Privacy Policy

Privacy and Data Protection Policy

The security of personal data has become one of the top priorities for organisations and along with ensuring the inviolability of this information, it must be a priority objective for us. In this sense, we wish to be transparent and make this Privacy Policy available to everyone who interacts with us.  

This policy applies to all the companies that make up ACCIONA's real estate business (collectively called “ACCIONA Inmobiliaria”), whose structure can be checked at any time at https://inmobiliaria.acciona.com/about-us/inmobiliaria/. The references in this Privacy Policy to "ACCIONA Inmobiliaria", "we", "us" and "our" concern the Data Controller in charge of processing your personal information, which, in general, will be the entity that collects, processes and at any time identifies this information. This Policy has a global reach since each time we collect your data, we will provide you with specific information on the treatment.

ACCIONA Inmobiliaria undertakes to process personal data in accordance with Regulation (EU) 2016/679 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, in conformity with and with respect for the applicable local legislation in each case, meaning that in some jurisdictions this Policy could be supplemented by the corresponding local regulations.

This Privacy Policy is applicable to all Users, these being understood to be visitors to the website, as well as any other person who provides us with personal information through the various channels (hereinafter, "User" or "Users"). In this context, with Channels we understand to be a reference to the various means or services that we make available to you so the User can interact with us, whether or not they involve registration, such as websites, applications, platforms, mailboxes, addresses or telephone numbers for the provision of information or assistance to Users, profiles on social networks, forms, events, etc.  

Some of our Online Channels may contain links to other non-ACCIONA Inmobiliaria third party websites and applications. This Privacy Policy does not apply to these. Please also review the privacy policies of such third parties to familiarise yourself with their practices. They may also contain cookies from third parties that are not owned or controlled by ACCIONA Inmobiliaria. In this case you can choose your third party cookie settings by using our Cookie Settings Tool, where you can manage your preferences, which you can access by clicking on "Cookies".  

ACCIONA Inmobiliaria adopts the technical and organisational measures necessary to guarantee the security of personal data and to prevent the alteration, loss or unauthorised processing of or access to such data, taking into account the state of the art, the nature of the data and the risks to which the data are exposed. You may also confirm the presence of the SSL certificate by checking the Website’s properties in your browser. A connection will be secure when "https://" appears in the browser's address bar instead of "http://" and a padlock symbol is displayed. You can look up more features of the SSL certificate in the Legal Notice section. 

 

Who is in charge of processing the personal data?

Whenever personal data are collected and processed, we shall inform the User of the ACCIONA Inmobiliaria company which is the Data Controller in charge of processing, and we shall provide the corresponding identifying data.   

With regard to this Privacy Policy and this website, we would inform you that the Data Controller in charge of processing is: 

• Company name: Acciona Inmobiliaria, S.L.U.
• Tax ID: B84364579
• Address: Gran Vía de Hortaleza, 3, Campus ACCIONA, 28033 (Madrid)
• Telephone: +34 91 663 29 50
• Contact e-mail address: contactoinmobi@acciona.es

Regardless of the ACCIONA Inmobiliaria company that is responsible for the processing in each case, the user may contact the Data Protection Department to resolve their questions related to the treatment of this at the postal address indicated above, via the email address protecciondedatosinmobiliaria@acciona.com or by filling out this form.

 

What personal data may we collect through our Channels? 

For the purposes of this Privacy Policy, "personal data" are data that identify a person or can be used to identify them.   

ACCIONA Inmobiliaria hereby informs its Users that their personal data, obtained through the Channels owned by ACCIONA, may only be collected for processing when they are adequate, relevant and not excessive in relation to the specific, explicit and legitimate scope and purposes for which they were obtained.   

Whenever personal data are collected through our Channels for specific purposes, Users will be provided beforehand with clear and unequivocal information on i) the Data Controller and its contact details, iii) the specific purposes of the processing and the basis for the legitimacy thereof, iv) the recipients or categories of recipients, where applicable, as well as the existence or not of international transfers, v) the storage criteria or periods, vi) and the rights enjoyed by Users in their capacity as data subjects.  

