Privacy Policy

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 COMPANY) provide you with this Privacy Policy in order to provide you with information about how we process your personal data and protect your privacy and information. THE COMPANY requests that you take a few minutes to read this Privacy Policy carefully. This Privacy Policy applies to your interactions with THE COMPANY. THE COMPANY may change this Privacy Policy from time to time. In the event of changes, we will inform you so that you can be aware of the new Privacy Policy and, in those cases where it is necessary, we will request your express consent.

Who is responsible for the processing of your personal data?
The parties responsible for the processing of 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 (hereinafter jointly referred to as THE COMPANY), both with registered offices at calle Gregorio Benítez n.º 3, Edificio B, Planta 2, C.P. 28043 Madrid.

To ensure the proper management in the processing of your data, THE COMPANY has designated a Data Protection Officer, to whom you can contact for any questions you may have and who can be reached at privacy@12miles-rentalhomes.com.

What data is processed by THE COMPANY and from what sources does it come?
The data processed by THE COMPANY as a result of the interactions carried out come from the following sources:

– Data provided by you as a result of the management, processing and development of the contractual relationship, either by legal requirement or necessary for the formalisation of the contract.
– Data provided by you through the completion of forms made available by THE COMPANY, digital or not, own or third parties, to manage the relationship between the parties; by collecting personal data in telephone calls made to THE COMPANY, or by any other means by which you enter into communication with THE COMPANY.
– Data generated as a result of the development, processing and maintenance of the contractual relationship between you and THE COMPANY.
– Data on energy consumption related to the supply point of the rented property provided by the distribution companies.
– Data on solvency and creditworthiness, provided by third party credit information file registration entities.
– Information from official sources and registers on possible criminal activities within the framework of compliance with the regulations for the prevention of money laundering and the financing of terrorism.

THE COMPANY may process personal data of the following types, depending on the relationship established with you:

– Identification and contact data (e.g. name and surname, e-mail address, postal address, telephone number, DNI/NIE, etc.).
– Data on personal characteristics and social circumstances (e.g. date of birth, marital status, property regime, number of family members, etc.).
– Employment details (e.g. profession, employment status, pay slips, etc.).
– Economic, financial and insurance data (e.g. bank account number, credit card number, etc.).
– Special categories of data (e.g. degree of disability).
– Energy consumption data, in an aggregated and anonymised form, relating to the supply point of the rented dwelling.
– Data relating to financial solvency and creditworthiness (e.g., files and/or registers of financial solvency and/or financial solvency relating to the fulfilment and non-fulfilment of monetary obligations).
– Information and documentation on their economic activity and the origin of their funds in order to comply with the regulations on the prevention of money laundering and the financing of terrorism.
– Other types of data. Exclusively in the event that the client provides other types of data in interactions with THE COMPANY (reason for the interaction, preferences, interests, etc.) such data will be processed by THE COMPANY 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 COMPANY.

In relation to personal characteristics data, the information you provide may include your marital status, number of children, etc. and personal information about your family members that THE COMPANY will process due to legal or contractual obligations (e.g., by identifying them as co-owners of the contract). In this regard, THE COMPANY informs you that it will process the data of these third parties that you provide for the purpose of carrying out the activities necessary to enable the legal relationship between you and THE COMPANY.

You warrant that you have obtained the consent of those third parties (e.g. co-owners) from whom you communicate personal data to us, for such communication of data to THE COMPANY, to carry out the processing of data necessary for the performance of the activities of the contract management requested, as well as having informed such third parties of the purposes of data processing and of their rights under this clause.

In relation to the special categories of data, we inform you that we will only request and process such data in the event that their processing is essential in the context of the formalisation of the contract between you and THE COMPANY, and that we will adopt appropriate measures (technical, legal and organisational) to ensure the security and confidentiality of the processing of such data.

For what purposes do we process your personal data?
The personal data provided by you may be processed by THE COMPANY for the following purposes, depending on the interactions that the customer enters into with THE COMPANY:

1. Contacting, managing and processing customer enquiries and requests: The personal data of customers who contact THE COMPANY through any of the contact channels made available by THE COMPANY for the purpose of receiving queries and/or requests from customers will be processed for the purposes of maintaining contact between the parties, providing the required information, providing customer services and managing and processing requests or queries made by the customer through the channels made available by THE COMPANY for the purpose of receiving queries and/or requests from customers, and for the purposes of maintaining contact between the parties, providing the required information, providing customer services and managing and processing requests or queries made by the customer through the channels made available by THE COMPANY for the purpose of receiving queries and/or requests from customers.
through the channels provided for this purpose by THE COMPANY.

