We care about your privacy and take every precaution to protect your personal data. We never sell your private data, but it’s important to us that you know what happens to your personal data once we have it.
This Privacy Notice (the “Notice” for short) is intended to provide you with information about how we collect and use your personal data and about your legal rights under Spanish law (Article 15/1999 of December 13th, the Protection of Personal Data), and under the General Data Protection Regulation (EU 2016/679), or “GDPR”, the European law concerning the use of personal data.
We have taken every effort to make this Notice as user friendly and as easy to understand as is possible. However, we want to be as transparent and unambiguous as we can be, so that you can easily understand our policy. Where applicable, you consent to the use of your personal data as described in this Notice each time you use our website or our products or services, so please take time to read this Notice carefully.
Ultimately, you need to know that we have the highest respect for our customers, our potential customers, and the great people we work with and meet everyday. That´s why we would never sell your personal data, or do anything else with your personal data that wasn´t an expected requirement of our role as an estate agent here in Spain.
This Privacy Notice was published 22nd May 2018.
1. Important information and who we are
This Notice aims to give you information on how Sangria Properties collects and processes your personal data, whether you have provided it to us directly or whether we have obtained it from other people, online web applications and programs, and other businesses or organisations. This Notice explains your rights with regard to your relationship with us, and how you can exercise those rights easily.
The Personal Data Controller
Costablanca Restassured is the personal data controller and responsible for your personal data. When we refer to “Sangria Properties”, “we”, “us” or “our” in this Notice, that’s who we are talking about.
If you have any questions about this Notice or if you want to exercise any of your legal rights under EU or Spanish data protection law, please contact us. You can find our contact details on our contact us page, and for maximum clarity they are here too:
C. C. La Rioja 28
03189 Los Dolses
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If we change this Notice in any significant material way we will let you know so that you can make an informed choice about how we manage your personal data, and whether you wish to allow us to continue to use or retain your personal data.
2. Why we process personal data and how we collect it
“Personal data” or “Private data” or “Your data” means any information about an individual, held by a data controller, from which the data controller can identify a specific, living person. It does not include data about a living person that the data controller cannot identify.
The main purpose of the data processing undertaken by us is to provide, carry out and improve our services to you, both now and in the future. There are several different reasons why we may need to collect, manage and retain your data. Some of the reasons are simply so that we might meet our obligations under EU and Spanish law, and on other occasions we will need to retain your personal data in order to fulfill the requirements of our contracts, deliver the goods or services that you have asked us for, or to be able to offer you the most appropriate services suited to your individual circumstances.
You may directly or indirectly provide us with your personal data in a number of different ways. For example, when you engage our services to buy or sell a property, visit our website, or contact us in another way, such as at a property viewing or via email. We may also collect personal data from a third party, for example via a property portal that we partner with, via our social media channels, or if you request tickets for an exhibition that we´re attending.
We may collect, use, store and transfer different kinds of personal data about you. The personal data we collect will depend on the relationship you have with us. We process personal data for the following purposes, based on the following lawful basis:
|Purpose of processing
||Lawful basis for processing
|To confirm your identity and verify your personal and contact details
||To fulfill contracts and commitments made to you
|To match property to your requirements and provide products and services to you
||To fulfill contracts and commitments made to you
|To provide you with customer service with regards to our products and services
||To fulfill contracts and commitments made to you
|To manage your potential participation in property exhibitions and events
||To fulfill contracts, and other legitimate interests
|To work with third party businesses, professionals, and organisations
||To fulfill contracts, and other legitimate interests
|To comply with the EU and Spanish legislation and to combat money laundering
||To comply with current and future legislation
|To meet our financial and taxation obligations
||To fulfill contracts, and to comply with legislation
|To engage in marketing analysis so that we may improve our services to you
||Other legitimate interests
|To promote our products and services via digital marketing and advertising
||Other legitimate interests
|To promote our products and services via printed marketing and advertising
||Other legitimate interests
The EU GDPR definition of “Legitimate Interest” and how we use your data
When we use the lawful basis “Legitimate Interest”, this means that the processing of personal data is required in order to satisfy our legitimate interest as an estate agent. For example, to be able to offer you property related products and services such as our free property valuation. We might also choose to follow up a property viewing visit to find out what you thought about the property, or we might like to ensure that you are happy in a new home that you might have purchased from us.
