a feature of a product or service provided to you Necessary for the performance of a contract with you Stored for the duration of the contract and up to 2 years thereafter
Identity, technical, usage, transaction To use data analytics to improve our Platforms, products/services, marketing, customer relationships and experiences Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platforms updated and relevant, to develop our business and to inform our marketing strategy)
Necessary to comply with a legal obligation
Up to 18 months, after which the data is anonymised or deleted
Identity, contact, technical, usage, profile To make suggestions and recommendations to you about goods or services that may be of interest to you Necessary for our legitimate interests (to develop our products/services and grow our business) Until you opt out or after 2 years of inactivity
Guest data To invite guests to register for guest access to the Platform and to proactively offer concierge services and contact them with relevant service offerings during their stay Necessary for our legitimate interests (to optimize our service offerings and improve customer experience);
Necessary for the performance of a contract with the member or partner providing the guest access
Up to 1 year after the last interaction
Transaction, profile, usage,
marketing
To understand which  services have been purchased from our service providers and by whom, in order to provide targeted  recommendations, develop tailored offerings, and enable future or repeat bookings. Necessary for our  legitimate interests (to optimize our service offerings and improve customer experience) Up to 2 years after the last purchase
Identity, profile, transaction, membership  To generate digital vouchers or QR codes for use at service provider locations to redeem benefits and verify active membership status 

Necessary for the performance of a contract with you 

Stored for the duration of the membership and up to 2 years after termination

 

2. MARKETING

We may use your Identity, Contact, Technical, Usage and Profile Data for marketing purposes. This helps us determine which products, services, or offers may be most relevant to you.

If you are not an existing customer, we will only send you marketing communications if we have obtained your consent. If you are an existing customer, we may send you marketing communications about similar products or services unless you have opted out of receiving such communications. You can ask us or third parties to stop sending you marketing messages at any time by logging into the Platform and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

With your consent we may share your personal data (such as your name, email address, gender, date of birth, and nationality) with third parties for marketing purposes. These third parties may have their own privacy policies, which govern the collection and use of your information. However, they may also provide options for you to opt out of having your information collected or used in this manner.

3. AI-BASED MODULE

We may use artificial intelligence (“AI”) on our Platforms to improve functionality, efficiency and your overall user experience. These AI-based tools may analyse interactions, usage patterns and user- provided content to enhance features, streamline processes and provide relevant support.

Our customer support may be provided partly through AI-driven systems, including automated text- or voice-based tools. These systems may process personal data contained in your communications with us in order to respond to inquiries, provide assistance and improve our services. When using our AI- based features, we may process the following categories of information:

- User-provided content: text, messages or other content that you voluntarily submit when interacting with our AI assistant, which may include personal data such as your name, email address, gender, telephone number, age or other identifiers.
- Usage data: Information about your interaction with our AI assistant such as features used, timestamps, frequency of use and interaction patterns.
- Device and technical data: technical information such as device type, operating system, application version and similar technical identifiers.
- Optional data: location data and analytics data use to monitor and improve the performance and usability of the application.

Where AI-based customer support is used, you may always request to communicate with a human representative.

We do not use AI systems to make decisions that produce legal effects concerning you or similarly significantly affect you, unless we inform you otherwise and such processing is permitted under applicable data protection law.

We process personal data collected through our AI-based tools for the following purposes:

- respond to your questions;
- improve the AI assistant;
- keep our systems secure and reliable; and
- comply with legal obligations

The processing of personal data through AI-based tools can be lawfully based on the following legal grounds:

- Necessary for the performance of a contract (Article 6(1)(b) GDPR): where AI-based tools and customer support are necessary for the performance of the agreement, such as handling support requests, providing assistance, and enabling core platform features.
- Our legitimate interests (Article 6(1)(f) GDPR): where AI-based tools are used to enhance user experience, optimize customer support, ensure quality control, and improve or train our systems.
- Consent (Article 6(1)(a) GDPR): where the use of AI-based tools goes beyond the performance of the contract or legitimate interests, such as for marketing, profiling, or the processing of sensitive data, we will seek your (explicit) consent.

We may use trusted service providers (such as cloud hosting providers) to operate the AI-based tools. They only process data on our behalf and under strict safeguards. We do not sell your personal data.

Conversations with our AI assistant may be stored for a limited time to provide the service, check quality and fix technical issues. Data is kept only as long as necessary or as required by law.

4. SHARING YOUR PERSONAL DATA

Your personal data may be processed outside the European Economic Area (EEA) in countries that may not provide the same level of data protection as within the EEA. In such cases, we ensure that appropriate safeguards are implemented to protect your personal data in accordance with applicable data protection laws.

We may share your personal data with other entities within our group of companies for purposes consistent with this privacy statement. This includes, but is not limited to, the provision of services, internal administrative purposes, compliance with legal obligations, and ensuring the security and integrity of our systems. We may share your personal data with service providers that perform functions on our behalf, such as IT services, payment processing, marketing support, or other similar services to us. Your personal data may also be shared with professional advisors, such as lawyers, accountants, or consultants, where necessary for legal, tax, or business purposes. If we provide access to your data, we require the third parties to keep your data confidential and – where applicable – instruct these parties to process this data only on behalf of us.

In the event of a merger, acquisition, reorganization, sale of assets, or other business transaction that involve us, the Platform or (parts of) our company, your personal data may be transferred as part of the transaction.

Furthermore, we may also disclose your data if we believe that the disclosure is required by law, or is in response to a legal request. We may also disclose your personal data to government authorities, regulatory bodies, or law enforcement agencies if required by law or necessary to protect our rights, prevent fraud, or ensure the security of our systems.

5. SECURITY

We implemented appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access and against all other forms of unlawful processing. Also, we require our data processors to implement such appropriate technical and organizational measures.

6. RETENTION PERIOD

Your data will be stored no longer than is necessary for the purposes for which the personal data is collected unless otherwise required by law. See the table under section 1 for the specific retention period per data category.

When determining the appropriate retention period, we take into account the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized access or disclosure, the purposes for processing your data and whether these purposes can be achieved through alternative means, as well as the applicable legal requirements. In some cases, we may anonymize your personal data (so that it can no longer be linked to you) for research or statistical purposes, in which case we may use this data indefinitely without further notice to you.

7. YOUR RIGHTS

You may contact us by using the contact details at the bottom of this privacy statement, if you wish:

- to know whether or not we process your personal data;
- rectify your data;
- erase your data;
- restrict your data; and/or
- us to transmit your data to another organization.

We may request provision of additional information necessary to confirm your identity. To the extent required, we will provide information on the actions taken without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of your request, together with the reasons for the delay.

If you believe that our processing of your personal data violates applicable data protection laws, you have the right to lodge a complaint with the relevant supervisory authority. For Spain, the supervisory authority is the Spanish Data Protection Agency (Agencia Española de Protección de Datos - AEPD). You can find more information about how to submit a complaint on their official website: www.aepd.es.

8. MODIFICATIONS

It is possible that this statement will be amended in the future. The most recent version will be available at www.goodmoodgroup.com at all times.

9. CONTACT US

If you have any questions or complaints, please do not hesitate to contact us at legal@goodmoodgroup.com.