1. Programme Terms and Conditions

1.1 Promoter and contractual operator

GRUPO HOTELES PLAYA, S.A., a company limited by shares (sociedad anónima) incorporated under the laws of Spain, with Spanish Tax Identification Number (C.I.F.) A04108973, having its registered office at Ctra. Faro Sabinal, No. 341 – Edificio Playa Hoteles, 04740 Roquetas de Mar (Almería), Spain, and registered with the Commercial Registry of Almería under Volume 204, Folio 212, Section 3, Sheet 3018, Entry 1 (the “Promoter”, “Senator”, “we”, “us” or “our”), operates the UK Trade Welcome Programme / UK Trade Programme (the “Programme”) under the Senator Hotels & Resorts / Senator Pro / Senator Pro+ commercial umbrella.

The Programme is made available exclusively to eligible professional travel trade businesses and authorised travel trade professionals operating in or targeting the United Kingdom market. It is not directed at consumers and must not be relied upon by consumers.

1.2 Definitions and interpretation

In these terms and conditions (the “Programme Terms”), the following definitions apply unless the context requires otherwise:

• “Affiliate” means, in relation to Senator, any company controlled by, controlling or under common control with Senator from time to time.
• “Agent Toolkit” means any photographs, images, copy, hotel descriptions, sales sheets, links, documents, brand assets, logos, booking information, training materials or other content made available by Senator for use in connection with the Programme.
• “Applicable Law” means all laws, regulations, regulatory guidance, advertising codes, data protection laws, electronic marketing rules and mandatory legal requirements applicable to the Programme, including, where relevant, Spanish law, EU GDPR, applicable Spanish data protection and e-commerce rules, UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), the CAP Code and applicable UK advertising, gambling and lottery rules.
• “Commission Terms” means the commission rules set out in Section 2 below, as amended from time to time in accordance with these Programme Terms.
• “Eligible Booking” has the meaning given to it in the Commission Terms.
• “Participating Hotels” means the hotels, hotel brands, properties or accommodation products expressly identified by Senator as participating in the Programme from time to time.
• “Programme Benefits” means any access, registration status, toolkit access, commission opportunity, prize draw entry, promotional advantage, information, content, offer or other benefit made available under or in connection with the Programme.
• “Trade Partner” means an eligible professional travel agency, travel trade business, travel agent or authorised travel trade representative that has completed registration and has been accepted or validated by Senator for the Programme.

For the avoidance of doubt, the use of the expression “travel agent” in any marketing material is descriptive of the recipient’s business sector only and does not create an agency, mandate, authority to bind, commercial agency or representative relationship with Senator.

1.3 Acceptance and contractual effect

By registering for, accessing or using the Programme, the Trade Partner agrees to be bound by these Programme Terms, the Commission Terms, the Prize Draw Terms where applicable, the Privacy Notice and any additional instructions or eligibility requirements notified by Senator.

Where an individual accepts these Programme Terms on behalf of a company, agency or other business, that individual represents and warrants that they are duly authorised to bind that business. Senator may require evidence of such authority at any time.

1.4 B2B nature and eligibility

The Programme is a business-to-business trade initiative and is available only to Trade Partners acting in the course of business. Senator may request verification of professional status, business identity, website, trade credentials, licensing, regulatory status, VAT/tax details, booking profile, market focus or authority to act for the relevant agency.

Senator may decline, suspend, reject or terminate any registration, in its sole discretion and without liability, where the registration is incomplete, inaccurate, duplicated, automated, not properly authorised, inconsistent with the purpose of the Programme, or reasonably suspected of fraud, misuse, misrepresentation, breach of law or breach of these Programme Terms.

1.5 Registration as a condition precedent

Valid registration, acceptance of the applicable terms and validation by Senator are conditions precedent to any Programme Benefit accruing or becoming capable of being claimed. No commission, prize draw entry, access right, toolkit licence, promotional benefit or other right shall arise, accrue or become enforceable before the date and time on which the Trade Partner has completed the registration process required by Senator and has been accepted or validated by Senator.

The Programme has no retrospective effect. Bookings, leads, clients, enquiries, contacts, opportunities, transactions or relationships originated, introduced, made, held, quoted, pending or confirmed before valid registration shall not be eligible for Programme Benefits, unless Senator expressly agrees otherwise in writing and on a case-by-case basis.

