Politique de confidentialité

Last updated: [COMPLETAR: date of last review]

This policy explains how your personal data is processed in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

1. Data controller

• Controller: [COMPLETAR: full name or company name] · Tax ID (NIF) [COMPLETAR: NIF]
• Address: [COMPLETAR: full address]
• Telephone and WhatsApp: +34 611 359 567 · Email: [COMPLETAR: contact email]
• Data protection officer: [COMPLETAR: contact details of the data protection officer, only if one has been appointed; otherwise delete this line]

2. What data we process

This website has no forms. We only process the data you choose to give us when you get in touch:

• Telephone: your number and what you tell us during the call.
• WhatsApp: your name or alias, telephone number, profile photo if visible, and the content of your messages. The message that opens when you tap the button includes the reference of the page you are writing from; you can edit it before sending.
• Email: your address, your name and the content of the message.
• If you proceed with a purchase: identification data (ID card, NIE or passport), contact and financial details, and the documentation needed to formalise the reservation or contract and to comply with anti-money-laundering legislation.

3. Purposes and legal basis

• Answering your enquiries, sending you the information, prices and terms you request, and arranging viewings. Legal basis: taking steps at your request prior to entering into a contract (Art. 6(1)(b) GDPR).
• Managing the reservation, the purchase and the contractual relationship. Legal basis: performance of a contract (Art. 6(1)(b) GDPR).
• Complying with legal obligations, in particular those under Spanish Law 10/2010 of 28 April on the prevention of money laundering and terrorist financing, and tax and accounting obligations. Legal basis: legal obligation (Art. 6(1)(c) GDPR).
• Sending you news about the development, only if you expressly agree. Legal basis: consent (Art. 6(1)(a) GDPR), which you may withdraw at any time.

We do not make automated decisions or create profiles that produce legal effects concerning you.

4. Retention period

• Enquiries: for as long as you are interested in the villas and, at most, [COMPLETAR: period, e.g. 2 years] from the last contact.
• Contractual data: for the duration of the relationship and, thereafter, for the limitation periods of any claims that may arise and the periods set by tax and commercial law.
• Anti-money-laundering documentation: ten years, as required by Article 25 of Spanish Law 10/2010.

After these periods, the data is deleted or blocked for as long as liability may be claimed.

5. Recipients

• Providers processing data on our behalf (processors), under a contract complying with Article 28 GDPR: web hosting ([COMPLETAR: hosting provider]) and email ([COMPLETAR: email provider]).
• WhatsApp: if you message us on WhatsApp, communication takes place through WhatsApp Ireland Limited (Meta group), subject to its own terms and privacy policy.
• To process a purchase, if you proceed: the developer of the villas, notaries, land registries and, at your request, banks and advisers.
• Public authorities, where required by law (for example, the Spanish Tax Agency or the Executive Service of the Commission for the Prevention of Money Laundering).

[COMPLETAR: review this list and add or remove recipients as applicable, e.g. accountancy firm or customer management software]

6. International transfers

Meta (WhatsApp) may process data in the United States. These transfers are based on the EU-US Data Privacy Framework (European Commission adequacy decision of 10 July 2023) or on standard contractual clauses approved by the European Commission.

7. Your rights

You may exercise your rights of access, rectification, erasure, objection, restriction of processing and data portability, and withdraw any consent you have given at any time, by writing to [COMPLETAR: contact email] or to the address above, enclosing a copy of a document proving your identity.

If you believe your request has not been handled properly, you may lodge a complaint with the Spanish Data Protection Agency (AEPD, C/ Jorge Juan, 6, 28001 Madrid · www.aepd.es) or with the supervisory authority of your country of residence in the EU.

8. Minors

The services on this website are intended for adults. We do not knowingly process data of children under 14 (Art. 7 LOPDGDD).

9. Security

We apply technical and organisational measures appropriate to the risk to protect your data against loss, misuse or unauthorised access.

10. External links and cookies

The WhatsApp and telephone buttons and the “Open in Google Maps” link only take you to those services when you tap them; until then, no data is sent to them. From that moment, their own privacy policies apply. The use of cookies and similar technologies is explained in the cookie policy.

11. Changes to this policy

We may update this policy to reflect legal or service changes. The date of the last review is shown at the top.