LAS RUINAS
BATHHOUSE & GYM
PRIVACY POLICY

(Effective Date: December 1, 2025)

Las Ruinas Bathhouse & Gym LLC (“Las Ruinas,” “we,” “our,” or “us”) is committed to protecting

your privacy.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal

information when you visit our website, make a booking, use our facilities, or interact with

our services.

This Policy complies with:

U.S. Federal privacy laws

Puerto Rico laws, including Act 39-2012 (PR Data Breach Notification Act) and

relevant consumer privacy protections

EU General Data Protection Regulation (GDPR) for users located in the EU/EEA

By accessing our website or services, you acknowledge that you have read and understood

this Privacy Policy .

1. INFORMATION WE COLLECT

We collect information in the following categories :

1.1 Information You Provide Directly

This includes :

Personal details: name, email, phone number, date of birth, address

Booking information: reservation details, membership data, service selections

Payment information: card details processed securely by third-party processors (we

do not store full card numbers)

Health-related disclosures voluntarily provided for sauna, steam, massage, and

wellness services

Identification documents when required for age verification or legal compliance

Communications: emails, customer support requests, surveys, and feedback

1.2 Information Collected Automatically

When you use our website or booking system, we may

collect:

IP address

Browser type

Device identifiers

Cookies and tracking technologies

Pages viewed and actions taken

Access times

Referral URLs

We use this information for security, analytics, customization, and performance improvement.

1.3 Information from Third Parties

We may receive information from:

Booking platforms (e.g., Mariana Tek, Stripe, Toast)

Social media platforms (if you interact with our accounts)

Gift card or membership partners

Data security and fraud prevention vendors

2. HOW WE USE YOUR INFORMATION

We use your information for the following lawful purposes:

2.1 To Provide

Services

Process bookings and payments

Verify eligibility (including age requirements)

Provide bathhouse, wellness, gym, and spa services

Schedule appointments and manage memberships

Maintain safety and operational functionality

2.2 For Customer Service & Communications

Confirm bookings or cancellations

Provide updates, reminders, and service notifications

Respond to inquiries

Send safety, policy, or operational messages

2.3 For Legal, Safety, and Security Purposes

To comply with U.S. and Puerto Rico laws

To comply with GDPR for EU visitors

Fraud detection and prevention

Enforcement of Terms & Conditions

Response to legal requests or subpoenas

Maintaining on-site security

2.4 For Internal Operations

Data analysis and performance optimization

Improving customer experience

Staff training

Marketing analytics (anonymous or aggregated)

2.5 With Your Consent

Certain uses—such as marketing emails—may require your affirmative consent.

You may withdraw consent at any

time.

3. COOKIES & TRACKING TECHNOLOGIES

We use:

Essential cookies (for site functionality)

Analytics cookies (Google Analytics, Meta Pixel, etc.)

Security cookies (fraud prevention)

You may disable cookies in your browser, though some features may not function properly.

For EU users, we provide cookie consent controls as required by GDPR.

4. LEGAL BASIS (GDPR Users Only)

For users located in the EU/EEA, we rely on the following lawful bases:

Contract performance (e.g., bookings, membership fulfillment)

Consent (e.g., marketing communications)

Legitimate interests (e.g., security, analytics)

Legal compliance (e.g., tax, accounting, safety regulations)

5. SHARING OF PERSONAL INFORMATION

We do not sell personal information.

We may share information with:

Service providers: payment processors, booking platforms, email/SMS systems

Professional advisors: legal, accounting, cybersecurity

Government or law enforcement where required

Third-party contractors or vendors necessary for operations

Affiliated businesses under common control of Las Ruinas

All third parties are bound by confidentiality and data protection obligations.

6. INTERNATIONAL TRANSFERS

If you are located outside Puerto Rico or the United States:

Your information may be transferred to servers in the U.S.

We use GDPR-approved safeguards such as Standard Contractual Clauses (SCCs)

when applicable

7. DATA RETENTION

We retain your information only as long as necessary to:

Provide services

Comply with legal obligations

Resolve disputes

Enforce agreements

Membership and booking records may be retained pursuant to Puerto Rico statutory

requirements .

8. YOUR RIGHTS

Your rights differ based on jurisdiction .

8.1 Rights Under Puerto Rico Law

You may :

Request copies of your personal data

Request corrections

Request deletion, where legally permissible

Receive breach notifications under PR Act 39-2012

8.2 GDPR Rights (EU/EEA Visitors Only)

You have the right to:

Access your data

Correct your data

Delete your data “right ( to be forgotten” )

Restrict processing

Object to processing

Data portability

Withdraw consent

File complaints with EU supervisory authorities

To exercise any rights, email: hello@lasruinas.com

9. CHILDREN’S PRIVACY

Las Ruinas does not knowingly collect personal information from individuals under 18

without parental or guardian

consent.

If we learn that we have inadvertently collected such information, we will delete it.

10. DATA SECURITY

We employ industry-standard security

measures:

Encryption of payment data

Secure server storage

Access controls

Firewalls and intrusion prevention

Vendor security vetting

No system is fully secure, and we cannot guarantee absolute protection.

11. DATA BREACH NOTIFICATION:

Should a breach occur:

We will notify affected individuals as

required by Puerto Rico Act 39-2012, U.S. law,

and GDPR (within 72 hours, when applicable).

12. MARKETING COMMUNICATIONS

You may opt out of marketing emails at any time via:

“Unsubscribe” links

Transactional messages (e.g., booking confirmations) cannot be opted out of.

13. THIRD-PARTY LINKS

Our website may contain links to third-party

sites.

We are not responsible for their privacy practices or

content.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy at any

time.

Updates will be posted on our website with a new “Effective Date.”

Continued use of the website constitutes acceptance.

15. CONTACT INFORMATION

For privacy-related questions, rights requests, or complaints:

Email: hello@lasruinas.com

Postal Address:

Las Ruinas Bathhouse & Gym LLC

104 C. De la Cruz,Viejo San Juan, Puerto Rico