PRIVACY POLICY
CASA TORNO
La Tahona · El Refugio · La GalerÃa · El Mirador
Last updated: July 2026
1. DATA CONTROLLER
The controller responsible for the processing of personal data is:
TORNO LIVING, S.L.
Tax ID (CIF): B26755926
Calle Torno nº 8
11540 Sanlúcar de Barrameda (Cádiz), Spain
Email: [email protected]
Telephone: +34 711 510 319
Tourist registration number: VUT/CA/25950
Hereinafter, CASA TORNO or TORNO LIVING, S.L.
TORNO LIVING, S.L. processes personal data in accordance with Regulation (EU) 2016/679 (GDPR), Spanish Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights, and any other applicable legislation.
2. PERSONAL DATA WE MAY PROCESS
Depending on the user’s or guest’s relationship with CASA TORNO, the following categories of personal data may be processed:
- Identification and contact details, such as first and last name, identity document or passport, address, email address and telephone number.
- Information necessary for the booking and stay, including dates, accommodation booked, number and identity of guests and requests relating to the stay.
- Information required to comply with legal obligations concerning guest registration and reporting.
- Billing and payment information.
- Communications with CASA TORNO before, during or after the stay.
- Information relating to requests, incidents, complaints or services requested.
- Technical and browsing data generated when using the website, where applicable.
- Images captured by CCTV systems installed in certain common areas and access points of the property.
CASA TORNO will only process data that is appropriate and necessary for the relevant purposes.
3. PURPOSES OF PROCESSING
Personal data may be processed for the following purposes:
Booking management and provision of accommodation
To manage booking requests, confirm and administer stays, carry out check-in procedures, manage access, provide booked services and assist guests before, during and after their stay.
Compliance with legal obligations
To comply with legal obligations applicable to the activity, including guest registration and reporting requirements, as well as tax, accounting, administrative and consumer protection obligations.
Payments and invoicing
To manage payments, deposits or security deposits where applicable, refunds and the issuing of invoices.
Guest assistance and communications
To respond to enquiries, requests, incidents, complaints and communications relating to a booking or stay.
Provision and coordination of services
To manage services included in the stay or requested by the guest and, where necessary, coordinate the involvement of staff or service providers.
Security
To protect guests, staff, visitors, facilities and property, manage access systems and investigate possible incidents.
Operation and improvement of the website
To ensure the operation, security and maintenance of the website and, where consent has been given or otherwise permitted by law, analyse its use.
Marketing communications
To send marketing information about CASA TORNO only where there is a valid legal basis to do so and, where required, the user has given prior consent.
4. LEGAL BASIS FOR PROCESSING
Depending on the circumstances, personal data will be processed on one or more of the following legal bases:
- Performance of a contract or steps taken prior to entering into a contract, for the management of bookings, stays, services, payments and related communications.
- Compliance with legal obligations, including those relating to guest registration, taxation, accounting and consumer protection.
- Legitimate interests of TORNO LIVING, S.L., where applicable, including ensuring the security of the property, preventing fraud, managing incidents and protecting its rights and property.
- Consent of the data subject, where required for certain processing activities, such as certain marketing communications or the use of non-essential cookies.
Where processing is based on consent, consent may be withdrawn at any time without affecting the lawfulness of processing carried out before its withdrawal.
5. GUEST REGISTRATION
CASA TORNO is required to collect and report certain guest information to the competent authorities in accordance with Spanish regulations applicable to accommodation providers.
Providing the information legally required for guest registration is mandatory in order to stay at the property.
The data will be used and retained for the periods established by applicable legislation.
6. PAYMENTS
Payments may be managed through financial institutions, booking platforms or payment service providers.
CASA TORNO may process the information necessary to manage payments, confirm receipt of payment, issue refunds, manage security deposits and carry out the corresponding invoicing.
Where payment is processed directly by a specialised payment provider, full payment method details may be processed directly by that provider in accordance with its own terms and privacy policies.
7. RECIPIENTS OF PERSONAL DATA
Personal data will not be disclosed to third parties unless this is necessary to provide the booked services, required by law or otherwise supported by a valid legal basis.
Depending on the circumstances, personal data may be accessible to:
- Public authorities, law enforcement agencies, courts and other authorities where required by law or pursuant to a valid request.
- Financial institutions and payment service providers.
- Intermediary platforms used to make or manage bookings.
- Technology providers required for the operation of the website, booking systems, communications and management of the property.
