The security of personal data has become one of the top priorities of organizations, and in AYRE Estates, ensuring the inviolability of this information has to be a priority objective. In this sense, we want to be transparent and make available to all people who interact with us, this Privacy Policy.
This policy applies to AYRE Estates and the websites relating to AYRE Estates whose composition can be checked from time to time at: https://ayreestates.es/politica-privacidad/ (referred to as "AYRE Estates"). References in this Privacy Policy to "AYRE Estates", "we", "us", "us" and "our" refer to the entity responsible for the processing of your personal information, which will generally be the entity that collects and processes it.
AYRE Estates is a Real Estate committed to the processing of personal data in accordance with Regulation (EU) 2016/679, 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, and other current Data Protection regulations.
This Privacy Policy applies to all Users, understood as such, visitors to the website, as well as any other person who provides us with personal information through the different channels (hereinafter, "User" or "Users"). In this context, Channels are the different means or services that we make available to you so that you can interact with us, whether or not they involve registration, such as websites, applications, platforms, mailboxes, addresses or telephone numbers for information or attention to the User, profiles in social networks, forms, events, etc.
Some of our online channels may contain links to other websites and third-party applications outside AYRE Estates. This Privacy Policy does not apply to them. Please also review the Privacy Policies of such third parties in order to familiarize yourself with their practices. They may also contain cookies from third parties that are not owned or controlled by AYRE Estates. In this case you can choose your third-party Cookie settings by using our Cookie Settings Tool, located at the bottom of the website, where you can manage your preferences and which you can access by clicking on "Cookies".
AYRE Estates adopts the necessary technical and organizational measures to ensure the security of personal data and to prevent its alteration, loss, unauthorized access or processing, given the state of technology, the nature of the data and the risks to which they are exposed. You can also verify the presence of the SSL certificate by checking the properties of the Page in your browser. A connection is secure when "https://" appears in the browser address bar instead of "http://" and the padlock symbol is displayed. You can consult more characteristics of the SSL certificate in the Legal Notice section.
WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?
Whenever personal data is collected and processed, we will inform the User of the AYRE Estates Inmobiliaria company that is responsible for the processing, and we will provide the corresponding identification data.
With respect to this Privacy Policy and this website, we inform you that the data controller is:
- Company name: Asesoramiento y rentabilidad S.L.
- TAX IDENTIFICATION NUMBER: B10853786
- Address: Calle Alemania número 7, planta:5ª letra: B, 29001 , Málaga.
- Phone: +34 951 915 000
- Fax: +34 919 931 000
- Contact email: contacto@ayreestates.es
- The user may contact the Data Protection Department to resolve any doubts related to the processing of personal data at the same postal address provided or through the e-mail address contacto@ayreestates.es.
WHAT PERSONAL DATA MAY WE COLLECT THROUGH OUR CHANNELS?
For the purposes of this Privacy Policy, "personal data" is data that identifies an individual or can be used to identify an individual.
AYRE Estates informs its Users that their personal data, obtained through the Channels of its property or ownership, may only be collected for processing when they are adequate, relevant and not excessive in relation to the scope and specific, explicit and legitimate purposes for which they have been obtained.
When personal data is collected through our Channels for specific purposes, the User will be previously provided with clear and unequivocal information about i) the responsible party and its contact details, iii) the purposes of the specific processing and the basis of legitimacy, iv) the recipients or categories of recipients, if applicable, as well as the existence or not of international transfers, v) the criteria or retention periods, vi) as well as the rights that the User has as a data subject.
The User is also solely responsible for the information provided, and for the truthfulness and legality of the same.
FOR WHAT PURPOSES AND ON WHAT GROUNDS DOES AYRE ESTATES PROCESS PERSONAL DATA?
AYRE Estates treats the personal data of Users, collected through any of our Channels, for the following purposes and legitimate bases:
- Manage the relationship established with us
In those services we provide through APPs or web platforms, we process the data provided by Users in order to manage access credentials; provide assistance, answer queries, as well as manage our products and services.
We also process the data in order to respond to requests for services and requests for information from our users received through any of our channels, as well as to process suggestions, claims or complaints.
In the same way we treat your data, when you subscribe to any of our alerts channels, Newsletter, newsletters of our products and / or services, or request the sending of commercial communications.
We process your data to manage the appointments for the visits to the real estate assets, the previous documentary actions of reservation of the real estate asset, signing of earnest money and activities derived from the preparation of the sale and purchase. In short, everything related to the management for the final acquisition of the real estate asset(s).