Senator may withhold access to the Programme, the Agent Toolkit, commission processing and Prize Draw participation pending completion of verification to Senator’s reasonable satisfaction.

1.6 Nature of the Programme; no appointment

The Programme is discretionary, promotional, non-exclusive, non-permanent and revocable. It is intended to support commercial awareness of Senator hotels and the Senator Pro+ booking route among UK travel trade professionals.

Nothing in these Programme Terms or in any Programme material shall be construed as creating any franchise, agency, mandate, employment, partnership, joint venture, fiduciary relationship, commercial agency, distribution agreement, exclusive sales arrangement or permanent cooperation relationship between Senator and any Trade Partner.

The Trade Partner is not authorised to bind Senator, incur obligations on Senator’s behalf, make representations or warranties for Senator, vary booking conditions, grant discounts, amend rates, promise availability, approve claims, or hold itself out as Senator’s agent, representative, branch, franchisee, distributor, authorised signatory or exclusive partner.

1.7 Participating Hotels, availability and booking routes

Unless Senator expressly states otherwise, the welcome commission is intended to apply across Senator’s full hotel collection made available through Senator Pro+ during the Welcome Commission Period. Participating Hotels, room types, rates, booking routes, allocations, booking windows, rate plans, geographical markets, promotional messages and availability may vary from time to time. Inclusion of any hotel in the Programme does not guarantee availability, inventory, price parity, rate continuity, commissionability, allocation, room category, brand participation or continued participation in the Programme.

Senator may add, remove, replace, suspend or reclassify hotels, booking routes, rate plans and Programme assets at any time in accordance with these Programme Terms.

1.8 No vested rights or goodwill compensation

Participation in the Programme shall not give rise to any acquired, vested, continuing, future, goodwill, exclusivity, minimum-volume, renewal, compensation, indemnity, loss of profit, loss of chance or similar rights in favour of any Trade Partner.

For the avoidance of doubt, no Trade Partner shall be entitled to any payment, goodwill indemnity, customer indemnity, portfolio compensation, loss of profit, loss of business, loss of opportunity or similar amount by reason of the modification, suspension, withdrawal, expiry or termination of the Programme or any Programme Benefit, except to the extent that such exclusion is prohibited by mandatory Applicable Law.

1.9 Modification, suspension, withdrawal and termination

Subject always to mandatory Applicable Law, Senator may, in its sole discretion, at any time, for any reason or no reason, with or without prior notice and without liability, modify, suspend, withdraw, restrict, interrupt, terminate or discontinue all or any part of the Programme, including any Programme Benefit, registration, commission offer, Agent Toolkit, booking route, Participating Hotel, landing page, promotional claim or access credential. Senator shall not be required to provide reasons, prior warning or advance notice for exercising any of the rights set out in this clause, except to the extent required by mandatory Applicable Law.

Senator may exercise the rights in this clause for any commercial, operational, technical, regulatory, reputational, strategic, availability, security, fraud-prevention, abuse-prevention, force majeure or other legitimate business reason, including where required to protect the integrity, economics or lawful operation of the Programme.

To the fullest extent permitted by law, the Trade Partner waives and releases any claim against Senator for compensation, indemnity, damages, loss of profit, loss of business, loss of opportunity, reimbursement, reliance loss or other payment arising out of or in connection with any modification, suspension, withdrawal, restriction, interruption, termination or discontinuance of the Programme or any Programme Benefit.

Unless otherwise stated by Senator, Eligible Bookings validly confirmed before the effective date of a change will be assessed under the terms applicable at the time of confirmation, provided that the booking remains an Eligible Booking and has not been cancelled, modified into ineligibility, unpaid, duplicated, fraudulent, abusive, non-traceable or otherwise excluded under the Commission Terms.

1.10 Non-assignment, non-transfer and no subrogation

All registrations, Programme Benefits, commission opportunities, commission claims, prize draw entries, prizes, toolkit access credentials and other rights connected with the Programme are personal to the relevant accepted Trade Partner and are conditional, revocable, non-transferable, non-assignable, non-sub-licensable and non-subrogable.

The Trade Partner shall not assign, transfer, novate, subrogate, delegate, sell, pledge, charge, encumber, licence, sub-license, share, commercialise, pool, syndicate or otherwise make available to any third party any registration, access credential, Programme Benefit, commission entitlement, Prize Draw entry, prize or other right arising under or in connection with the Programme without Senator’s prior written consent.