Another example of legitimate interest is keeping our services as relevant, effective, and as user-friendly as is possible. That means we need to analyse how our services are used, including asking for feedback from customers, to enable us to make improvements for you and for future customers.
We always aim to assist you with relevant communications, and only offer products and services that are appropriate and compatible with your individual circumstances. For the lawful basis “Legitimate Interest”, we always consider the balance between our interest in processing your personal data, and your interest in protecting your personal data.
Personal data in “Special Categories”
Some personal data falls into “Special Categories” under the GDPR and are given greater protection. As an estate agent, we will never ask our customers or potential customers for information or retain data that falls into the definition of “Special Categories” at any time during our relationship with you. We do not collect personal data from our customers or potential customers that falls into the definition of “Special Categories” and we do not retain or store this type of data. We market our products and services to adults and we do not knowingly collect or retain personal data for children or persons under the age of 18 years.
3. The personal data we collect
Personal data we collect from our customers and potential customers
We only ever collect personal data from our customers that is essential to provide the services or information we are asked for. Examples of data that we might collect from you include:
- IDENTITY DATA including your name, residential address, contact telephone numbers, passport number or your national identity number, and your email address.
- TRANSACTION DATA including details about payments to and from you and other details of products or services you have purchased from us.
- USAGE DATA including information about how you use our website, products and services, and marketing and communications data including your preferences for receiving marketing material from us and your communication preferences.
- TECHNICAL DATA including the internet protocol (IP) address of your device, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, device language, hardware platform, and other technology on the devices you use to access our website.
- PROFILE DATA including inquiries made by you, and your areas of interest and preferences, for instance, the type of property that you might be interested in purchasing, or the areas in our locality that you have expressed a preference for. Profile data may also include recording the results of property viewings including your provided feedback.
- PHYSICAL DATA which may not fall under the scope of personal data legislation, but which might contain your personal data. For instance, we might have to ask you to provide copies of documents to enable us to sell your property, so that we can complete the purchase of a property on your behalf, or so we can meet our legal obligations to prevent money laundering, and these documents may contain personal data (such as your name or bank account details).
- AGGREGATED DATA on visitors to our website, and anyone who submits a query or request for further information via our website (whether directly from our website or from a partner organisation or property portal). This may include statistical or demographic data which we may use for statistical and analytical purposes.
Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or evaluate the level of interest in a property. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Notice.
Personal data we collect from third parties
We may collect personal data from business partners and marketing agencies. This includes your contact data from marketing partners when we engage in joint marketing or co-branded activities, your IP address or location information from service providers, to offer certain products and services relevant to your location, and personal data our social network channels.
Personal data we collect from businesses we work with
For persons and businesses who supply us with goods or services (including hiring things to us), and any company or other organisation to whom we supply goods or services, or otherwise work with in our usual business as a real estate agent; we may collect, use, access, and retain the following types of personal data about you:
- IDENTITY DATA including your name, title, job title, role or similar identifier, and gender.
- CONTACT DATA including your work address, email address, and telephone numbers
- FINANCIAL DATA if we supply or purchase goods or services to or from you as an individual (including sole traders and partnerships), or as a professional, business, or organisation, we will record and retain details of those transactions.
Where we process your personal data
We, our service suppliers and business partners generally process your personal data within the EU/EEA. In cases where personal data is processed outside the EU/EEA, we ensure that our chosen service suppliers and business partners comply with the same level of security and protection that is applied in the EU/EEA, or protect your personal data under the EU/US Privacy Shield framework.