We also process the data to manage the Customer Private Area that the Customer Service and After Sales Department makes available to customers. This service includes, among others, the After-sales function, which provides access to the incident registration service and where you can follow the process.
Management related to the service provided, such as management of collections, payments, non-payments, invoicing, accounting and tax management, financing, guarantees, warranties and taxes derived from the sale and purchase.
In these cases, the legal basis for the processing is the consent given by the User, as well as the execution of a contract and/or legal relations established with AYRE Estates.
- Promotional activities and commercial communications
We may send, by any means of communication, commercial communications, offers, gifts, sales, information about participation in sweepstakes, participation in contests, events, fairs, virtual tours of the homes, etc.
Sending promotional information about services and products by any means of communication, marketed by other companies in the AYRE Estates Group or marketed by third parties, including companies in the AYRE Estates Group provided that they have previously and expressly consented to do so..
In these cases, the legal basis for the processing is the consent given by the User.
- Manage contact data within the scope of contractual or commercial relations.
We process contact data of potential clients; legal representatives of legal entities and organizations, whether public or private; analysts and investors; or other participants, who provide us with their data, in order to send them information of interest, manage the business relationship that binds us, to manage invitations or communications about events organized or sponsored by AYRE Estates or in which it participates.
The basis of legitimacy is the maintenance of the contractual and/or commercial relationship that binds us, or if it does not exist, the consent expressed when the User provides the contact data.
- Compliance with the legal obligations that affect us.
Whether these legal obligations are of a commercial, fiscal, accounting or administrative nature, the legal basis that enables us to carry out this processing is the fulfillment of legal obligations.
- Fraud management
In some of the services we provide, it is necessary to verify identity in order to provide protection, detect and prevent fraud or other illegal activities, unauthorized transactions, claims and other types of liabilities, as well as to manage the quality and risks associated with the business; as well as to investigate, if necessary, illegal activities and potential violations of our policies and/or conditions of our services.
The legal basis is compliance with the legal obligations applicable in each case. Among others, and by way of example, Law 10/2010 of April 28, 2010 on the Prevention of Money Laundering and Terrorist Financing.
- Statistics and satisfaction surveys
We may process the data Users' data in order to carry out satisfaction surveys in relation to our services and, experience in the process of buying your home, as well as cookies collected through navigation in web environments.
The legitimate basis in these cases is the consent given by the User.
- Security and surveillance of facilities
Our facilities are equipped with cameras and video surveillance systems, in order to safeguard the security of goods and people.
The legitimate basis for the processing is the legitimate interest of AYRE Estates in ensuring the security of its facilities.
- Visitor and third party management
In order to control access to the works and facilities of visitors, collaborators or other third parties, it is possible that, in some of our facilities, identification data may be collected.
The legitimate basis is, in this case, consent, as well as the legitimate interest of AYRE Estates, in ensuring the safety of goods and people in their facilities.
- Information from third parties
When the User provides us with data regarding third parties, either voluntarily or because we require it in compliance with any legal obligation, the User consents to the processing and declares that the data are accurate. Likewise, the User declares that he/she has proceeded to inform the third parties of the content of this policy and/or that which applies to him/her and of which he/she has been specifically informed, and of the corresponding rights they are entitled to with regard to the Protection of Personal Data. Notwithstanding the foregoing, AYRE Estates will make every effort to act properly in relation to the treatment of such third parties.
- Public information
AYRE Estates may process information to which it may have access because it is information that is legitimately accessible to the public, and in particular, public information that is available in official records. In any case, this treatment will only be carried out if there is a legitimate basis of those listed in the applicable regulations and, whenever possible or if there is a contractual relationship, you will be informed.
HOW LONG DOES AYRE ESTATES KEEP THE USER'S PERSONAL DATA?
In general, the data will be kept (i) for the time necessary for the purpose for which they were collected, (ii) for the applicable statute of limitations, if any liabilities may arise from the processing.
On an individual basis:
- The data collected for the purpose of responding to requests or inquiries, will be retained for the time necessary to respond to them.
- Data collected on the basis of your consent will be retained until you withdraw your consent.
- In all other cases, the User will be informed of the retention periods applicable to the specific processing.
TO WHOM CAN AYRE ESTATES PROVIDE THE USER'S DATA?