2. Management of data derived from the contractual relationship between THE COMPANY and the client: THE COMPANY will collect certain personal data from the customer as a
as a result of the contractual relationship (reservation contract, rental contract or purchase contract) between you and THE ENTITY.

During the booking process, THE COMPANY will carry out activities aimed at knowing your creditworthiness and credit (assessment of your profile) in order to assess your suitability as a lessee or buyer. In addition, when required by current legislation or internal procedures of THE COMPANY, your information and documentation will be analysed to comply with the regulations for the prevention of money laundering and terrorist financing. In this way, your data will be processed to enable compliance with the legal and contractual obligations that correspond to THE COMPANY and to manage the collections and economic transactions that may arise from the relationship.

Specifically, the data necessary for the management of direct debit orders for SEPA CORE direct debits will be processed for the purpose of managing the direct debit of recurring or one-off direct debits and communicating them to the bank responsible for managing the direct debits. In the same way, THE COMPANY may also request information required by the Public Administrations in relation to specific types of housing.

Once the contract has been signed, THE COMPANY will provide its customers with the digital means necessary to manage their own personal data. THE COMPANY will process such personal data in order to carry out the administrative or operational procedures necessary for the formalization or management of the contract (e.g., examination of the documentation provided by the customer, rectifications of data requested by customers, etc.).

The customer can view on the website provided by THE COMPANY relevant information relating to the contractual relationship with THE COMPANY (e.g., whether the contract is in force, the property, etc.).
contract is in force, the property to which it refers, etc.). The personal data contained in this space will be processed by THE COMPANY for the sole purpose of providing such information to customers.
information to customers.

In addition, your data may be processed to evaluate certain personal aspects of a natural person, in particular to analyse or predict aspects relating to the professional performance, financial situation, personal preferences, interests, reliability, behaviour, location or movements of that natural person. No automated individual decisions will be taken on the basis of this data processing.

Finally, THE COMPANY may process your data for the purpose of conflict resolution, as a result of the contractual relationship, in cases where a situation of special vulnerability of the client and/or the occupants of the property is detected, and may be transferred or transferred to public bodies and/or public service entities competent in matters of social policy, in case their action is necessary, and in the event that it is strictly necessary.

3. Commercial, promotional or advertising communications: The personal data of customers may be processed by THE COMPANY in order to send 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 (email, SMS, messaging and other means of electronic communication), even after the contractual relationship has ended.

The information to be sent may relate to THE COMPANY and/or other entities. The information may also be sent on the basis of an analysis and evaluation of your profile, which
will be made on the basis of internal data held by THE COMPANY. THE COMPANY informs you that such third party entities with which it enters into collaboration agreements may belong, among others, to the sectors of insurance, credit, energy, electricity, gas, telecommunications services, security, cleaning, administrative activities and auxiliary services, recreational and entertainment activities, sport, leisure, culture and shows. All this, exclusively, if you have given your express consent.

The COMPANY informs you that, in order to optimize and improve the information it sends, 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 that THE COMPANY has, 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 COMPANY using the channels provided by THE COMPANY, as detailed later in this document.

4. Satisfaction surveys: The personal data of customers may be processed by THE COMPANY to conduct periodic surveys, both by telephone and electronic means, to determine the degree of satisfaction and preferences of users and customers with THE COMPANY, their housing and the attention received by the staff or collaborators of THE COMPANY. 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.

THE COMPANY informs that it will only process personal data for the purposes of processing based on the customer’s consent in cases where the customer has consented to each of the processing operations.

To whom is your data communicated?
The personal data processed by THE COMPANY to achieve the purposes detailed above may be communicated to the following recipients depending on the legitimate basis for the communication. THE COMPANY informs you that your data may be communicated, where appropriate, to:

1. Public Bodies, Public Administrations, State Security Bodies and Forces or Courts and Tribunals, under the terms established in the current regulations, exclusively in the event that such communication of data is necessary and/or in compliance with legal obligations arising from claims, preliminary proceedings or any administrative or judicial procedure.

2. Public bodies and administrations, in compliance with legal obligations under current legislation, in order to verify compliance with administrative requirements (subsidised housing) or to carry out the corresponding tax declarations, among others.

3. Agencies and Public Administrations competent in matters of social policy, for the purpose of conflict resolution, and if strictly necessary, when situations of special social vulnerability of tenants and/or occupants of the dwellings are detected or there are indications of such situations.

4. Banking and financial institutions to enable the management of collections and economic transactions derived from the contractual relationship. Where applicable, banking entities with which a mortgage is constituted on the property in which the leased property is located, exclusively in the event that it is necessary for the financial entity to process the data of the lessees in order to know the leasing situation of the property prior to the constitution of guarantees.

