PRIVACY POLICY
INTRODUCTION
Maintaining the security of your data is our priority, and we are committed to respecting your privacy rights. We undertake to handle your data fairly and legally at all times and to only process your data with your consent. We are also dedicated to being transparent about what data we collect from you and how we may use such data.
This privacy policy aims to explain the types of personal data Spain Luxury for Rent SL (SPLR) and any of its subsidiaries, may collect about you when you interact with us, whether you visit our developments, offices, use your mobile device or go on line. It also aims to explain how we will process, share and keep your data.
As we may need to update this notice from time to time, we will inform you if there are any significant changes, however, please feel free to check this notice as you wish from time to time.
WHO IS SPAIN LUXURY FOR RENT SL?
Spain Luxury for Rent SL is a registered company in Spain with our registered office domiciled at Plaza del Bulevar Edificio “B” local 12, 1a planta oficinas 1A y 1B, 29649 La Cala de Mijas, Malaga. This notice provides you with the necessary information regarding your rights and obligations and explains how, why and when we collect and process your personal data.
HOW CAN I CONTACT THE DESIGNATED SPLR DATA CONTROLLER?
You can contact our Data Controller (a) by postal communication to the address indicated in the previous question of this document, or (b) by sending an email to the following address: privacy@spainluxuryforrent.com
FOR WHAT PURPOSE WILL SPLR COLLECT YOUR PERSONAL DATA?
We may collect and process your personal information for a number of reasons. These reasons include:
· So that we may comply with any legal obligation that we have;
· Where you have consented to the processing
· To manage your candidacy when you have applied for a job with us
· In order to comply with our duties and exercising our rights under a contract with you
This includes, but is not limited to, information you (or a joint purchaser and/or owner) provides:
· When you visit/access one of our websites or platforms – (platforms are the means by which we establish digital contact, including websites operated by us and any form of social media);
· When you visit any of our offices or developments;
· When you contact us in person, over the telephone, by e-mail, by post or any other form of messaging;
· When you complete any of our website forms for a service request;
· When you access information about any of our developments and/or new homes via a third-party provider, such as a property portal;
· At the time of reserving a property to purchase from us;
· At the time of purchasing options and extras from us;
· During the course of purchasing a property from us and/or selling a property to us in part exchange;
· When you enter into any transaction with us, whether in person or any other way;
· When you apply for a job vacancy with us.
HOW WILL WE USE THIS INFORMATION?
We do not sell customers personal data to third parties and will only use your personal information to provide you with details of our own products, properties or developments which we believe will be of interest to you. In addition, we may use your information to:
· Contact you – if you have indicated a specific interest in a property/development or a particular area in which we have properties/developments available;
· Provide a relevant service –if you have contacted us for a specific purpose or accessed our services by completing a website form and not opted out, we will take into account your perceived preferences for a specific property type or location. In the vent that you do not wish to receive this personalised service, you can unsubscribe from our e-mails or similarly contact us as set out above
· Tailor our service to your location – With your permission, we may use IP addresses and device identifiers to identify your location. We will use this for general statistical purposes. We may also use this information to direct you to certain developments/properties in your area.
· Improve our service – we provide information to third parties for research and analytical purposes, so that we can improve the services we offer to you.
Please be assured that any personal information given to us for a specific use or purpose will not be used for any other purpose without your notification and (where appropriate) permission.
WITH WHOM WILL WE SHARE YOUR PERSONAL DATA?
We take your privacy very seriously and will never disclose or share your personal data without your knowledge, unless we are required to do so by law or you have previously authorised us to do so.
In some cases, we may share your personal data with:
– Third parties who provide services for us where necessary for the delivery of our products and services. For example:
o contractors who undertake snagging work on our behalf;
o third parties who administer agreements on our behalf
o suppliers who provide or make provisions to provide services to, or in relation to your property;
o managing agents appointed in accordance with the terms of your home purchase agreement;
o to protect our rights, property or our safety and/or the safety of our customers, or others.
– Other third parties with your consent and where you request we introduce you to them, for example mortgage brokers and bodies for the purposes of undertaking market research analysis in respect of purchasers of new homes;
· law enforcement agencies or regulatory bodies where we are required to do so in order to comply with a regulatory or legal provision;
· local authorities;
· credit reference agencies and fraud prevention agencies;
· our professional advisors;
· suppliers of services in respect of any property you reserve from us
WHEN WILL WE CONTACT YOU?
