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.
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.
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 or via the email address firstname.lastname@example.org
What personal data may we collect through our Channels?
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.
ACCIONA Inmobiliaria may collect User data through any of our Channels, provided by the Users interested in our real estate promotions.
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.
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.
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.
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 email@example.com.
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:
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.
ACCIONA Inmobiliaria may process User data to send commercial communications regarding other real estate services and products, offers, gifts, discounts, information on participation in raffles and contests, the holding of events and fairs, or to facilitate virtual tours of the homes.
In all these cases, the legal basis for this processing is the informed, specific and express consent previously provided by the User for this purpose, in the different forms, questionnaires on the Website and in those documents in which the relationships between the users, clients and suppliers with whom the person in charge has any link, through the corresponding checkboxes and the different forms of requesting explicit consent.
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.
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.
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.
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.
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.
To whom is ACCIONA Inmobiliaria permitted to provide Users’ data?
The following data communications are planned, when necessary:
Likewise, ACCIONA Inmobiliaria would inform you that some of these service providers, third parties or 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.
In general, unless prior express and informed consent has been obtained, ACCIONA Inmobiliaria does not use Users' personal data for direct marketing purposes.
As a User, you may at any time revoke your consent or 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 relevant "unsubscribe" option or similar option included in the communication method.
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, or, by writing to the Department of Protection of Personal Data, at c/ Anabel Segura, 11, Edificio D, 28108 de Alcobendas (Madrid), or by sending an email to the following address: firstname.lastname@example.org. 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).
Observation: During periods of an exceptional nature such as States of Alarm or Emergency, which imply periods of confinement, or other external disturbances such as natural disasters, extreme weather conditions or wars, rights which are exercised by ordinary mail rather than through the email account will have a longer response time than usual, with response times being re-established once the recommended confinement period has been lifted.
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.
The User can obtain further information on the processing of personal data of ACCIONA at https://www.acciona.com/privacy-policy/
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
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/
Last updated: 29 March 2021
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