RESPONSIBLE FOR TREATMENT

Identity: FINE HOMES HOLDING, S.L. (hereinafter, SIR)

NIF: B66643636

Address: Passeig de Gràcia, 41, 2º-1ª, 08007 Barcelona, España

Email: rgpd@barcelona-sir.com

FINE HOMES HOLDING, S.L. (hereinafter, SIR), as responsible for the Website, in accordance with the provisions of EU Regulation 2016/679 of April 27, 2016 (RGPD) on the protection of individuals with regard to the processing of personal data and the free circulation of this data and other regulations in force regarding the protection of personal data, and by the Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSICE), informs you that the necessary security measures have been implemented, of a technical and organizational nature, to guarantee and protect the confidentiality, integrity and availability of the data entered.

COMPANIES LINKED TO THE T&T FINE HOMES HOLDING, S.L. GROUP

COMPANY NAME

COMPANY ADDRESS

NIF

FINE HOMES HOLDING, S.L.

Passeig de Gràcia 41, 2º – 1ª, 08007 Barcelona (Spain)

B66643636

MC COSTA BRAVA, S.L.

Avenida Castell d’Aro 24, 17250 Platja d’Aro (Girona, Spain)

B63592711

T&T FINE HOMES BARCELONA, S.L.

Passeig de Gràcia 41, 2º – 1ª, 08007 Barcelona (Spain)

B55103568

PURPOSE OF THE TREATMENT

Your personal data will only be used for the following purposes:

– To carry out necessary commercial and administrative procedures with the web users;

– To send advertising commercial communications by email, fax, SMS, MMS, social communities or any other electronic or physical means, in the case that the User has expressly consented to be sent commercial communications electronically by subscribing to the NEWSLETTER;

– To respond to queries and/or provide information required by the User;

– To carry out the provision of services and/or products contracted or subscribed to by the User;

– Use the data to contact you, both electronically and non-electronically, to obtain your opinion about the service provided and,

– To notify you about changes, important developments in the privacy policy, legal notice or cookie policy;

– To carry out analysis of profiles and usability;

– The data of customers and/or suppliers will be treated, within the contractual relationship that links them with the person in charge, in compliance with the administrative, fiscal, accounting and labour obligations that are necessary under current ;

– Facility security through a video surveillance system.

You can revoke your consent at any time by writing to rgpd@barcelona-sir.com with the subject “Unsubscribe”

According to the LSSICE, SIR does not put into practice SPAM, therefore, it does not send commercial e-mails that have not been previously requested or authorized by the User. Consequently, in all the communications that you will receive from SIR, the user has the possibility to cancel their consent over receiving our communications.

We will not treat your personal data for any other purpose than those described except by legal obligation or judicial requirement.

Your data will be kept for the duration of the commercial relationship with us or until you exercise your right of cancellation or opposition, or limitation to treatment. However, we will keep certain personal identification and traffic data for a maximum period of 2 years in case it is required by the Judges and Courts or to initiate internal actions derived from the improper use of the website.

It will not be subject to decisions based on automated treatments that produce effects on your data.

LEGITIMATION OF THE TREATMENT

The legal basis for treatment of the data is your given consent to carry out the purposes described above, which will be requested at the time of marking the corresponding box when collecting your data.

Failure to provide the requested personal data or failure to accept this data protection policy means that it is impossible to subscribe, register or receive information about the Provider’s products and services.

In cases where there is a prior contractual relationship between the parties, the legitimacy for the development of administrative, tax, accounting and labour obligations that are necessary under current legislation will be the prior existence of the commercial relationship established between the parties.

COMMUNICATIONS

Any communication sent will be incorporated into the information systems of SIR. By accepting these conditions, terms and policies, the User expressly consents to SIR carrying out the following activities and/or actions, unless the User indicates otherwise:

– The sending of commercial and/or promotional communications by any means enabled informing the Users of the activities, services, promotions, advertisements, news, offers and other information about the services and products related to the activity.

– In the event that the User has expressly consented to the sending of commercial communications electronically by subscribing to the NEWSLETTER, the sending of such communications by electronic means informing the Users of the activities, services, promotions, advertisements, news, offers and other information about the services and products of SIR equal or similar to those that were originally the object of contract or interest by the User.

– The conservation of the data during the periods provided in the applicable provisions.

OFFICIAL COMMUNICATION MEANS

We inform the user that the means enabled by the company to communicate with clients and others affected are the corporate phone, corporate mobile phones and corporate email.

If you send personal information through a means of communication other than those indicated in this section, the COMPANY will be exempt from liability in relation to the security measures available to the means in question.

RECIPIENTS OF CESSIONS OR TRANSFERS

SIR does not carry out any data cession or communication neither inside nor outside the EU. In any other case, SIR will request prior consent from the User. The Provider will only provide information to the security forces and bodies under judicial order or due to the obligation of a legal norm, without prejudice of being able to block or cancel your account if there may be indications of the commission of any crime by the user. The information provided will only be available to the provider at this time.

The information that you provide to us both through this website and through the application will be hosted on the SIR servers.

RIGHTS OF INTERESTED PERSONS

As an interested-user, you can request the exercise of the following rights before SIR by submitting a letter to the postal address at the heading or sending an email to rgpd@barcelona-sir.com, indicating as the Subject: « RGPD, Affected Rights », and attaching a photocopy of your DNI or any similar means in law, as indicated by law.