Any purported assignment, transfer, novation, subrogation, delegation, sale, pledge, charge, licence, sub-license or other disposal in breach of this clause shall be void and of no effect against Senator and may result in immediate suspension or exclusion from the Programme.

1.11 Senator Affiliates and service providers

Senator may administer, operate, fulfil, host, market, support or process the Programme directly or through its Affiliates, hotels, booking engines, technology providers, CRM providers, email service providers, media partners, consultants, professional advisers and other service providers.

The Trade Partner acknowledges that such administration shall not constitute an assignment of any Trade Partner rights and may involve the sharing of data and information as described in the Privacy Notice and as permitted by Applicable Law.

1.12 Agent Toolkit licence

Subject to valid registration and continuing compliance with these Programme Terms, Senator grants the Trade Partner a limited, revocable, non-exclusive, non-transferable, non-sub-licensable licence to access and use the Agent Toolkit solely for the professional promotion of the Participating Hotels to the Trade Partner’s prospective clients in accordance with Senator’s instructions.

The Trade Partner shall not copy, adapt, crop, alter, overprint, remove notices from, combine with misleading claims, resell, sub-license, scrape, upload to unauthorised platforms, use in paid advertising without approval, or otherwise use the Agent Toolkit in any unlawful, misleading, defamatory, infringing, reputationally harmful or unauthorised manner.

Senator may withdraw, replace, update or restrict access to any Agent Toolkit content at any time. Upon request by Senator, the Trade Partner shall promptly cease use of and remove any withdrawn or non-compliant content.

1.13 Brand use, third-party marks and marketing claims

The Trade Partner shall use Senator brands, hotel names, descriptions, images, logos and materials strictly in accordance with the content supplied or approved by Senator. The Trade Partner shall not make any claim about hotel category, rating, adult-only positioning, services, availability, facilities, sustainability, accessibility, luxury positioning, IHG-related references, pricing or guest experience unless such claim is expressly supported by then-current Senator-approved materials.

The Trade Partner is solely responsible for ensuring that its communications to its clients are accurate, fair, lawful, up to date and not misleading. The Trade Partner shall promptly correct or remove any claim or content that Senator reasonably considers inaccurate, outdated, non-compliant or damaging to Senator’s reputation.

1.14 Compliance obligations

The Trade Partner shall comply with all Applicable Law, advertising standards, consumer information obligations applicable to its own client communications, anti-bribery, sanctions, anti-money laundering, data protection, e-privacy and travel trade regulatory requirements in connection with its participation in the Programme.

The Trade Partner shall not use the Programme to promote unlawful, misleading, unauthorised, abusive or reputationally harmful practices, nor shall it make any representation that would impose obligations on Senator beyond the booking terms expressly made available by Senator or the relevant hotel.

1.15 Fraud, misuse, audit and clawback rights

Senator may investigate any suspected fraud, misuse, manipulation, duplicate registration, self-booking abuse, unauthorised transfer, channel abuse, misleading promotion, booking splitting, artificial booking, sham transaction, conflict of interest, breach of law or breach of these Programme Terms.

Pending investigation, Senator may suspend access, withhold commission, delay payment, cancel Prize Draw entries, request documents, reverse or claw back amounts paid in error, exclude the Trade Partner and take any other action reasonably necessary to protect the Programme.

The Trade Partner shall provide reasonable cooperation and documentation requested by Senator to verify eligibility, booking traceability, authority, commissionability and compliance.

1.16 Data protection and electronic marketing

Personal data will be processed in accordance with the Privacy Notice made available on the Programme landing page and with Applicable Law. The Trade Partner shall ensure that any personal data it provides to Senator has been collected and disclosed lawfully and transparently.

Where the Trade Partner elects to receive marketing communications or trade updates, such communications will be sent in accordance with applicable direct marketing rules and the Trade Partner’s preferences. The Trade Partner may unsubscribe or object to direct marketing at any time using the mechanism provided.

1.17 Limitation of liability

Nothing in these Programme Terms excludes or limits any liability that cannot be excluded or limited under mandatory Applicable Law.

Subject to the foregoing, and to the fullest extent permitted by law, Senator shall not be liable for any indirect, consequential, special, punitive or exemplary loss, loss of profit, loss of business, loss of opportunity, loss of goodwill, loss of anticipated savings, loss of data, loss arising from unavailable inventory, third-party booking route decisions, technical interruptions, email delivery failures, landing page downtime, withdrawal of Programme Benefits, or reliance on Programme materials.