AYRE Estates undertakes not to transfer or disclose the personal information of our users except as described in this Privacy Policy or, where appropriate, at the time of data collection.
The following data communications are foreseen, when necessary:
- To the Tax Agency and other competent state, autonomous and local public administrations and entities for the purpose of observing all the legal provisions contained in the regulations and to carry out the corresponding tax declarations (taxes and fees), obtaining licenses and administrative authorizations, notifications of cadastral ownership of real estate assets, domiciles of the owners, also allowing the management of obligations related to the Real Estate Tax and the Tax on the Increase in Value of Urban Land.
- Other agencies with competence in the area of communications and information services, or agencies with competence in the area of consumer affairs to deal with possible complaints from users.
- If applicable, to Official Bodies in compliance with the Entities obliged by virtue of Law 10/2010, of April 28, 2010, on the prevention of money laundering and financing of terrorism.
- To banks and credit institutions for the economic management of the purchase and sale operations including financing, mortgage subrogations, guarantees and endorsements.
- To Insurance Brokers and Insurance Companies by virtue of Law 38/1999, of November 5, 1999, on Building Regulation and for the purpose of allowing the management of the activities necessary for the contracting of insurance policies for the amounts paid on account as a consequence of the acquisition of a real estate asset.
- To the Administrators of properties that manage or intend to manage initially the communities of neighbors constituted or to be constituted, in relation to the corresponding housing development.
- We may exchange personal information with service providers, whether AYRE Estates Inmobiliaria companies or third parties, contracted to perform services on our behalf. In these cases, whenever necessary, the corresponding processing assignment contracts are signed according to the regulations on data protection. For example, entities involved in the construction of the real estate asset and in the processes of review of its adequacy, for the purpose of managing the performance of work, prior or subsequent to the delivery of the real estate asset to the purchaser, which require or involve the intervention of these for the purpose of its development.
- Likewise, your data may be communicated to other entities that are part of the AYRE Estates Group, including those located in third countries in order to respond to your requests and send you by any means, including electronic means, commercial information and any other action described in the purposes previously described. Consent for such communications will have been obtained previously, in the different forms, questionnaires of the Page and in those documents in which the relationships between users, customers and suppliers with whom the responsible has any link, through the corresponding check boxes and the different forms of requesting explicit consent.
- In case of non-payment, the data related to the non-payment of bills may be communicated to files related to the fulfillment or non-fulfillment of monetary obligations.
- We reserve the right to transfer to a third party any information we have about Users in the event of any actual or potential transfer or sale of all or part of our business or assets (including in the event of a merger, acquisition, joint venture, restructuring, divestiture, dissolution or liquidation) or other structural or business transaction. In such an event, such third parties will be required to ensure levels of protection comparable to those provided by AYRE Estates with respect to the information to be shared.
- Other than in these cases, we may only disclose your personal information (1) to courts and tribunals or administrations in the exercise of their administrative powers and authorities, if we are permitted or required to do so by law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other public officials in order to comply with a lawful and legitimate request; (3) when we believe it is necessary to prevent physical harm or financial loss; (4) to establish, exercise or defend our legal rights; (5) in connection with an investigation of suspected or proven fraud or illegal activity; or (6) with the consent of the User.
We also inform you that in order to carry out the aforementioned purposes, we rely on the collaboration of service providers, third parties or Group companies that may be located in territories outside the European Economic Area that do not provide a level of data protection comparable to that of the European Union. In such cases, we transfer Users' data with adequate guarantees and always safeguarding their security, such as the formalization of Standard Contractual Clauses approved by the Commission, the content of which can be consulted at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_es.
SOCIAL NETWORKS
In AYRE Estates we use social networks such as LinkedIn, Twitter, Facebook, Google+, Instagram or YouTube, to share our content. We act in the networks as responsible for the data we publish, always treating them according to the conditions established in each of the social networks.
The interaction with Users through the use of such profiles or tools may involve the international transfer of data, of an analytical and technical nature, in relation to the Page and the social network profiles, being on the servers of the social network companies where the data provided by Users through such profiles are processed.
PERSONAL DATA OF MINORS
AYRE Estates does not deliberately collect personal data from minors without the authorization of their parents, representatives or legal guardians. None of the Channels made available to the User by AYRE Estates, are designed or directed to minors.
If parents, representatives or legal guardians believe that their minor children have provided personal information without their consent, please contact us by e-mail at protecciondedatosinmobiliaria@ayreestates.es.