Rights:

– Rights of access: allows the interested party to know and obtain information about their personal data submitted to treatment.

– Right of rectification or elimination: allows to correct errors and modify the data that prove to be inaccurate or incomplete.

– Right of cancellation: allows data that turns out to be inadequate or excessive to be deleted.

– Right of opposition: right of the interested party to not carry out the processing of their personal data or to cease it.

– Limitation of the treatment: it involves the marking of the personal data kept, with the purpose of limiting its future treatment.

– Portability of the data: facilitation of the data object of treatment to the interested party, so that they can transmit it to another person in charge, without impediments.

– The right not to be subject to automated individual decisions (including profile preparation): the right not to be the subject of a decision based on automated treatment that produces effects or significantly affects.

As a user, you have the right to withdraw the consent given at any time. The withdrawal of consent will not affect the lawfulness of the treatment carried out before the withdrawal of consent.

You also have the right to submit a claim to the supervisory authority if you believe that your rights may have been violated in relation to the protection of your data (agpd.es).

ADDITIONAL INFORMATION

INFORMATION THAT WE COLLECT

The data collected by the responsible party are the following:

– That that the users provide through the different services offered on the website

– That included in the different forms provided on the website

– Data collected through « cookies » for the improvement of the browsing experience as reported in the cookies policy.

With this Privacy Policy we inform you that the photographs that are posted on the website are property of SIR, including those of minors, in which, in order to obtain these, the prior consent of parents, guardians or legal representatives has been obtained by signing the forms made for that purpose by the centres of which the minors are part.

 

VIDEO SURVEILLANCE

At some sale points, images are captured for the sole purposes indicated in the purpose section of this privacy policy and / or at the request of public authorities.

We have an informative pamphlet at the disposition of the interested parties that request it and a video-monitored zone logo located in a place prior to the camera and sufficiently visible that informs that the place is a video-surveyed establishment.

The images captured by the cameras will be limited to the public establishment in question. No images of the public highway will be captured except for a minimum strip of access to the establishment.

The recording system will be located in a guarded or restricted access area. The images obtained will be accessed only by the authorized person and will be kept for a maximum period of one month from their recording.

 

SOCIAL NETWORKS

We inform you that SIR may have presence on social networks. The treatment of the data that is carried out on people who become followers on social networks (and/or carry out any connection or connecting action through social networks) of the SIR official pages will be governed by this section, as well as for those conditions of use, privacy policies and access regulations that belong to the social network that is appropriate in each case and previously accepted by the user.

SIR will process your data with the purpose of correctly managing your presence in the social network, informing you of activities, products or services of the provider, as well as for any other purpose that the regulations of the Social Networks allow.

The publication of contents is prohibited:

– That are allegedly unlawful by national, community or international regulations or that carry out activities that are allegedly unlawful or contravene the principles of good faith.

– That threaten the fundamental rights of people, lack of courtesy in the network, annoy or may generate negative opinions in our users or third parties and in general whatever contents that SIR considers inappropriate.

– And in general that contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, consumer protection and intellectual and industrial property rights.

Likewise, SIR reserves the right to withdraw, without prior notice from the website or from the corporate social network, those contents deemed inappropriate.

Communications sent through social networks will be incorporated into a file owned by SIR, who may send you information of interest.

You can access more information, as well as consult the companies that are part of our group, in this privacy policy.

In any case, if you send personal information through the social network, SIR will be exempt from liability in relation to the security measures applicable to this platform, and the user should, in case of wanting to know them, consult the corresponding particular conditions of the network in question.

 

SECURITY MEASURES

The information you provide will be treated confidentially. The Provider has adopted all the technical and organizational measures and all the levels of protection necessary to guarantee the security in the treatment of the data and to avoid its alteration, loss, theft, treatment or unauthorized access, according to the state of technology and nature of the stored data. Likewise, it is also guaranteed that the treatment and registration in files, programs, systems or equipment, premises and centres comply with the requirements and conditions of integrity and security established in the current regulations.

LANGUAGE

The language applicable to this Privacy Policy is Spanish. Therefore, in the case that there is any contradiction in any of the versions provided in other languages, the Spanish version will prevail.

 

SENDING YOUR CV

In the event that the user submits their CV through www.barcelona-sothebysrealty.com / www.costabrava-sothebysrealty.com / rrhh@barcelona-sir.com, we inform you that the information provided will be treated to make you a participant in the selection processes that may exist, carrying out an analysis of the profile of the applicant in order to select the best candidate for the vacancy of the Responsible party. We inform you that this is the only official procedure to accept your CV, so CVs submitted by another procedure will not be accepted. In case of any change in the data, please inform us in writing as soon as possible, in order to keep your data properly updated.

The data will be kept for a maximum period of one year, after which the data will be deleted guaranteeing a total respect to confidentiality both in the treatment and in its subsequent destruction. In this sense, after the aforementioned deadline, and if you wish to continue participating in the selection processes of the Responsible party, please resend your CV.

The data may be processed and / or communicated to the member companies of our group during the time of conservation of your CV and for the same purposes previously reported.

 

CHANGES IN THIS PRIVACY POLICY

SIR reserves the right to modify this policy to adapt it to new legislation or jurisprudence.

 

LEGISLATION

For all purposes, the relations between SIR and the Users of its telematic services, present on this Website, are subject to the Spanish legislation and jurisdiction to which the parties expressly submit themselves.