 

Users are also solely responsible for the information provided, and for the veracity and legality of the same.  

• User data

ACCIONA Inmobiliaria may collect User data through any of our Channels, provided by the Users interested in our real estate promotions.

• Customer data

ACCIONA Inmobiliaria may also collect the personal data of its Clients to provide the different services reported in each case, among others, the Post-Sales function. 

• Information from third parties

Whenever Users provide us with data concerning third parties, either voluntarily or because we require such data to comply with any legal obligation, Users consent to the processing and declare that the data are accurate. Likewise, Users declare that they have informed the third parties of the content of the present policy and/or of the policy that applies to them and of which they have been specifically informed, and of the corresponding rights relating to the Protection of Personal Data that are enjoyed by them. Notwithstanding the foregoing, ACCIONA Inmobiliaria will use its best efforts to act appropriately in relation to the processing of [the data of] such third parties.

• Public information 

ACCIONA Inmobiliaria may process information to which it may have access as information that is lawfully accessible to the public, and in particular, public information that is available in official registers. This processing will in any event only be done if there is a legitimate basis as set out in the applicable regulations and, whenever possible or where there is a contractual relationship, you will be informed.

• Personal data of minors

ACCIONA Inmobiliaria does not knowingly collect personal data from minors without the consent of their parents, guardians or legal representatives. None of the Channels made available to Users by ACCIONA Inmobiliaria are designed for or directed at minors.   

If parents, guardians or legal representatives believe that their minor children have provided personal information without their consent, please contact us by e-mail at protecciondedatosinmobiliaria@acciona.com, or by filling out this form.

 

For what purpose and legitimate reasons does ACCIONA Inmobiliaria process personal data? 

ACCIONA Inmobiliaria processes the personal data of Users, collected through any of our Channels, for the purposes and on the legitimate bases as set out in detail and notified for each specific processing operation; however for your information only, we have set out some of these, which are more general in scope, below:

 

• To manage the relationship established with us

o   For those services that we provide through APPs or online platforms, we process the data provided by Users in order to manage access credentials, provide assistance, answer queries, and manage our products and services. 

o   In this sense, we will also process the data provided in order to respond to requests for services and requests for information from our Users received through any of our Channels, and to be able to deal with any suggestions, claims or complaints, where applicable.

o   We process your data to manage appointments for visits to real estate assets, for prior documentary actions for the reservation of real estate assets, to deposit signature and for activities derived from the preparation of the sale. In short, everything related to the management for the final acquisition of the real estate asset(s).

o   We also process the data to manage the Private Area of customers that the Customer Service and Post-Sales Department makes available to Users. This service has, among others, the Post-Sales function, where access is given to the incident registration service and where they can follow their process. This processing has its specific informative clause available to customers in the Private Area.

o   Procedures related to the service provided, such as management of collections, payments, defaults, billing, accounting and tax management, financing, guarantees and taxes derived from the sale.

o   We can process User data for satisfaction surveys regarding our services and experience in the process for the purchase of your property may be processed.

In all of these cases, the legal basis for the processing is the execution of a contract or pre-contractual measures and/or the maintenance of the relationships established with ACCIONA Inmobiliaria.

 

• Promotional Activities and Commercial Communications

• If you contact us to obtain information about our real estate developments through the forms provided for this purpose, we may process your data in order to deal with and manage your queries, requests, complaints, suggestions, visits or calls, as well as to send, by any means, including electronic, information about our developments, offers and products of Acciona Inmobiliaria S.L.U. and about developments of other entities of ACCIONA's real estate business.  At the time of collecting your data, you will be provided with information about these entities of ACCIONA's real estate business.

The legal basis for the processing of data is the consent of the data subject when communicating with us through the information request form.