The Programme, the Agent Toolkit and all Programme Benefits are provided on a discretionary promotional basis and, except as expressly stated in these Programme Terms, no warranty, representation, guarantee or undertaking is given as to continuity, availability, fitness for a particular purpose, performance, commission generation, booking volumes or commercial results.

1.18 Force majeure and technical failures

Senator shall not be liable for delay, failure, interruption or non-performance caused by events beyond its reasonable control, including technical failures, cyber incidents, acts or omissions of third-party providers, booking engine downtime, network failure, regulatory intervention, force majeure, labour disruption, public authority measures, hotel closure, overbooking, safety incidents or other circumstances affecting the operation of the Programme.

1.19 Assignment by Senator

Senator may assign, transfer, novate, subcontract or otherwise deal with its rights and obligations under the Programme to any Affiliate, successor, purchaser of assets, hotel operator, service provider or other third party involved in the operation or reorganisation of the Programme, provided that such arrangement is made in accordance with Applicable Law.

1.20 Notices and communications

Senator may provide Programme notices by email, through the landing page, through the booking platform, within the Agent Toolkit or by any other reasonable electronic means. Notices shall be deemed received when made available or sent to the contact details provided by the Trade Partner, unless delivery failure is notified to Senator.

1.21 Entire agreement, severance and no waiver

These Programme Terms, together with the Commission Terms, the Prize Draw Terms where applicable, the Privacy Notice and any expressly incorporated Programme rules, constitute the entire agreement between Senator and the Trade Partner in relation to the Programme and supersede any prior statements, proposals, drafts, emails, presentations or marketing materials, except where expressly incorporated in writing by Senator.

If any provision of these Programme Terms is held to be invalid, unlawful or unenforceable, it shall be deemed modified to the minimum extent necessary to make it valid, lawful and enforceable. If modification is not possible, the relevant provision shall be deemed deleted and the remaining provisions shall continue in full force and effect.

No failure or delay by Senator in exercising any right or remedy shall constitute a waiver of that or any other right or remedy.

1.22 Third-party rights

Except for Senator Affiliates and service providers who may enforce provisions intended for their benefit, no person other than Senator and the relevant Trade Partner shall have any right to enforce these Programme Terms, whether under the Contracts (Rights of Third Parties) Act 1999, any equivalent third-party beneficiary doctrine or otherwise, to the fullest extent permitted by Applicable Law.

1.23 Language, governing law and jurisdiction

These Programme Terms are made available in English for use in the UK travel trade context. If a Spanish version is prepared for reference or interpretative purposes, the English version shall prevail for the Programme-facing materials unless Senator expressly states otherwise.

These Programme Terms and any dispute or non-contractual obligation arising out of or in connection with them, the Programme or any Programme Benefit shall be governed by and construed in accordance with the laws of Spain, without prejudice to any mandatory laws, data protection rules, electronic marketing rules or advertising standards that may apply in the United Kingdom and cannot be excluded.

Subject to any mandatory jurisdiction rules that cannot be excluded, the courts of Almería, Spain, shall have exclusive jurisdiction to settle any dispute arising out of or in connection with these Programme Terms, the Programme or any Programme Benefit.

2. Commission Terms

These Commission Terms form part of the Programme Terms and apply to commission opportunities offered by Senator under the Programme. They are to be read together with the Programme Terms. Capitalised terms have the meaning given in the Programme Terms unless defined differently below.

2.1 Commission offer

Subject to these Commission Terms, Senator may make available to accepted Trade Partners a welcome commission of 17% on Eligible Bookings made and confirmed through Senator Pro+ after valid Programme registration and no later than 23:59 UK time on 30 September 2026 (the “Welcome Commission Period”). From 00:00 UK time on 1 October 2026, the standard Programme commission shall be 15%, unless Senator expressly notifies different terms in writing.

The commission offer is promotional, discretionary, conditional and non-retroactive. It does not create any entitlement to future commission rates, minimum volumes, ongoing participation, exclusivity, renewal, compensation or continued access to any booking route. Senator may amend, suspend, pause, withdraw or terminate the Programme, the Welcome Commission Period or any commission offer for future bookings at any time, with or without prior notice and without liability, in accordance with the Programme Terms.

