GALA EUROPE INVESTMENTS S.L.U., with tax identification number B-88388335 and AZZAM VIVIENDA S.L.U., with tax identification number B-31347602 (hereinafter jointly referred to as THE ENTITY) make this Privacy Policy available to you, in order to provide information about how we process your personal data and protect your privacy and information.
THE ENTITY requests that users spend a few minutes carefully reading this Privacy Policy.
Introduction.
This Privacy Policy applies to your interactions with THE ENTITY. THE ENTITY may modify this Privacy Policy when necessary. In the event of changes, we will inform you so that you can be aware of the new Privacy conditions and, in those cases in which it is necessary, we will request your express consent.
Who is the controller for the processing of your personal data?
The controller for the processing of your personal data are GALA EUROPE INVESTMENTS S.L.U., with tax identification number B-88388335 and AZZAM VIVIENDA S.L.U., with tax identification number B-31347602. The address for notification purposes is in calle Gregorio Benítez n.º 3, Edificio B, Planta 2, C.P. 28043 Madrid (Spain)
Hereinafter jointly referred to as THE ENTITY.
To guarantee proper management of the processing of your data, THE ENTITY has appointed a Data Protection Officer, whom you may address for any questions you may have and who can be contacted at the email address privacy@12miles-rentalhomes.com.
What data are processed by the entity and what are their sources?
The data processed by THE ENTITY as a result of the interactions carried out come from the following sources:
• Data provided by you through the completion of the forms made available by THE ENTITY, digital or not, own or third parties, to manage communication with users; by collecting personal data in a phone call made to THE ENTITY, or by any other means by which you enter into communication with THE ENTITY.
• Data generated as a result of the development, processing and maintenance of the relationship between the user and THE ENTITY.
THE ENTITY may process personal data of the following types, depending on the relationship established with you:
• Identification and contact data (e.g., name and surname, email, postal address, telephone, ID card, etc.).
• Data on personal characteristics and social circumstances associated with your preferences and interests in one or more of the properties marketed by THE ENTITY (e.g., preferences about the environment, tastes and hobbies, family characteristics, preferred type of housing, etc.).
• Other types of data. Exclusively if the user provides other types of data in interactions with THE ENTITY, such data will be processed by THE ENTITY only if their processing is necessary for the purpose pursued. Otherwise, the data will be destroyed without having been previously stored or processed by THE ENTITY.
What is the purpose of processing your personal data?
The personal data provided by you may be processed by THE ENTITY for the following purposes, depending on the interactions that the user enters into with THE ENTITY:
• Contacting, managing and processing enquiries and requests from users: The personal data of users who contact THE ENTITY through any of the contact channels made available by THE ENTITY in order to receive queries and/or requests from users will be processed to maintain contact between the parties, providing the information required by users, providing customer service and managing and processing requests or queries made by the user through the channels provided for this purpose by THE ENTITY.
Commercial, promotional or advertising communications: Users’ personal data may be processed by THE ENTITY for the purpose of sending them personalised commercial and advertising information about activities, products, services, offers, special promotions, as well as documentation of various kinds, by post, telephone or electronic means (e-mail, SMS, messaging and other means of electronic communication).
The information to be sent may be related to THE ENTITY and/or other entities in the real estate sector. The information may also be sent on the basis of an analysis and evaluation of your profile, which will be based on internal data held by THE ENTITY. This is only if you have given your express consent.
The ENTITY informs you that, in order to optimize and improve the sending of information that it carries out, as well as to offer you personalized information according to your characteristics and/or needs, it may perform automatic analysis and evaluation of profiles and apply segmentation techniques, exclusively with internal data held by the ENTITY, prior to sending advertising and commercial communications.
You may object at any time to the processing of your data for advertising or promotional purposes by THE ENTITY using the channels provided by THE ENTITY, as detailed later in this document.
• Satisfaction surveys: The personal data of customers may be processed by THE ENTITY to conduct periodic surveys, both by telephone and electronic means, to ascertain the degree of satisfaction and preferences of users and customers with THE ENTITY, their housing and the attention received by the staff or collaborators of THE ENTITY. The answers provided by the customer in the survey are completely anonymous, so that the information provided by you cannot be linked to your person.
What is the legal basis for the processing of your data by THE ENTITY?
THE ENTITY processes your personal data in accordance with the following legal bases:
• The processing of your data for the purpose of “Contacting, managing and processing enquiries and requests from users” is based on their need to perform a contract to which the data subject is a party or for the application at his request of pre-contractual measures; that is, in the management of his own request, in maintaining contact between the parties and, where appropriate, in the provision of the service that the user had requested.