- Professional advisers and service providers where necessary to comply with legal obligations or manage the business.
- Service providers involved in providing services requested by the guest, only where necessary.
Providers processing personal data on behalf of TORNO LIVING, S.L. will act as data processors where legally applicable and will be subject to the relevant data protection obligations.
8. INTERNATIONAL DATA TRANSFERS
Some technology providers or platforms used by CASA TORNO may process personal data outside the European Economic Area.
Where an international transfer of personal data takes place, TORNO LIVING, S.L. will adopt or require the safeguards provided for under applicable data protection legislation, such as adequacy decisions, Standard Contractual Clauses or other legally recognised mechanisms.
9. DATA RETENTION
Personal data will be retained for as long as necessary to fulfil the purpose for which it was collected.
Thereafter, data may be retained, duly restricted or blocked where applicable, for the periods necessary to comply with legal obligations and address any potential liabilities arising from the contractual relationship.
Data subject to specific statutory retention requirements will be retained for the periods established by the relevant legislation.
Where processing is based exclusively on consent, data may be retained until consent is withdrawn, without prejudice to any additional retention period required to address legal liabilities.
10. CCTV
CASA TORNO operates CCTV systems in certain common areas and access points of the building for the purpose of protecting guests, staff, visitors, facilities and property.
Cameras may be located in areas such as the entrance, common courtyard and garage.
There are no cameras inside the apartments or in areas intended for guests’ private use.
The controller responsible for processing CCTV images is TORNO LIVING, S.L.
Images are processed for security and prevention purposes and, where necessary, to investigate incidents.
The legal basis for this processing is the legitimate interest in ensuring the security of people, property and facilities, in accordance with applicable legislation.
Images will generally be retained for a maximum of one month from the date of recording, unless they need to be retained for longer in order to establish facts affecting the integrity of people, property or facilities, or where required by the competent authorities.
Access to CCTV images is restricted to authorised persons. Images may be disclosed to law enforcement agencies, courts or other authorities where legally appropriate.
Areas under CCTV surveillance will be identified by the corresponding notices and signage.
11. MARKETING COMMUNICATIONS
CASA TORNO may send communications necessary to manage a booking, stay, request or booked service.
Marketing or promotional communications will only be sent where there is a valid legal basis for doing so.
Where such communications are based on consent, the data subject may withdraw that consent at any time.
Recipients may also request to stop receiving marketing communications through the mechanisms provided in each communication or by contacting TORNO LIVING, S.L.
12. COOKIES AND BROWSING DATA
The CASA TORNO website may use cookies and similar technologies.
Strictly necessary cookies may be used to enable the operation and security of the website.
Analytics, advertising or other categories of cookies requiring consent will only be used where the user has accepted them.
Full information is available in the CASA TORNO Cookie Policy and through the cookie settings panel available on the website.
13. DATA SUBJECT RIGHTS
Individuals whose personal data is processed may exercise, where applicable, the following rights:
- Access to their personal data.
- Rectification of inaccurate or incomplete data.
- Erasure of their personal data.
- Objection to processing.
- Restriction of processing.
- Data portability.
- Withdrawal of consent where processing is based on consent.
To exercise these rights, a request may be sent to:
TORNO LIVING, S.L.
Calle Torno nº 8
11540 Sanlúcar de Barrameda (Cádiz), Spain
[email protected]
The request must allow the data subject to be identified and specify the right they wish to exercise. Where necessary to verify the identity of the applicant, additional information may be requested.
Data subjects also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD) if they consider that the processing of their personal data does not comply with applicable data protection legislation.
14. DATA SECURITY
TORNO LIVING, S.L. will implement appropriate technical and organisational measures to protect personal data against loss, alteration, unauthorised access, disclosure or processing, taking into account the nature of the data and the risks associated with the processing.
15. THIRD-PARTY DATA
Where a person provides CASA TORNO with personal data relating to other guests or individuals, they declare that they are authorised to do so and undertake, where applicable, to inform those individuals about the processing of their data.
The information provided must be accurate and kept up to date where necessary.
16. UPDATES TO THIS POLICY
TORNO LIVING, S.L. may update this Privacy Policy to reflect legislative, technical or operational changes or changes relating to the services provided.
The version in force shall be the version published on the website at any given time.
Last updated: July 2026
CASA TORNO
La Tahona · El Refugio · La GalerÃa · El Mirador
Welcome to a peaceful way to discover Sanlúcar.