2.2 Eligible Booking

An “Eligible Booking” means a booking that satisfies all of the following conditions:

• the booking is made and confirmed by an accepted Trade Partner after valid Programme registration and acceptance of the applicable terms;
• the booking is made and confirmed during the applicable commission period exclusively through the Senator Pro+ direct trade booking channel, or any other direct booking route expressly recognised in writing by Senator as commissionable for the Programme;
• the booking relates to a Participating Hotel within Senator’s hotel collection made available through Senator Pro+ and to an eligible rate plan, room type and booking window;
• the booking is properly traceable to the Trade Partner in Senator’s booking systems or records;
• the guest completes the stay and the applicable tariff charges are paid in full and irrevocably received by Senator or the relevant hotel, or, in the case of a cancellation or no-show, the applicable cancellation or no-show charge forming part of the Pro+ tariff is charged and irrevocably received by Senator or the relevant hotel;
• the booking is not unpaid, fraudulent, duplicated, disputed, refunded, chargebacked, modified into ineligibility, cancelled or no-showed without a commissionable cancellation or no-show charge, or otherwise excluded under these Commission Terms; and
• the Trade Partner remains in good standing and compliant with the Programme Terms at the time the commission is assessed and paid.

2.3 Excluded bookings

Unless Senator expressly agrees otherwise in writing, the following bookings shall not be Eligible Bookings and shall not accrue commission under the Programme:

• bookings made, quoted, held, originated or confirmed before valid Programme registration;
• bookings made through any channel other than Senator Pro+ or another direct booking route expressly recognised in writing by Senator as commissionable for the Programme;
• bookings made through OTAs, wholesalers, tour operators, bedbanks, net rate arrangements, corporate agreements, opaque channels, selected trusted partners or any other third-party channel, whether or not such channel is referred to in any marketing material as an available booking option;
• group bookings, MICE bookings, contracted allotments, crew bookings, staff/family rates, complimentary stays, barter arrangements, house use, voucher stays, rewards, discounted internal rates or special negotiated rates unless expressly included by Senator and processed as commissionable through Senator Pro+;
• bookings that cannot be reliably attributed to the Trade Partner in Senator’s records;
• bookings resulting from fraud, manipulation, self-booking abuse, duplicate registration, booking splitting, artificial booking patterns or unauthorised transfer of Programme Benefits;
• bookings cancelled or no-showed without a commissionable cancellation or no-show charge, or bookings that are unpaid, refunded, charged back, disputed or amended into a non-eligible rate or channel.

2.4 Commissionable tariff amount

Commission shall be calculated only on Commissionable Pro+ Tariff Amount actually received by Senator or the relevant hotel for the Eligible Booking, unless Senator expressly confirms another basis in writing.

“Commissionable Pro+ Tariff Amount” means the tariff amount actually charged and irrevocably received for the Eligible Booking through Senator Pro+, including the room rate, VAT where included in the tariff, food and beverage or board basis included in the stay rate, and cancellation or no-show charges where such charges form part of the Pro+ tariff and are actually charged and received. Unless expressly included in the Pro+ tariff and recognised by Senator as commissionable, Commissionable Pro+ Tariff Amount excludes parking, transfers, pets, spa, insurance, tourist tax, city tax, third-party charges, payment fees, service charges, refunds, discounts, chargebacks and any other item not included in the Pro+ tariff or not capable of being booked through Senator Pro+.

2.5 Accrual, invoicing and payment

Commission shall accrue only after the guest has completed the stay and the relevant Pro+ tariff charges have been paid in full, or, in the case of a cancellation or no-show, after the applicable commissionable cancellation or no-show charge has been paid in full, and in each case only once the booking has been validated by Senator as an Eligible Booking. No commission is earned merely by making a reservation, generating a lead, registering interest, sending an enquiry or accessing the Agent Toolkit.

Payment timing, invoicing requirements, currency, VAT/tax treatment, payment method and supporting documentation shall be as notified by Senator from time to time or as set out in the booking platform. Senator may withhold payment until the Trade Partner has provided all information reasonably required for payment, tax, compliance and anti-fraud purposes.

2.6 Amendments, cancellations and clawback

If an Eligible Booking is refunded, reduced, disputed, charged back, unpaid, amended or otherwise ceases to meet the eligibility criteria, or if a cancellation or no-show does not result in a commissionable cancellation or no-show charge actually received by Senator or the relevant hotel, Senator may cancel, reduce, reverse or claw back the relevant commission, whether before or after payment.