You may unsubscribe at any time by sending an e-mail to protecciondedatosinmobiliaria@acciona.com or by filling out this form.

• ACCIONA Inmobiliaria may use your data to send commercial information through any channel (email, SMS, push notifications, etc.) about products and services marketed by other ACCIONA GROUP businesses, without this implying the transfer of your personal data. At the time your consent is obtained, you will be provided with information about these ACCIONA GROUP business entities.

The legal basis for the processing of the data is the consent given by the interested person by ticking the appropriate box below the information request form or the consent given by ticking the appropriate box in the document that will be provided via e-mail during the signature process of the sales and purchase documentation by the Client.

You may unsubscribe at any time by sending an e-mail to protecciondedatosinmobiliaria@acciona.com or by filling out this form.

• ACCIONA Inmobiliaria may process the data of its Clients to send commercial communications regarding other real estate services and products, offers, gifts, sales, information on participation in raffles and contests, events and fairs, or to provide virtual tours of the homes.

The basis of legitimacy of this treatment is the maintenance of the contractual and/or commercial relationship authorized by article 21.2 of the Law of Services of the Information Society and the legitimate interest of the entity. You may request opposition to this treatment and unsubscribe by sending an email to the email address protecciondedatosinmobiliaria@acciona.com.

 

• To manage contact details within the scope of contractual or commercial relationships

We process contact details of potential partners, legal representatives of legal entities and organisations, whether public or private, analysts and investors or other concerned parties who provide us with their details, this in order to send them information of interest, to manage the commercial relationship that binds us and to be able to manage invitations or communications about events organised or sponsored by ACCIONA Inmobiliaria or in which ACCIONA participates.

The basis for the legitimacy of such purposes is maintaining the pre-contractual, contractual and/or commercial relationship that binds us.

 

• Compliance with the legal obligations incumbent upon us.

Whether these legal obligations are of a commercial, fiscal, accounting or administrative nature, the legal basis authorising us to carry out this processing is compliance with legal obligations.

 

• Fraud management

For some of the services that we provide, it is necessary to check on people’s identity in order to offer protection, detect and prevent fraud or other unlawful activities, unauthorised transactions, claims and other types of liabilities, and to manage quality and business-associated risks, and to investigate, where necessary, illegal activities and potential breaches of our policies and/or the terms and conditions of our services.

The legal basis is compliance with the legal obligations that apply in each case. Inter alia, and by way of an example, Law 10/2010 of 28 April on the Prevention of Money Laundering and the Financing of Terrorism.

 

• Security and surveillance of facilities

Our facilities are equipped with cameras and video surveillance systems, with the aim of safeguarding the security of goods and people. 

The legitimate basis for the processing is ACCIONA Inmobiliaria's legitimate interest in ensuring the security of its facilities.

 

• Visitor and third party management

o   Access to the facilities of ACCIONA Inmobiliaria In order to control the access of visitors, collaborators or other third parties to facilities, it is possible that, at some of our facilities, identification data may be collected. 

The legitimate basis is in this case consent, as well as ACCIONA Inmobiliaria's legitimate interest in ensuring the security of goods and people at its facilities.

o   Visits to Points of Sale and Pilot Flats. Only the data necessary to manage appointments for visits to real estate assets will be collected.

In the event that, for security reasons, a special protocol is established that involves the processing of other personal data, they will be specifically and previously communicated.

 

How long does ACCIONA Inmobiliaria keep Users’ personal data?

In general, the data will be kept i) for as long as is necessary for the purpose for which the data were collected and ii) for the applicable limitation periods, if liabilities might be incurred as the result of the processing.