We may contact you:
· For legitimate purposes aligned with our contract;
· In relation to previous communication from you. This includes any comment or complaint concerning us, our services, properties or developments, or any previous contact we may have had with you;
· If you requested further information. If you have signed up to a product, property or development whether directly or indirectly through us or via a third-party provider, such as a property portal;
· If you have expressed an interest in a specific product, property or development;
· To provide you with additional information concerning a specific property/development, type of property/development or similar properties/developments to those in which you expressed an interest;
· For marketing purposes if you have chosen to receive a service from us by completing one of our website forms and not opted out in accordance with this policy.
WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA?
You have the right to access any personal information that we process about you and to request information about:
· What personal data we hold about you;
· The purposes for which we process your data;
· The categories of personal data concerned;
· The recipients to whom the personal data has/will be shared with;
· How long we intend to store your personal data;
· If we did not collect the data directly from you, information about the source.
You have the right to ask us to correct and/or complete the information if you believe that we hold any incomplete or inaccurate data about you. We will strive to update/correct this as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
If you would like to request to have your personal data removed or its use to be amended, you have the right to request:
· Your personal data to be erased (deleted) from our records;
· The use/processing of your personal data to be restricted in accordance with data protection laws;
· To opt out of any direct marketing from us (this can be done in a variety of ways and will be dependant on the type of marketing that you are receiving. (please see the relevant marketing material for details on how to unsubscribe);
· To be informed about any automated decision-making that we use.
· A request for the deletion or correction of personal data should be addressed to the Data Controller at the registered offices Spain Luxury for Rent SL and any of its subsidiaries, or by e-mail to privacy@spainluxuryforrent.com
In some cases, you have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified.
You have the right to receive, move, copy or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.
HOW LONG DO WE STORE YOUR PERSONAL INFORMATION?
We only ever retain your personal information for as long as Is necessary. This is dependent on its purpose, or the amount of time set out in the contract you enter with us.
– Purchasing a Property – If you enter into a contract with us to purchase a property, we will hold your information for a maximum of 7 years from the date of completion of that purchase;
– Anti-money Laundering – in the event that you provide us with personal information so that we can fulfil any anti-money laundering obligations, we will retain such information for a period of 7 years – this is to fulfil our legal obligations;
– If you contact us – if you get in touch regarding any of our properties/developments or types od property/developments or the services we provide – whether we receive such information from you or a third-party – we will retain your personal information until whichever of the below happens first:
o You request that we delete it – We will need to retain a record of your request to be deleted. Unless you purchase a property from us, in which case we would keep your data for as long as is deemed legally necessary.
o A maximum period of 7 years. From the date that you last made contact with us – directly or via a third-party – in relation to any of our properties or developments.
WHAT IF I AM NOT SATISFIED WITH THE WAY IN WHICH SPLR SL HAVE TREATED MY DATA?
If you are not satisfied or you consider the way in which we have treated your personal information in accordance with the regulations unsatisfactory, you can contact our Data Controller at our registered office or by e-mail to privacy@spainluxuryforrent.com.
You may also file a claim with the Spanish Agency for Data Protection (www.agpd.es)
COOKIE POLICY
This policy (‘Cookie Policy’) is an integral part of the Privacy Policy
WHAT IS A COOKIE?
A cookie is a file that is downloaded to your computer when you access certain web pages. It contains a small amount of data and (typically) a unique identifier. When you access any of our websites or platforms (or those of third-party providers), a cookie will be sent to your device. The cookie records information about your online preferences and therefore allows us to tailor our websites and any contact with you to your specific interests.
WHY DO WE USE COOKIES?
The information we obtain by monitoring all visits to our websites enables us to improve through anonymous analysis, our services to our customers and visitors.
Cookies are used by us to improve your experience when using our website and to track usage. For example, what pages are being viewed. This in turn, helps us to understand how the site is being used. We do not use personal information in the cookies and we do not track you personally, only the computer or device that you are using. These can be session cookies which are deleted when you close your browser and/or persistent cookies which remain on your computer for a longer period of time.
HOW CAN I MANAGE THE COOKIES ON MY DEVICE?
You can allow, block or delete the cookies installed on your device by configuring the options in your specific internet browser. You will need to refer to the help menu on your internet browser, In a few cases, blocking cookies may reduce the functionality of our sites or prevent access to them depending on your chosen browsers options.
UPDATE OF OUR COOKIE POLICY
We may update our cookie policy for our websites in accordance with any legal or technical requirements. We therefore recommend that you check this policy to be properly informed about how and for what purposes we use cookies.
Last update: 17th February 2019
HOW CAN I CONTACT SPLR SL WITH ANY ISSUES/CONCERNS SURROUNDING THIS PRIVACY & COOKIE POLICY?
Any contact you wish to make with us concerning this policy or how it works in practice should be directed to the Data Controller. Please either write to us at our registered office address or e-mail to privacy@spainluxuryforrent.com