5. Third parties that exercise functions in THE COMPANY, including, among others, management, control, document management, monitoring of regulatory compliance or auditing, for the provision of services required by current regulations.

6. Third parties contracted by THE COMPANY to provide services that you proactively request related to possible incidents in the home, as well as the necessary actions for the management, monitoring and administration of contracts.

7. Third party entities, for commercial purposes, with which collaboration agreements are entered into in the sectors of insurance, credit, energy, electricity, gas, telecommunications services, security, administrative activities and auxiliary services, recreational and entertainment activities, sport, leisure, culture and shows. These communications will only be made if you have expressly authorised commercial, promotional or advertising communications.

8. Insurance companies providing coverage services for non-payment of rent, with which THE COMPANY maintains a formal insurance relationship at all times, such communication being necessary to enable the insurance coverage in question and, consequently, in execution of the established contractual relationship.

9. Where applicable, the Community of Owners of the property in which the rented or acquired home is located, in order to allow the correct development of the operations of the community and the development of the functions entrusted to it, as well as, in If applicable, the invoicing by the Community of Owners of the corresponding amounts.

10. Common asset solvency files related to compliance and non-compliance with monetary obligations. In the event of non-payment of the monthly rent receipt and other similar amounts (common expenses and taxes), as well as any other monetary obligation derived from this contract, in the terms provided for in the contract that you formalize with THE ENTITY , and provided that the requirements established in current regulations regarding the protection of personal data are met (existence of a liquid, overdue, enforceable debt), the data related to non-payments may be communicated to common solvency files, related to compliance. or breach of monetary obligations.

How long do we keep your data?
THE ENTITY will keep your personal data as long as the contractual relationship between the parties is maintained and/or to achieve the intended processing purpose. Subsequently, as long as the client has not exercised their right to deletion, their data will be kept for the legal periods that apply in each case, taking into account the type of data, as well as the purpose of the processing.

In any case, the client can request detailed information about the data retention periods applied in THE ENTITY by contacting our Data Protection Officer.

What personal data must you provide us in each case?
THE ENTITY informs clients that, when personal data is collected through a form made available to them, it will be necessary for the client to provide, at least, the data that is 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 client.

What must you guarantee us when providing your personal data?
You, by providing your data to THE ENTITY, declare and guarantee that you are over 18 years of age, taking full responsibility for such declaration. You guarantee that the data you provide is true, accurate, complete and up-to-date, and you are responsible for any direct or indirect damage or loss that may arise as a result of failure to comply with such obligation.

In the event that the client provides data belonging to a co-owner of the contract or third parties, he guarantees that he has informed said persons of all the aspects contained in this Privacy Policy and that he has obtained their consent to provide us with their data for the processing purpose in question. All of this, prior to the provision of data from a third party through the communication channels enabled by THE ENTITY.

What measures do we take to protect your personal data?
THE ENTITY guarantees at all times the security and confidentiality of your data. THE ENTITY has adopted the security levels required by current regulations for the
protection of personal data and the necessary technical and organizational means have been installed to prevent loss, misuse, alteration, unauthorized access and theft of data personnel provided.

What are your rights over your personal data?
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 THE ENTITY is processing personal data that concerns you or not, 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 that concerns you.
• Right of deletion. In certain circumstances, you have the right to request the deletion of your data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
• Right to limitation of treatment. In certain circumstances, you will have the right to request THE ENTITY to limit the processing of your data, in which case we inform you that only the data on which you have requested limitation in processing for the exercise or defense of claims will be kept.
• Right to data portability. In certain circumstances, you will have the right to receive the personal data that concerns you, and that you have provided to us, in a structured format for common use and machine reading, as well as to have it transmitted by THE ENTITY to another person responsible for the treatment.
• Right to object. In certain circumstances and for reasons related to your particular situation, you will have the right to object to the processing of your data, in which case
We would stop processing them unless we must continue to do so for compelling legitimate reasons or for the exercise or defense of possible claims.
• Right to withdraw consent. We remind you that you have the right to oppose the processing of your data for commercial or advertising purposes, as well as to withdraw any of the consents you have given for the processing of your data, without affecting the legality of the processing based on prior consent. upon his withdrawal.
• Automated individual decisions. You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects 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” which you may send to one of the following addresses: Gregorio Benítez Street, number 3, Building B, Floor 2, C.P. 28043, Madrid or to the email 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 another two months if necessary.
necessary, taking into account the complexity and number of requests.

THE ENTITY informs you that you may file a claim with the competent supervisory authority in matters of data protection (Spanish Data Protection Agency). However, in the first instance, you may file a claim with the Data Protection Officer, who will resolve the claim within a maximum period of two months.