Private Property Marbella Privacy Policy
Privacy Policy and Cookie Policy
Last Updated on: 8th June 2021
Private Property Spain SL understands that your privacy is important to you and that you care about how your information is used and shared online. We take the issue of privacy seriously. We recognise that when you provide us with information about yourself or your business, that you trust us to act in a responsible manner and we are committed to making sure we earn that trust. We respect and value the privacy of everyone who visits privateproperty.es and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.
This Policy applies to our use of any and all data collected by us in relation to your use of privateproperty.es. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of privateproperty.es and/or you will be required to read and accept this Privacy Policy when signing up for an account. If you do not accept and agree with this Privacy Policy, you must stop using privateproperty.es immediately.
1. Definitions and interpretation
In this Policy, the following terms shall have the following meanings:
Account means an account required to access and/or use certain areas and features of privateproperty.es;
Cookie means a small text file placed on your computer or device by privateproperty.es when you visit certain parts of privateproperty.es and/or when you use certain features of privateproperty.es. Details of the Cookies used by privateproperty.es are set out in section 12, below;
Our site means this website, privateproperty.es;
EU cookie law means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015;
We/Us/Our means Private Property Spain SL, a company registered in Spain under company registration number B93191492, whose registered address is Centro Comercial Los Halcones, Ctra.de Ronda A397, 29679 Benahavis (Malaga) and whose main trading address is Centro Comercial Los Halcones, Ctra.de Ronda A397, 29679 Benahavis (Malaga).
2. Information about us
Our site, privateproperty.es, is owned and operated by Private Property Spain SL, a company registered in Spain under company registration number B93191492, whose registered address is Centro Comercial Los Halcones, Ctra.de Ronda A397, 29679 Benahavis (Malaga) and whose main trading address is Centro Comercial Los Halcones, Ctra.de Ronda A397, 29679 Benahavis (Malaga). Our TAX ID number is B93191492.
2.1. Our data protection officer is Gary Francis who can be contacted at info@privateproperty.es
2.2. We are not currently regulated by any official regulating bodies
2.3. We are not currently members of any associations
3. Scope – What does this policy cover?
This Privacy Policy applies only to your use of privateproperty.es. It does not extend to any websites that are linked to or from privateproperty.es (whether we provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What data do we collect?
Some data will be collected automatically by privateproperty.es (for further details, please see section 12 on our use of Cookies), other data will only be collected if you voluntarily submit it and consent to us using it for the purposes set out in section 5, for example, when signing up for an account.
Depending upon your use of privateproperty.es, we may collect some or all of the following data:
4.1. Name
4.2. Date of Birth
4.3. Company Name
4.4. Job Title
4.5. Profession
4.6. Contact Information such as email addresses and telephone numbers
4.7. Demographic Information such as post code, preferences and interests
4.8. IP address (automatically collected)
4.9. Web browser type and version (automatically collected)
4.10. Operating system (automatically collected)
4.11. A list of URLs starting with a referring site, your activity on our site, and the site you exit to (automatically collected)
4.12. Bank details for the purpose of making payments to clients
5. How do we use your data?
5.1. All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2. We use your data to provide the best possible products and services to you.
This includes:
5.3. Providing and managing your account;
5.4. Providing and managing your access to privateproperty.es;
5.5. Personalising and tailoring your experience on privateproperty.es;
5.6. Supplying our products and services to you;
5.7. Personalising and tailoring our products and services for you;
5.8. Responding to communications from you;
5.9. Supplying you with email updates e.g., newsletters, alerts etc. that you may have subscribed to (you may unsubscribe or opt-out at any time by contacting us);
5.10. Market research;
5.11. Analysing your use of privateproperty.es and gathering feedback to enable us to continually improve privateproperty.es and your user experience;
5.12. In some cases, the collection of data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you without your consent for us to be able to use such data.
5.13. With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or text message and/or post with information, news and offers on our products and/or services We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.14. Advertisers whose content appears on privateproperty.es may engage in what is known as behavioural advertising, advertising which is tailored to your preferences, based on your activity. Your activity is monitored using cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that we do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on privateproperty.es.