DIRECT MARKETING
In general AYRE Estates does not use the personal data of Users for direct marketing purposes, unless prior consent has been obtained.
As a User you may, at any time, unsubscribe from direct marketing campaigns and object to the future processing of your personal data for such purposes by sending us an e-mail to the address of the data controller or by using the corresponding "unsubscribe" option included in the e-mails.
AUTOMATED DECISIONS
In AYRE ESTATES, the automation of decision making, including profiling, is carried out.
ATTENDEES AT EVENTS ORGANIZED BY AYRE ESTATES
In those events, trainings, meetings, initiatives, etc. (hereinafter "Events"), which are organized or promoted by AYRE Estates, inside or outside its facilities, we may ask the user to provide personal data in order to properly manage the events and attendance to them. These data, including but not limited to, may be related to the management of access, accreditation, transportation and travel, accommodation, catering, delivery of related documentation, etc.. This treatment will be based on consent, as well as, in certain cases, in compliance with a contractual relationship or a legal obligation.
This data may have to be transferred to any of the service providers or collaborating or sponsoring entities, which participate or intervene in the Event. As a general rule, we will only keep this information for the period of time strictly necessary to carry out the Event. of which the User will be duly informed in each case.. As a general rule, we will only keep this information for the time strictly necessary to carry out the Event and, where appropriate, to comply with any statute of limitations that may apply.
Image: In addition to the treatment derived from the security and surveillance of our facilities, it may be that, as a result of the User's participation in Events, his image, and sometimes his voice, is captured and treated by AYRE Estates through photographs and or video recording. Whenever the Events involve this treatment, we will expressly inform the User. This treatment may be for internal, external and / or promotional purposes of the Events, so that such material may be used to reproduce, distribute, transform, publicly communicate, fix it and make it available in any format or medium (including but not limited to, exploitation through analog or digital media and the Internet, such as social profiles, websites or intranet owned by AYRE Estates Group entities) without such activities confer any right of remuneration, consideration or economic benefit to the User.
This treatment is based on the consent, either derived from the individual and express granting, whenever possible, by the User, or from the attendance to the Events whose image treatment has been previously informed. The User's authorization extends to the worldwide territorial scope, with a transferable character (inside and outside AYRE Estates) and for the entire duration of the intellectual property rights. The User may revoke consent at any time, through the appropriate channels.
The intellectual and industrial property rights of the materials generated on the occasion of the events and activities correspond exclusively to AYRE Estates.
WHAT ARE YOUR RIGHTS WHEN WE PROCESS YOUR DATA?
Users may exercise their rights of access, rectification, deletion, portability of their data, and/or limitation or opposition to its processing, before the corresponding data controller, or by writing to the Personal Data Protection Department, at Calle Alemania number 7, planta:5ª letra: B, 29001 , Málaga, or by sending an e-mail to the following address: protecciondedatosinmobiliaria@ayreestates.es. In case we consider necessary to identify you, we may request a copy of a document proving your identity.
You may also, at any time, withdraw the consent given by contacting the above address, as well as to file a complaint with the relevant Data Protection Control Authority and, in particular, with the Spanish Data Protection Agency (www.aepd.es).
Observation: During periods of exceptionality such as States of Alarm or Emergency, involving periods of confinement, or other external disturbances such as natural disasters, extreme weather conditions or wars rights that are not exercised through the mail account and are exercised through regular mail will have a longer response time than usual, with response periods being reestablished when the recommended period of confinement is lifted.
MORE INFORMATION
Below, we provide you with a series of links where you can obtain further information that may be useful to you in relation to other processing of personal data. You can also obtain information about the website in the Legal Notice.
- Consulting and profitability S.L.
Further information on the processing of personal data by ASE entities is available at www.ayreestates.es.
- Candidates
Through our Employment Channel, any interested party can apply for job vacancies, scholarships and/or specific programs. Complete information about this treatment can be found at: https://ayreestates.es/politica-de-privacidad/
- Ethical channel
We have a whistle-blowing channel, called the Ethics Channel, through which employees, suppliers and third parties can confidentially report any non-compliance of which they may become aware. You can consult the complete information on this treatment at: https://ayreestates.es/politica-de-privacidad/
CURRENT
Any changes made to the Privacy Policy and information management practices will be reflected in a timely manner, and AYRE Estates may add, modify or replace such Policy as it deems necessary.