Senator may set off or deduct overpaid, erroneous, reversed or clawed-back commissions against any amounts that may otherwise become payable to the Trade Partner under the Programme, to the extent permitted by Applicable Law.

2.7 Commission disputes

Any commission query must be submitted in writing to the contact point notified by Senator within the query period specified in the relevant commission statement or, if no such period is specified, within 30 days after the date on which the relevant commission statement or payment was made available. The Trade Partner must provide booking references, guest stay details, booking route information and any other documentation reasonably required by Senator.

Commission not queried within the applicable period shall be deemed accepted, except in the case of manifest error or fraud. Senator’s booking records shall be conclusive evidence of booking eligibility and commission calculation in the absence of manifest error.

2.8 Taxes and compliance

The Trade Partner is responsible for all taxes, filings, declarations, invoices, permits and regulatory obligations arising from the receipt of commission. Senator may deduct or withhold any taxes, charges or amounts required by Applicable Law and may request valid invoices, tax residency information or other compliance documentation before payment.

2.9 Changes to commission rates

Senator may amend commission rates, eligibility criteria, excluded channels, Participating Hotels and commission periods, and may pause, suspend or withdraw the Programme or any commission offer, for future bookings at any time, with or without prior notice and without liability, in accordance with the Programme Terms. Unless Senator expressly states otherwise, changes shall not affect Eligible Bookings validly confirmed before the effective date of the change, provided that such bookings remain fully eligible under these Commission Terms.

3. Prize Draw Terms

These Prize Draw Terms apply to the free prize draw associated with the Programme. The prize draw is operated as a no-purchase-required promotional prize draw for UK travel trade professionals.

3.1 Promoter

The promoter of the prize draw is GRUPO HOTELES PLAYA, S.A., a company limited by shares (sociedad anónima) incorporated under the laws of Spain, with Spanish Tax Identification Number (C.I.F.) A04108973, having its registered office at Ctra. Faro Sabinal, No. 341 – Edificio Playa Hoteles, 04740 Roquetas de Mar (Almería), Spain, and registered with the Commercial Registry of Almería under Volume 204, Folio 212, Section 3, Sheet 3018, Entry 1 (the “Promoter”).

3.2 Eligibility

The prize draw is open to professional UK travel trade representatives aged 18 or over who validly register for the Programme during the Promotional Period and satisfy the eligibility requirements set out in the Programme Terms.

Employees, officers, directors, contractors and representatives of the Promoter, its Affiliates, participating hotels, campaign providers, advertising agencies and their immediate family members are not eligible to enter.

3.3 No purchase necessary

No purchase, booking, payment or paid transaction is necessary to enter or win. A booking will not increase the chances of winning.

3.4 Promotional Period

The prize draw opens and closes on the dates and times, and in the time zone, stated on the Programme landing page or in the relevant prize draw communication (the “Promotional Period”). Entries received before or after the Promotional Period will not be valid.

3.5 How to enter

To enter, eligible participants must complete and submit the Programme registration form during the Promotional Period and accept these Prize Draw Terms. Only one entry per eligible person and/or agency is permitted unless the Promoter expressly states otherwise. Automated, bulk, third-party, incomplete, duplicated, fraudulent or misdirected entries will be void.

3.6 Prize

The prize is one seven-night hosted stay at Senator Banús for the number of guests, and with the room type and board basis, stated on the Programme landing page or in the relevant prize draw communication, subject to availability, blackout dates and the hotel’s booking conditions.

Unless expressly included above, the prize excludes flights, transfers, transport, insurance, visas, meals, drinks, spa treatments, extras, upgrades, taxes, personal expenses, incidental charges and any other costs. The winner and guest are responsible for all excluded costs and for ensuring they can travel and comply with any applicable travel requirements. The winner is responsible for any taxes, charges or reporting obligations arising from acceptance or use of the prize, except to the extent that Applicable Law requires the Promoter to withhold, report or account for any amount.

3.7 Winner selection

The winner will be selected at random from all valid entries received during the Promotional Period, using a verifiably random computer process or, where required by applicable advertising standards, by an independent person or under the supervision of an independent person, on or around the date stated on the Programme landing page or in the relevant prize draw communication.