How long we store your personal data
We retain personal data for the period of time required for the purposes specified in this Notice. We retain your personal data for as long as is necessary to be able to complete the task or role you assigned to us, to provide the products or services you asked us for, or we may retain your personal data to allow us to meet our obligations under contracts or for other commitments, such as data retention periods specified by law.
Inter-company data transactions
We may share personal data with all companies, organisations, and businesses owned by us including companies we may form in the future. In the event of a merger, reorganisation, acquisition, joint venture, assignment, transfer, sale, or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party.
4. Sharing your data with third parties
We don´t sell your personal data to any other persons, businesses or organisations, and naturally we don´t share your personal data with just anyone. However, sometimes we may need to share your personal data with selected third parties. If we do need to transfer your information to a third party, we make sure that the transfer of your personal data happens in a secure way that protects your privacy. Here are some examples of when we might need to share your personal data, and who we might share your personal data with:
- LAWYERS AND NOTARIAL COMPANIES so that we might assist you with buying or selling your property. All our lawyers and notaries are fully registered professional companies operating in Spain.
- BUSINESS PARTNERS so that we might assist you with products or services that are relevant to your needs in our role as an estate agent. For instance, if you ask us to provide you with home insurance for your property in Spain, or if you ask us to arrange for the issue of an NIE.
- BUSINESS SYSTEMS so that we can store your personal data for the provision of the information, products or services that you have contracted us to provide you with, and for administration purposes.
- THIRD PARTY MARKETING SERVICES so that we can send you relevant offers and information about property, or other goods or services that you might express an interest in, provided you have consented (opted-in) to receiving marketing material from us.
- SUPPLIERS OF COMMERCIAL PRINTED MATERIAL we may also share details about you with suppliers that provide printed material and distribution services, including your photograph if you have consented to it´s use.
- LAW ENFORCEMENT AND REGULATORY AGENTS both here in Spain and throughout the entire EU, only if we are required to do so by law.
Third party service providers
We share personal data with companies that provide essential services to us or who we work with in the normal course of our business as an estate agent, such as website hosting services, companies that provide mobile and computer operating systems, email service providers, communication applications, companies that provide us with online and administrative services, digital online and offline marketing services, digital analytical services, auditing and payment processing providers, customer research centres, other estate agents and property developers (where it is necessary to carry out your instructions), and other service providers that assist us or are essential for providing our products and services. Some of these companies may be based outside of the EU/EEA but are obligated to protect your personal data to the same standards that we are, under the requirements of the EU GDPR or EU/US Privacy Shield framework.
Third party websites, products, and services
Our products and services, including our websites and digital media properties, may contain links to third party websites, products, or services. We are not responsible for the privacy practices employed by those third parties, nor are we responsible for the information or content their websites, products, or services may contain. This Notice, and the contents of this Notice, applies solely to personal data collected by us. We encourage you to read the privacy notices of any third party website before proceeding to use the website, product, or service.
Legal compliance and security
It may be necessary, by law or as a result of due legal process, litigation, or requests from public or governmental authorities within or outside your country of residence, for us to disclose your personal data. We may also disclose personal data if we believe that is necessary for the purposes of protecting national security, law enforcement, or other issues of significant public importance, where disclosure is considered necessary or appropriate.
We may also disclose personal data to third parties if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our business, customers, employees, or other people we work with.
5. Your rights to your personal data
You will always have control over your own personal data, regardless of the information we hold about you. Your rights are guaranteed by stringent data protection legislation which we adhere to vehemently. You can choose at any time to exercise your rights to your personal data including:
- Your right to access
You can request a copy of the personal data we retain and verify the data we hold that applies to you.
- Your right to rectification
You are entitled to have inaccurate or incomplete data about you rectified.
- Your right to be forgotten
You have the right to request that your personal data be deleted if the data is no longer needed for the purpose for which it was collected. However, if the personal data is being stored because of a legal obligation to store that information, you are not entitled to request that such information is deleted nor are we obligated to delete the information.