• The processing of your data for the purpose of “commercial, promotional or advertising communications” is based on the express consent of the user.
• The processing of your data for the purpose of “Satisfaction surveys” has its legal basis in the legitimate interest of THE ENTITY to know the opinion and preferences of users and customers in relation to THE ENTITY, their rented housing and the customer services provided in order to solve the problems identified and improve current processes.
THE ENTITY informs that it will only process personal data for the purposes of processing based on the user’s consent in cases where the user has consented to each of the processing operations.
To whom is your data communicated?
THE ENTITY informs users that the processing purposes detailed in this Privacy Policy involve the following communications of their data by THE ENTITY to third entities.
THE ENTITY informs you that your data may be communicated, where appropriate, to Public Bodies, State Security Forces or Courts and Tribunals, under the terms established in current legislation, exclusively in the event that such communication of data is necessary and/or in compliance with legal obligations.
Personal data may also be disclosed to third parties who perform functions in THE ENTITY such as, among others, management, control, document management, monitoring of regulatory compliance or auditing, for the provision of services required by current regulations.
How long do we keep your data?
THE ENTITY will keep your personal data for the time necessary to provide the requested service and/or to achieve the intended purpose of processing.
Subsequently, provided that the user has not exercised their right to erasure, your data will be kept for the legal periods that apply in each case, taking into account the type of data and the purpose of processing.
In any case, the user may request detailed information on the data retention periods applied in THE ENTITY by contacting our Data Protection Officer.
What personal data must be provided in each case?
THE ENTITY informs users that, when personal data are collected through a form made available to users, it will be necessary for the user to provide at least the data that are indicated as mandatory in the form in question by legal or contractual requirement. If such data, considered necessary, is not provided, THE ENTITY will not be able to manage the service, or the query made by the user.
What should you guarantee when providing your personal data?
By providing your data to THE ENTITY, you declare and guarantee that you are over 18 years of age, and that you are fully responsible for this declaration.
You guarantee that the data you provide is true, accurate, complete and up to date, being responsible for any damage or loss, direct or indirect, that may arise as a result of a breach of this obligation.
In the event that the user provides data belonging to a third party, he/she guarantees that he/she has informed said third party of all the aspects contained in this Privacy Policy and that he/she has obtained their consent to provide us with their data for the purpose of the processing in question. All this, prior to the provision of data of a third party through the communication channels enabled by THE ENTITY.
What measures do we take to protect your personal data?
THE ENTITY guarantees the security and confidentiality of your data at all times. THE ENTITY has adopted the security levels required by current legislation for the protection of personal data and has installed the necessary technical and organizational means to prevent the loss, misuse, alteration, unauthorized access and theft of personal data provided.
¿Cuáles son sus derechos sobre sus datos personales?
THE ENTITY informs you that you have the following rights over your personal data:
• Right of access. You have the right to obtain confirmation as to whether or not THE ENTITY is processing personal data concerning you, and the right to access your personal data.
• Right to rectification. You have the right to obtain without undue delay from THE ENTITY the rectification of inaccurate personal data concerning you.
• Right to erasure. In certain circumstances, you have the right to request the deletion of your data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
• Right to restrict processing. In certain circumstances, you have the right to ask THE ENTITY to limit the processing of your data, in which case we inform you that only the data for which you have requested limitation of processing for the exercise or defence of claims will be retained.
• Right to data portability. In certain circumstances, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, as well as to have it transferred by THE ENTITY to another data controller.
• Right to object. In certain circumstances and for reasons relating to your particular situation, you have the right to object to the processing of your data, in which case we will stop processing it unless we have to continue to do so for compelling legitimate reasons or for the exercise or defence of any claims.
• Right to withdraw consent. We remind you that you have the right to object to the processing of your data for commercial or advertising purposes, as well as to withdraw any consent you may have given for the processing of your data, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.
• Automated individual decisions. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you or similarly significantly affects you.
THE ENTITY informs you that you may exercise your rights over your personal data by writing to THE ENTITY, identified with the reference “Data Protection” and accompanied by your ID card or equivalent document on both sides, which may be sent to one of the following addresses: calle Gregorio Benítez n.º 3, Edificio B, Planta 2, C.P. 28043 Madrid or to the e-mail address privacy@12miles-rentalhomes.com.
THE ENTITY will provide the requested information within a maximum period of one month from receipt of the request. This period may be extended for a further two months if necessary, taking into account the complexity and number of requests.
THE ENTITY informs you that you may lodge a complaint with the competent supervisory authority for data protection (Spanish Data Protection Agency). However, in the first instance, you may file a complaint with the Data Protection Officer, who will resolve the complaint within a maximum period of two months.