3.8 Winner notification and forfeiture

The winner will be notified using the contact details supplied at registration. If the winner does not respond within the timeframe stated in the winner notification, is not eligible, fails to provide required verification, declines the prize or cannot accept the prize, the Promoter may withdraw the prize and select an alternative winner at random from the remaining valid entries.

3.9 Non-transferability and substitution

The prize is personal to the winner, non-transferable, non-exchangeable, non-refundable and has no cash alternative. The prize may not be sold, assigned, auctioned, transferred, substituted or otherwise commercialised.

The Promoter reserves the right to substitute the prize with a prize of equal or greater value where necessary due to circumstances beyond its reasonable control or where the advertised prize becomes unavailable.

3.10 Booking and stay conditions

The stay must be booked and completed by the deadline stated on the Programme landing page, in the relevant prize draw communication or in the winner notification. Dates are subject to availability and may be subject to blackout dates, minimum stay restrictions, hotel closure periods, operational requirements and other hotel conditions. The winner and guest must comply with the hotel’s usual guest rules and policies.

3.11 Disqualification

The Promoter may disqualify any participant who breaches these Prize Draw Terms, breaches the Programme Terms, tampers with the entry process, provides false information, acts fraudulently, behaves abusively or otherwise undermines the fair operation or reputation of the prize draw.

3.12 Publicity and winner information

The Promoter may be required to make limited winner information available where required by applicable advertising standards or law, unless the winner objects on valid grounds. Any publicity use beyond what is legally required will be subject to the winner’s consent where required by law.

3.13 Data protection

Personal data will be processed for administering the prize draw, verifying eligibility, contacting the winner, awarding the prize, complying with legal obligations, maintaining records and, where applicable, sending marketing communications in accordance with the Privacy Notice and the participant’s preferences.

3.14 Changes, suspension and cancellation

The Promoter will not materially change the Prize Draw Terms during the Promotional Period unless the change is necessary due to circumstances that are genuinely unexpected and outside the Promoter’s reasonable control, or where required by law, a regulator, a competent authority or to ensure the lawful and fair operation of the prize draw.

The Promoter may suspend, cancel or amend the prize draw where necessary due to fraud, technical failure, force majeure, legal restriction, regulatory concern or circumstances beyond its reasonable control.

3.15 Governing law

These Prize Draw Terms and any non-contractual obligations arising out of or in connection with them shall be governed by and construed in accordance with the laws of Spain, without prejudice to any mandatory laws or advertising standards that may apply in the United Kingdom and cannot be excluded.

4. Short Privacy Notice for Landing Page

Controller: GRUPO HOTELES PLAYA, S.A., with Spanish Tax Identification Number (C.I.F.) A04108973 and registered office at Ctra. Faro Sabinal, No. 341 – Edificio Playa Hoteles, 04740 Roquetas de Mar (Almería), Spain, is the controller of the personal data collected through this UK Trade Programme landing page.

Purposes: We will process your professional contact details and registration information to manage your Programme registration, verify eligibility, provide access to the Agent Toolkit, administer commissions and booking enquiries, manage the Prize Draw where applicable, respond to requests, maintain records of acceptance, prevent fraud or misuse, comply with legal obligations and, where permitted, send trade communications and marketing updates.

Lawful bases: Depending on the activity, we rely on contract or steps prior to contract, legitimate interests in managing a B2B trade programme and promoting our hotels to professional travel partners, compliance with legal obligations, and consent where required for optional marketing communications or specific processing.

Data categories: name, agency, role, professional email address, telephone number, country, booking/channel preferences, hotels of interest, registration timestamp, acceptance logs, technical identifiers, communications and Prize Draw information.

Recipients: your data may be shared with Senator Affiliates, participating hotels, technology providers, CRM providers, email service providers, booking engine providers, campaign partners and professional advisers where necessary for the purposes described above. We do not sell your personal data.

International transfers: where personal data is transferred between the UK, the EEA (including Spain) or other countries, we will rely on applicable adequacy decisions or appropriate safeguards where required by Applicable Law.

Retention: we will retain your data for as long as necessary to manage the Programme, maintain commercial records, deal with claims, comply with legal obligations and respect your marketing preferences. Specific retention periods may vary depending on the data and purpose.

Your rights: you may request access, rectification, erasure, restriction, portability and objection, and you may withdraw consent where processing is based on consent. You may object to direct marketing at any time.

Contact: responsable.lopd@playasenator.com. Full Privacy Policy: available through the link provided on the Programme landing page.