- Your right to data portability
If our right to process your personal data is based on specific consent from you, or your personal data was collected in order to fulfil a contract with you, you are entitled to request a copy of that data in a machine readable form in order to reuse it with another company or agent you may choose to appoint. This primarily applies to data that you have given us. In other words, only certain data is covered by the right to data portability.
- Your right to object
You always have the right to request not to receive direct marketing or advertising from us, and to object to such processing of personal data based on a balancing of interests (a legitimate interest). In cases where we use a legitimate interest/balancing of interests as a lawful basis for a purpose, you have the opportunity to object to the processing of your personal data. If you choose to object to receiving direct marketing from us we will immediately cease processing your personal data for that purpose.
- Your right to restriction of processing
You have the right to restrict the processing of your personal data if, for example, you consider it to be inaccurate or no longer relevant to your circumstances or needs.
You can choose to exercise any of your rights listed above completely free of charge. However, if a request is clearly unfounded or unreasonable, or repeated requests are made in a short space of time, we will charge a fee to cover any administrative expenses that might be associated with that request. We may also refuse a request that is unfounded or unreasonable, or in circumstances where we are unable to confirm your identity, or if we ask you to confirm your identity and you refuse to do so.
Information for the Newsletter
If you wish to receive the newsletter that is offered on the website, we need your email address, as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. , No more data is collected or only voluntarily. We use this information exclusively for the delivery of the information requested and we do not transmit it to third parties.
The processing of the data entered in the registration form of the newsletter is done exclusively on the basis of your consent (Art. 6 (1) lit. DSGVO). The consent granted for the storage of the data, the e-mail address and its use to send the newsletter can be revoked at any time, for example, through the “unsubscribe” link in the newsletter. The legality of the data processing operations already completed is not affected by the revocation.
The data deposited with us in order to obtain the newsletter will be kept by us from the newsletter until its cancellation and will be deleted after the cancellation of the newsletter. The data that was stored for other purposes with us (such as email addresses for the members area) will not be affected.
This website uses the MailChimp services to send newsletters. The provider is Rocket Science Group LLC, 675 Ponce De Leon Ave. NE, Suite 5000, Atlanta, GA 30308, USA. UU
MailChimp is a service that helps you sending newsletters can be organized and analyzed. If you enter dates for subscription to the newsletter (for example, email address), they will be stored on the MailChimp servers in the United States.
MailChimp is certified under the EU-EE Privacy Shield. UU Privacy Shield is an agreement between the European Union (EU) and the US. UU To ensure compliance with European privacy standards in the United States.
With the help of MailChimp we can analyze our newsletter campaigns. When you open an email sent by MailChimp, a file included in the email (called web beacon) connects to the MailChimp servers in the United States. In this way, you can determine if a bulletin message has been opened and which links have been clicked on. In addition, technical information is collected (for example, recovery time, IP address, browser type and operating system). This information can not be assigned to the recipient of the respective newsletter. They are used exclusively for the statistical analysis of newsletter campaigns. The results of these analyzes can be used to better adapt future newsletters to the interests of the recipient.
If you do not want the analysis of MailChimp, cancel the subscription of the newsletter. For this, we provide a corresponding link in each bulletin message. In addition, you can unsubscribe from the newsletter directly on the website.
The data processing is based on your consent (Article 6 (1) (a) GDPR). You may revoke this consent at any time by canceling the subscription to the newsletter. The legality of the data processing operations already completed is not affected by the revocation.
The data deposited with us in order to obtain the newsletter will be stored by us from the newsletter until they are removed from the newsletter and, after unsubscribing from the newsletter, will be removed from both our servers and the MailChimp servers. The data that was stored for other purposes with us (such as email addresses for the members area) will not be affected.
If you have any complaints about the way in which we process your personal data, or if you would like more information about the issues raised in this Notice, please contact us and we´ll be happy to help you.
> GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016