PRIVACY POLICY AND DATA PROTECTION

In accordance with the provisions of current legislation on data protection, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, GDPR), as well as in the Organic Law 3/2018, of 5 December, on Data Protection and guarantee of digital rights (hereinafter, LOPD-GDD), the user is informed in accordance with the provisions of articles 13 of the GDPR and 11 of the LOPD-GDD:

I. RESPONSABLE

Who is responsable for your data treatment?

*Corporate name: PROMOCIONES INMOBILIARIAS CALERO SA
*Registered office: C/ Lérida, 8. Portal 1. 28020 (Madrid)
*CIF: A28239523
Contact: mfernandez@proinca.es

II. PURPOSE

With what intention will we be treating your personal data?

In PROMOCIONES INMOBILIARIAS CALERO, S.A. we will handle your information to:

• 1. Maintenance of the commercial relationship and provision of the contracted service.
• 2 .Preparation of an estimate tailored to your needs.
• 3. Manage e-mail communications with interested parties.
• 4. Carrying out the company's selection processes.
• 5. Management of the company's employees and human resources.
• 6. Sending commercial information related to our sector.
• 7. Control the security of the facilities (video surveillance).

For how long will we have your data?

The personal data you provide us with will be kept for as long as the current business relationship is maintained. However, in order to ensure maximum transparency with you, we would like to point out that the general computations we work with are as follows:

• - Generic identification data (e-mail, name, surname, first name, telephone number, etc.): for the duration of the business relationship or until consent is revoked. In any case, they will be deleted when they are not going to be used for the purpose for which they were collected.
• - Accounting, tax and labour: six (6) years.
• - Labour: ten (10) years.
• - Selection processes: two (2) years from the delivery of the curriculum vitae.
• - Video surveillance: thirty (30) days, unless recording an offence and/or crime.
• - Likewise, given the sending of commercial information, even if the relationship between the parties is terminated, PROMOCIONES INMOBILIARIAS CALERO SA will continue to keep your information for the sending of newsletters related to our products and services. You may always exercise the rights recognised by current legislation by contacting us through the channel that is most convenient for you

Despite the existence of these general deadlines, we will periodically review our systems to delete data that is no longer legally required.

III. LEGITIMATION

What is the legitimation for your data treatment?

Depending on the purposes for which our data is collected, the processing of your data is necessary:

• 1. To manage the business relationship, you have entered into and contracted with us.
  • a. Execution of a contract (enabled by Article 6(1)(b) GDPR).
  • b. Consent of the data subject (covered by Article 6.1.a GDPR).
• 2. Realization of a quotation tailored to your needs.
  • a. Execution of a contract and/or pre-contractual relationship (enabled by Article 6.1.b GDPR).
• 3. Manage e-mail communications with data subjects.
  • a. Consent of the data subject (enabled by Article 6.1.a GDPR)
  • b.Legitimate interest (enabled by Article 6.1.f GDPR).
• 4. To carry out the company's selection processes.
  • a. Consent of the data subject (enabled by Article 6.1.a GDPR)
• 5. Management of the company's internal human resources and employees
  • a. Contractual performance (enabled by Article 6.1.b GDPR)
• 6. Sending of commercial communications
  • a. Consent of the data subject (enabled by Article 6.1. GDPR)
  • b. Consent of the data subject (enabled by Article 20 LSSICE)
  • c. Legitimate interest (enabled by Article 6.1.f. GDPR)
• 7. To monitor the security of the premises (video-surveillance)
  • a. Legitimate interest (enabled by Article 6.1.f GDPR)

Furthermore, all data collected are necessary for the provision of the service. However, those data marked with an asterisk (*) are obligatory. In the event that the obligatory data are not provided PROMOCIONES INMOBILIARIAS CALERO SA will not be able to provide the contracted service.

IV. RIGHTS ASSISTED BY THE INTERESTED PEOPLE

What are my entitlements in relation to data protection?

In accordance with the provisions of articles 13 GDPR and 11.2.c) LOPD-GDD, you may exercise any of the following rights by contacting us at the postal address C. LÉRIDA - 8/10 PORTAL 1 BAJO, 28020 MADRID or at the e-mail address MFERNANDEZ@PROINCA.ES. In any case, according to current legislation, the following rights are recognized in accordance with the contents of articles 15 to 22 GDPR and 12 to 18 LOPD-GDD:

• Right to request access to your relative personal data.
• Right to request your rectification or erasure.
• Right to request the treatment limitation.
• Right to oppose to the operation.
• Right to the portability of your personal data.

You can use the following forms to exercise your rights more easily. You can download them by clicking here. Additionally, you can file a complaint with the Spanish Data Protection Agency (AEPD). More information in Section VII of this document.

V. RECIPIENTS

Your data will not be passed on to third party companies, unless otherwise indicated. We also inform you that your data will not be transferred internationally to any third country unless otherwise indicated.

VI PROVENANCE OF YOUR DATA

How have we obtained your data?

The personal data used by PROMOCIONES INMOBILIARIAS CALERO SA comes from the interested party, thus complying with the provisions of articles 13 GDPR and 11 LOPD-GDD already mentioned, or from companies of the group, about which you can obtain more information by writing to the e-mail address MFERNANDEZ@PROINCA.ES or at the office of the person responsible at the postal address indicated in this document.

What categories of data do we manage?

The categories of personal data handled:

• Identification details:
  • First name
  • Surname
  • DNI / NIE / Passport or equivalent document
  • Postal addresses
  • E-mail addresses
  • Gender
  • Date of birth
  • Place of birth
  • Contact telephone (mobile / landline)
• Business information
• Economic data:
  • Bank account number
  • Credit card number
• Curriculum vitae
  • Academic data
  • Qualifications
  • Hobbies
  • Membership of associations or clubs
• Video surveillance
  • Image

Unless otherwise indicated, PROMOCIONES INMOBILIARIAS CALERO SA will not process specially protected data in accordance with the provisions of articles 9 GDPR and 9 LOPD-GDD. In any case, the processing that involves the use of specially protected or sensitive data will be indicated to the interested party in this document.

VII SUPERVISORY AUTHORITY

PROMOCIONES INMOBILIARIAS CALERO SA makes every effort to comply with data protection regulations, as this is our most valuable asset. However, we inform you that in the event that you understand that your rights have been undermined, you can file a complaint with the Spanish Data Protection Agency (AEPD), located at C/ Jorge Juan, 6. 28001 - Madrid. More information about the AEPD: www.agpd.es