1. INTRODUCTION

Q21 Real Estate, S.L., of registered office at Camino de la Zarzuela, 15, 28023 Madrid, Spain and Tax ID Number B-87051553 (hereinafter, ‘ Q21’) takes the privacy of the personal data that it processes as a data controller very seriously, as its primary goal is to maintain the full trust of its customers and potential customers.

Therefore and in order to fully comply with General Data Protection Regulation 2016/679 (‘ GDPR’), Q21 has launched this Privacy Policy detailing its practices for the processing of personal data relating to the provision of its real estate development services, covering the entire process up to the delivery of housing or other property (the ‘ Services’).

Please read this Privacy Policy carefully and contact the Q21 Data Protection Officer if you have any questions regarding any of the practices described below. Any reference to ‘we’, ‘us’, ‘our’ or ‘Q21’ in this Privacy Policy is a reference to Q21.

2. PERSONAL DETAILS: CONCEPT, ORIGIN, LEGITIMACY AND PROCESSING

2.1. WHAT IS PERSONAL DATA?

Personal data is any data or information about an identified or identifiable individual, such as name, date of birth, postal address, e-mail address, gender, consumer status of a product or a company's customer or employee, creditworthiness, consumer habits, bank accounts and professional experience. On the other hand, it is also necessary to take into account personal data considered to be particularly sensitive personal data, which, due to its very personal nature, requires the subject or entity involved to apply more restrictive security measures to ensure not only its confidentiality but also its integrity and limited and restricted use. In addition, to collect and process these data, prior and explicit consent must always be requested, and, where applicable, compliance with the additional requirements established in the applicable regulations. Particularly sensitive personal data includes data such as ethnic or racial background, political opinions, trade union membership, religion or health, among others. Given the nature of the Services provided by Q21, we understand that we do not need to collect or process particularly sensitive data from our customers or potential customers. If, due to exceptional circumstances, Q21 needed to collect particularly sensitive data, we would first obtain the informed, free and explicit consent of those affected.

2.2. WHAT PERSONAL DATA DOES Q21 PROCESS?

Pursuant to the provision of the Services, Q21 processes the personal data of its customers or prospective customers (hereinafter: ‘ Data Subjector Data Subjects’), in order to fulfil its legal, contractual obligations and to fulfil its legitimate interests.

The personal data that Q21 may process from Data Subjects (hereinafter: ‘ Personal Data’) is as follows:

  • name and surname, age, gender, date of birth, address, nationality, marital status, ID card or passport, e-mail, telephone, voice data, calls, professional activity, family information, bank data, navigation data on the Q21 website, complementary information communicated by the Data Subject in messages with Q21, and any other data necessary for the provision of the Services.

2.3. SOURCE OF PERSONAL DATA

The source of the Personal Data accessed by Q21 may be the Data Subject or third parties. In particular, Q21 collects the Personal Data previously described in the following ways:

  1. Through third parties, such as real estate marketing companies.
  2. Directly through the Parties themselves, as a result of the formalisation of a contractual relationship and the provision of the corresponding Services.
  3. Directly, via the Q21 website or telephone calls and messages between Data Subjects and Q21. In this regard, the Data Subjects are informed that Q21 could record telephone calls and electronic messages that Q21 sends them (via e-mail, instant messaging applications, social networks or any other equivalent means that could be used), in order to serve as a means of proof of the instructions received and transactions carried out.

It is important that Data Subjects ensure that all Personal Data that they provide or have provided to Q21 is up to date. Therefore, in the event of any modification to the data previously sent by the Data Subjects to Q21 (namely those that could affect their postal address, e-mail address, contact numbers and bank details), the Data Subjects undertake to contact the Q21 Data Protection Officer for its updating.