5.15. Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
5.16. you have given consent to the processing of your personal data for one or more specific purposes;
5.17. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
5.18. processing is necessary for compliance with a legal obligation to which we are subject;
5.19. processing is necessary to protect the vital interests of you or of another natural person;
5.20. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
5.21. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child
6. How and where do we store your data?
6.1. We only keep your data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your data
6.2. Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). If we intend at any time to transfer any of your data outside the EEA, we will always obtain your consent beforehand
6.3. We use the following methods to store your data:
6.3.1. On-premises digital data storage
6.3.2. On-premises physical hard copy files
6.3.3. Cloud-based digital storage
6.4. Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our site. Steps we take to secure and protect your data include:
6.5. Staff awareness training on the importance of personal data
6.6. Data is only accessed by authorised personnel
6.7. All staff have signed confidentially agreements
6.8. Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet
7. Do we share your data?
7.1. We may share your data with other companies in our group. This includes our subsidiaries and/or our holding company and its subsidiaries
7.2. We may contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law
This is a list of third parties that we contract with and with whom some or all of your data might be shared with
7.3. mailchimp.com
7.4. inmoba.com
7.5. resales-online.com
7.6. We may compile statistics about the use of privateproperty.es including data on traffic, usage patterns, user numbers, sales and other information. All such data will be analysed and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law
7.7. In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us
8. What happens if our business changes hands?
8.1. We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Data provided by users will, where it is relevant to any part of our business, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by us
8.2. In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. If contacted, however, you will be given the choice to have your data deleted or withheld from the new owner or controller
9. How can you control your data?
9.1. When you submit information via privateproperty.es, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt out of receiving emails from us, which you may do by unsubscribing, using the links provided in our emails and at the point of providing your details and/or by managing your account)
9.2. You may also wish to sign up to one or more of the preference services operating in your country: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note however, that these services will not prevent you from receiving marketing communications that you have consented to receiving
10. Your right to withhold information and your right to withdraw information after you have given it
10.1. You may access certain areas of privateproperty.es without providing any data at all. However, to use all features and functions available on privateproperty.es you may be required to submit or allow for the collection of certain data
10.2. You may restrict your internet browsers use of cookies. For more information, see section 12 of our cookie policy
10.3. You may withdraw your consent for us to use your personal data as set out in section in 5 at any time by contacting us using the details set out in section 15, and we will delete your data from our systems. However, you acknowledge this may limit our ability to provide the best possible products and services to you
11. How can you access your data?
You have the legal right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us for more details at info@privateproperty.es, or using the contact details below in section 15
12. Cookies
privateproperty.es may place and access certain first party cookies on your computer or device. First party cookies are those placed directly by us and are used only by us. We use cookies to facilitate and improve your experience of privateproperty.es and to provide and improve our products and services. By using privateproperty.es you may also receive certain third-party cookies on your computer or device. Third party cookies are those placed by websites, services, and/or parties other than us. Our site uses third party analytics services, which applies third party use of cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use our site. This is a list of third-party analytics providers we currently use:
12.1. Google analytics
13. Summary of your rights under GDPR
Under the GDPR, you have:
13.1. the right to request access to, deletion of or correction of, your personal data held by us;
13.2. the right to complain to a supervisory authority;
13.3. be informed of what data processing is taking place;
13.4. the right to restrict processing;
13.5. the right to data portability;
13.6. object to processing of your personal data;
13.7. rights with respect to automated decision-making and profiling (see section 14 below)
To enforce any of the foregoing rights or if you have any other questions about privateproperty.es or this Privacy Policy, please contact us using the details set out in section 15 below
14. Automated decision making and profiling
14.1. In the event that we use personal data for the purposes of automated decision making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
14.2. The right described in section 14.1 does not apply in the following circumstances:
14.3. The decision is necessary for the entry into, or performance of, a contract between you and us;
14.4. The decision is authorised by law; or
14.5. You have given you explicit consent
Where we use your personal data for profiling purposes, the following shall apply:
14.6. Clear information explaining the profiling will be provided, including its significance and the likely consequences;
14.7. Appropriate mathematical or statistical procedures will be used;
14.8. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
14.9. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling
15. Contacting us
If you have any questions about privateproperty.es or this Privacy Policy, please contact us by email at info@privateproperty.es, by telephone on +34 952927878, or by post at Centro Comercial Los Halcones, Local 3, Ctra.de Ronda A397, 29679 Benahavis (Malaga). Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 11, above)
16. Changes to our privacy policy
We may change this privacy policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on privateproperty.es and you will be deemed to have accepted the terms of the privacy policy on your first use of privateproperty.es following the alterations. We recommend that you check this page regularly to keep up to date