Specifically:

• The data collected for the purpose of responding to requests or enquiries will be kept for the time necessary to be able to attend to the same, but never for longer than twelve months.
• The data collected based on your consent will be kept for as long as such consent is not withdrawn.
• The data for the provision of the services/information requested about our promotions through the websites, sales booths and call centres will be kept for the duration of the contractual relationship; If you wish, you may request the deletion of your data in the legally permitted cases.
• The data when you register as a client on the web/after sales service/customer service, as long as you keep your User account as a Customer. If desired, the User may request the cancellation of the service and deletion of their data.
• In all other cases, the User will be informed of the retention periods that apply to the specific treatment (prescribed for money laundering, latent defects insurance, and other applicable regulations).

 

To whom is ACCIONA Inmobiliaria permitted to provide Users’ data? 

At ACCIONA Inmobiliaria, we undertake not to transfer or disclose our Users’ personal information except as described in this Privacy Policy or, where applicable, as might be indicated at the time of collection of the data. 

The following data communications are planned, when necessary:

• To the Tax Agency and other Administrations and competent state, regional and local public entities for the purposes of observing all the legal provisions contained in the regulations and to carry out the corresponding tax returns (taxes and fees), obtaining licenses and administrative authorizations, notifications of cadastral ownership of real estate assets, owners' addresses, also allowing the management of obligations related to the Real Estate Tax and the Tax on the Increase in the Value of Urban Land.
• Other Administrative Bodies with competence in matters of communications and provision of information services, or Administrative Bodies with competence in consumer matters to deal with possible claims from users.
• Where appropriate, to Official Administrative Bodies in compliance with the Entities obliged by virtue of Law 10/2010 of April 28 on the prevention of money laundering and terrorist financing.
• To banks and credit entities for the economic management of sale and purchase operations including financing, mortgage subrogations, guarantees and endorsements.
• To insurance brokerages and insurance companies by virtue of Law 38/1999 of November 5 on Building Planning and for the purpose of allowing the management of the activities necessary for contracting insurance policies of the amounts paid on account as a result of the acquisition of a real estate asset.
• To the Property Administrators who initially manage or intend to manage the communities of neighbours constituted or to be constituted, in relation to the corresponding housing development.
• We may exchange personal information with service providers, who are either ACCIONA Inmobiliaria https://inmobiliaria.acciona.com/about-us/inmobiliaria/ companies or third parties and are in some cases contracted to perform services on our behalf. In these cases, the corresponding data processor agreements are signed whenever necessary, as established by the regulations on matters relating to data protection.
• Likewise, your data may be communicated to other Entities that are part of the ACCIONA's real estate business, including those located in third countries in order to meet your requests and send you by any means, including electronic means, commercial information and any other action for the purposes previously described with the consent of the User.
• In the event that payments are not made, the data related to the non-payment of receipts may be communicated to files related to the fulfilment or non-fulfilment of monetary obligations.
• We reserve the right to transfer to a third party any information we hold 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 any merger, acquisition, joint venture, restructuring, assignment, dissolution or liquidation) or other structural or business operation. In this case, such third parties will be required to ensure levels of protection comparable to those provided by ACCIONA Inmobiliaria with respect to the information to be shared.
• Outside of these cases, we will only be able to communicate your personal information (1) to courts and tribunals or administrations in the exercise of their administrative powers and powers, if we are permitted or required to do so by law or by a process of law (such as a court order or subpoena); (2) to law enforcement agencies or other public officials to comply with a lawful and legitimate request; (3) whenever we consider this 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 actual fraud or illegal activity; or (6) with Users’ express and informed consent. 

Likewise, ACCIONA Inmobiliaria would inform you that some of these service providers, third parties or ACCIONA Group companies 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 appropriate safeguards, maintaining at all times the security of such data; these may include the formulation of Standard Contractual Clauses approved by the Commission, the content of which may be examined by clicking on the following link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_es

 

Social networking sites.

 At ACCIONA Inmobiliaria we use social networks such as LinkedIn, Twitter, Facebook, Google+, Instagram or YouTube to share our content. We act in such networks as the Data Controller in charge of the data published by us, always processing such data in accordance with the terms and conditions established for each one of the social networks.  

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 Site and the social network profiles, with the data provided by Users through such profiles being processed on the servers of the social network companies.