3. PURPOSE

Q21 processes Personal Data in accordance with the purposes described below:

  1. To carry out contractual obligations with regard to the Services contracted by the Data Subjects and to comply with any other purpose connected with the provision of the Services, such as handling queries, suggestions and orders received by Q21 from the Data Subjects.
  2. Profiling the Data Subjects, based on the information available to Q21, so that Q21 can offer more personalised and appropriate processing to the interests and characteristics of the Data Subjects. It is important to mention that at no time is profiling carried out exclusively on an automated basis nor does it have legal effects on Data Subjects.
  3. With regard to the navigation data obtained through the Q21 website, ‘Cookies’, Q21 proceeds to process it in order to improve the user experience of its website; for example, the latest search criteria from users are analysed in order to present the offers of the Services that Q21 believes may be of interest to them.

    To learn more about Q21's Cookie Policy, please visit the following link https://q21realestate.es/cookie-policy/.
  4. To carry out analysis, study, evaluation, marketing, promotion, information and sending of commercial messages, with regard to the products and Services of Q21 or companies directly or indirectly owned by Q21, not only by post, telephone or fax, but also by SMS, instant messaging applications, social networks, e-mail, or any other electronic or telematic means available from time to time, under the terms set out in Article 21 of Law 34/2002, Information on Information Society Services and other applicable regulations.

    Q21 reminds you that at all times the Data Subject has the right not to receive information and advertising, particularly by electronic or telematic means, or by post. Therefore, if the Data Subject wishes to opt out and stop receiving commercial messages and advertising by electronic, telematic means or by any other available means, they may notify Q21 by sending an email to the Q21 Data Protection Officer.
  5. To comply with their legal and regulatory obligations.
  6. Performing such processing as are necessary to satisfy the legitimate interests of Q21, but ensuring that the rights and freedoms of Data Subjects are not affected.
  7. Facilitate the access of Data Subjects to commercially competitive financing conditions.

4. DISCLOSURE OF PERSONAL DATA

Furthermore, and in order to pursue compliance with the purposes set out above, Q21 may share the personal information of Data Subjects with third parties. In any event, Q21 undertakes to ensure that third party recipients of Personal Data comply with the privacy standards applied and offered by Q21. Q21 may share your Personal Information with:

  1. Companies directly or indirectly owned by Q21 for the purposes described above.
  2. Third party contributors and service providers contracted by Q21 to carry out duties related to their business. This category may include construction companies, real estate trading companies, financial services companies, banks, companies organising promotional events in the real estate sector, companies in the legal sector such as law firms or notary's offices, technology service companies, communications companies and any others that may be involved in the real estate marketing process.
  3. Relevant judicial and governmental authorities to comply with applicable laws and regulatory monitoring and reporting obligations, to respond to requests from public authorities or for other legal reasons.

5. SECURITY OF PERSONAL DATA

Q21 is very committed to the security, privacy and integrity of the Personal Data it processes belonging to its Data Subjects. For this reason, Q21 has in place and applies the highest security standards to ensure that Personal Data is handled in a fully secure manner within Q21. In particular, Q21 employs the organisational, technical and administrative measures which, in accordance with the state of the art and nature of the Personal Data applicable, guarantee full protection, integrity and confidentiality of Personal Data belonging to its Data Subjects. These also include measures to address any suspected breach of Personal Data.

6. RIGHTS OF DATA SUBJECTS

In line with the provisions of the GDPR, Q21 informs the Data Subjects that they have the following rights under it:

  • Right to access: Any Data Subject may request Q21 to confirm whether it is processing their Personal Data, to provide them with a copy of such Personal Data and to provide them with any other information about their Personal Data (what data do they have, for what they use it for, to whom they send it to, whether they transfer it to third parties, its location, how they protect it, how long they keep it for, what rights do Data Subjects have, how you may file a complaint, where your data has been obtained from), to the extent that this information has not already been provided to you in this Privacy Policy.
  • Right to rectification: Data Subjects may request that Q21 correct and update their inaccurate Personal Information.
  • Right to erasure of Personal Data: Data Subjects may require erasure of their Personal Data by Q21 when: (i) The Personal Data is no longer necessary in relation to the purposes for which it was collected, (ii) the Data Subject withdraws their consent (if the data processing is based on consent), (iii) the Data Subject exercises their right to opposition (as defined below), (iv) the Personal Data has been unlawfully processed, and (v) Q21 has to comply with a legal obligation.
  • Right to restriction: Any Data Subject may request that Q21 limit the processing of their Personal Data (i.e., retaining it but not using it) only if (i) its accuracy is disputed (see below the right to rectification), to enable us to verify its accuracy; (ii) the processing is unlawful, but the Data Subject does not want the Personal Data removed; (iii) it is no longer necessary for the purposes for which it was collected, but Q21 still needs them for the preparing, exercising or defending of legal claims; (iv) the Data Subject has exercised the right of opposition and the verification of the grounds for its opposition is pending.

    Q21 may continue to use your Personal Information after a request for restriction (i) if it has your consent; (ii) for the preparing, exercising or defending of legal claims; or (iii) to protect the rights of another individual or legal entity.
  • Right to data portability: Under certain circumstances, Data Subjects are entitled to receive their Personal Data from Q21 that is being processed in a structured, commonly used and machine-readable format. They also have the right to request the transfer of their Personal Data to another entity by Q21.
  • Right to opposition: Data Subjects may object to any processing of their Personal Data that is legally based on the ‘legitimate interests’ of Q21, if they believe that there are specific circumstances which could unreasonably affect their fundamental rights and freedoms.

    It is important to be aware that in those cases where Data Subjects exercise their right to object to the processing of such Personal Data as may be necessary to satisfy the legitimate interests of Q21 (and to comply with their legal and contractual obligations), Q21 may be unable to provide the Services to said Data Subjects.
  • Right to the opposition of sending commercial messages: Data Subjects have the right to object to the use of their Personal Data for the sending of commercial messages, including by electronic and telematic means.
  • Withdrawal of consent: Any Data Subject may withdraw their consent in connection with any processing of their Personal Data based on prior consent. Consent can be withdrawn by contacting the Q21 Data Protection Officer.
  • Right to file a complaint with the Spanish Data Protection Agency: While we prefer that Data Subjects first approach Q21 to resolve any complaints or queries, it is important that Data Subjects know that they have the right to file a complaint with the Spanish Data Protection Agency, through the contact details provided in Section 10 below.

Data Subjects may exercise their rights by contacting the Q21 Data Protection Officer, by written request duly justifying the scope of their request and attaching a photocopy of their ID or passport.

7. PERSONAL DATA STORAGE PERIOD

Q21 does not retain Personal Data on Data Subjects for longer than is necessary to meet the purposes for which it is processed.

In this regard, Q21 has a personal data retention policy in place that determines how long certain types of personal information are retained. For more information on the criteria Q21 uses to determine storage periods for personal information, please contact the Q21 Data Protection Officer.

8. CHANGES TO THIS PRIVACY POLICY

Any future privacy changes Q21 makes will be posted on its website. Please check the Q21 website often for updates or changes to our Privacy Policy.

9. Q21 CONTACT DATA DATA PROTECTION OFFICER

If you have any questions about the practices described in this Privacy Policy, you may contact the Q21 Data Protection Officer at the following addresses and telephone number:

  • rgpd@q21realestate.es / 91 514 90 05
  • Camino de la Zarzuela, 15, 28023 Madrid

The Data Subject is advised that in order for Q21 to be able to provide them with information or exercise their rights, they may need to verify their identity, request a copy of their ID card or passport, or ask for other details that will duly explain the scope of their request. We will contact you as soon as possible.

10. CONTACT DETAILS OF THE SPANISH DATA PROTECTION AGENCY

If you wish to contact the Spanish Data Protection Agency regarding any of the practices described in this Privacy Policy, you may do so via the following address and telephone numbers:

  • Agencia Española de Protección de Datos – Calle Jorge Juan 6, 28001 Madrid
  • 901 100 099 / 912 663 517

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