 

Automated decisions.

ACCIONA Inmobiliaria does not automate decision-making, nor does it create profiles.

 

Attendance at ACCIONA Inmobiliaria Events

At those functions, training sessions, meetings, initiatives, etc. (hereinafter, “Events”) that are organised or promoted by ACCIONA Inmobiliaria at or away from its facilities, we may request Users to provide us with personal data in order to properly manage the Events and attendance at them. As an illustration, the subject matters that these data may be related to include but are not limited to the management of access, accreditation, means of transport and travel, accommodation, catering, delivery of related documentation, etc. This processing will be based on consent, moreover in certain cases, on the performance of a contractual relationship or statutory obligation.  

This data may have to be transferred to any of the service providers or collaborating or sponsoring entities that participate or are involved in the Event, and Users will in each case be duly informed of this. As a general rule, we will only keep this information for the period of time strictly necessary to hold the Event and, where applicable, to comply with the limitation periods that may prove to be applicable. 

Image: In addition to the processing done as the result of the need to ensure the security and surveillance of our facilities, it is possible that, as a consequence of Users’ participation in Events, their image, and on occasions their voice, may be captured and processed via photographs and/or video recording. Where Events entail such processing, we shall expressly inform Users. This processing may be for internal or external purposes and/or for the purposes of promoting Events; consequently the said material could be used to reproduce the Event, distribute or transform it, communicate it publicly, set a date for it and make it available in any format or medium (including, as an illustration, but not limited to exploitation through analog or digital means and online, such as social profiles, websites or intranet owned by ACCIONA Inmobiliaria and Acciona S.A.), without the said activities conferring any right to remuneration, consideration or economic gain on Users.

This processing is based on consent, either, whenever possible, as the result of Users giving their individual, explicit consent, or from their attendance at Events for which they were informed beforehand of the processing of their image. Users’ authorisation extends worldwide, is transferable and remains in place for the entire duration of the intellectual property rights. Users may withdraw their consent at any time, through the appropriate channels. 

The intellectual and industrial property rights over the materials generated on the occasion of the events and activities accrue exclusively to ACCIONA Inmobiliaria.

 

What are Users’ rights whenever we process their data?

The User can exercise their rights of access, rectification, deletion, portability of their data, and/or the limitation or opposition to their treatment, before the person responsible for the corresponding treatment, by sending an email to the following address: protecciondedatosinmobiliaria@acciona.com or by filling out this form. If we consider this necessary to be able to identify you, we may request a copy of a document that proves your identity.  

You may likewise, at any time, withdraw the consent given by writing to the above address, and by filing a complaint with the relevant data protection Supervisory Authority and, in particular, the Spanish Data Protection Agency (www.aepd.es).

 

Related information:

We have provided you below with a series of links where you can obtain further information that might be of use to you in relation to any other processing of personal data, You can also find information about the website in the Legal Notice.   

• ACCIONA

The User can obtain further information on the processing of personal data of ACCIONA at https://www.acciona.com/privacy-policy/ 

• Applicants 

Any interested party can apply for job vacancies, scholarships and/or specific programmes through our Employment Channel. You can consult the information on this processing is available at: https://mediacdn.acciona.com/media/evmpl11q/politica-privacidad-candidatos-en.pdf

• Ethical channel 

We have a reporting channel, known as the Ethical Channel, in which both employees and providers or third parties can confidentially report any breach of which they are aware. You can consult the complete information regarding this treatment at https://www.acciona.com/shareholders-investors/corporate-governance/rules-governance/compliance/

 

Validity

If any change is made to the Privacy Policy and to information management practices, this will be reflected in a timely manner, however ACCIONA Inmobiliaria may supplement, amend or replace the said Policy whenever it considers this necessary.

This Privacy Policy is published in Spanish and English; in case of any discrepancy between the two versions, the Spanish version will prevail.

 

 

Last updated: November 2023