Privacy Policy

PERSONAL DATA PROTECTION POLICY

ZONA ALTA MG REAL ESTATE S.L. is an Organization that collects, through the various means at its disposal, personal data, which attributes to it an important responsibility in the design and organization of procedures, so that they are aligned with legal compliance in Data Protection. Therefore, ZONA ALTA MG REAL ESTATE S.L. will adopt all necessary security measures to ensure the protection of the data collected.

In the exercise of these responsibilities, and with the purpose of establishing the general principles that must govern the processing of personal data in the Organization, ZONA ALTA MG REAL ESTATE S.L. approves this Personal Data Protection Policy, which it notifies and makes available to all its Interest Groups, also respecting the following regulations:

  • 1. 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 (GDPR).
  • 2. Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights (LOPD-GDD).
  • 3. Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

I. SCOPE OF APPLICATION

This Personal Data Protection Policy will apply to ZONA ALTA MG REAL ESTATE S.L., its management, direction and staff bodies, as well as to all persons who relate to the Organization, with express inclusion of service providers with access to data ('Data Processors').

The controller of the personal data collected in the Organization is: ZONA ALTA MG REAL ESTATE S.L., with NIF: B64581770, whose representative is: MANUEL GIRÓ DE LA IGLESIA (hereinafter, Data Controller). Their contact details are as follows:

Address: C/ MIQUEL GUANSÉ, S/N, VILANOVA I LA GELTRU, BARCELONA, 08800

Contact phone: 932030808

Contact email: [email protected]

II. INFORMATION ON THE CONTROLLER AND PROCESSING OF PERSONAL DATA IN ZONA ALTA MG REAL ESTATE S.L.

Additional information on data processing is a set of more specific and expanded details that entities must provide to data subjects about how their personal data is managed. This concept derives from the principle of transparency of the General Data Protection Regulation (GDPR) and complements the basic information initially provided, providing a greater level of detail on processing.

Below, ZONA ALTA MG REAL ESTATE S.L. provides additional information on the data processing it carries out:

Additional information on Data Protection
DATA ON THE DATA CONTROLLER
Identity ZONA ALTA MG REAL ESTATE S.L.
Address C/ MIQUEL GUANSÉ, S/N, VILANOVA I LA GELTRU, BARCELONA, 08800
Contact phone 932030808
Email [email protected]
PURPOSES OF PERSONAL DATA PROCESSING
Data processing Processing purpose Retention period
SUPPLIERS CUSTOMER MANAGEMENT, ACCOUNTING, TAX AND ADMINISTRATIVE CUSTOMER MANAGEMENT: Data must be kept for the time necessary to comply with legal obligations. This period is generally set at 5 years for accounting and tax obligations. ACCOUNTING: Accounting documentation is usually kept for 6 years, as established in applicable tax and accounting regulations. TAX AND ADMINISTRATIVE: For tax obligations, the retention period is generally set at 4 years, following current tax regulations.
HR PAYROLL MANAGEMENT, OCCUPATIONAL RISK PREVENTION, HUMAN RESOURCES Payroll management: four years. Occupational risk prevention: four years. Human resources: four years.
WEB FORM PROFESSIONAL CONTACT, CUSTOMER MANAGEMENT, ACCOUNTING, TAX AND ADMINISTRATIVE, ADVERTISING AND COMMERCIAL PROSPECTING PROFESSIONAL CONTACT: Two years after the end of the relationship. CUSTOMER MANAGEMENT: Five years after ceasing to be a customer. ACCOUNTING, TAX AND ADMINISTRATIVE: Six years according to tax regulations. ADVERTISING AND COMMERCIAL PROSPECTING: Until consent is revoked.
CURRICULUM HUMAN RESOURCES Four years.
CLIENTS CUSTOMER MANAGEMENT, ACCOUNTING, TAX AND ADMINISTRATIVE, ADVERTISING AND COMMERCIAL PROSPECTING CUSTOMER MANAGEMENT: 6 years. ACCOUNTING, TAX AND ADMINISTRATIVE: 6 years. ADVERTISING AND COMMERCIAL PROSPECTING: While the commercial relationship is maintained or deletion is not requested.
LEGITIMACY OF PERSONAL DATA PROCESSING
Data processing Legitimacy
SUPPLIERS Performance of a commercial/sales/service provision contract
HR Performance of an employment contract and legal obligation: labor legislation
WEB FORM Express consent of the data subject
CURRICULUM Express consent of the data subject
CLIENTS Performance of a sales contract and similar contracts
RECIPIENTS OF YOUR PERSONAL DATA
Data processing Expected transfers International transfers
SUPPLIERS PUBLIC ADMINISTRATION WITH COMPETENCE IN THE MATTER, BANKING OR FINANCIAL ENTITIES No
HR PUBLIC ADMINISTRATION WITH COMPETENCE IN THE MATTER, BANKING OR FINANCIAL ENTITIES, ENTITIES OF THE SAME BUSINESS GROUP No
WEB FORM No transfers are expected No
CURRICULUM No transfers are expected No
CLIENTS PUBLIC ADMINISTRATION WITH COMPETENCE IN THE MATTER, BANKING OR FINANCIAL ENTITIES No
RIGHTS THAT CORRESPOND TO YOU AND MEANS AT YOUR DISPOSAL

Any person has the right to obtain confirmation as to whether ZONA ALTA MG REAL ESTATE S.L. is processing personal data concerning them.

Data subjects have the right to access their personal data, as well as to request the rectification of inaccurate data, or, where applicable, to request their deletion when, among other reasons, the data are no longer necessary for the purposes for which they were collected.

In certain circumstances, data subjects may request the limitation of the processing of their data, in which case we will only keep them for the exercise or defense of claims, as well as to comply with legally established retention periods.

Likewise, data subjects may object to the processing of their personal data. Therefore, ZONA ALTA MG REAL ESTATE S.L. will stop processing their data, except for legitimate and compelling reasons, or in the exercise of possible claims.

In the same sense, when certain circumstances occur and it is technically possible, data subjects will have the right to have their personal data transmitted directly to another controller or processor, upon request.

To exercise the rights indicated above, you must contact us, by sending a written request to:

· ZONA ALTA MG REAL ESTATE S.L. C/ MIQUEL GUANSÉ, S/N, VILANOVA I LA GELTRU, BARCELONA, 08800, or by email to [email protected]. We recommend accompanying your request with a copy of your ID card.

III. PRINCIPLES APPLICABLE TO PERSONAL DATA PROCESSING

The Personal Data Protection Policy is a proactive Responsibility measure, which aims to ensure compliance with applicable legislation in this matter and, in relation to this, respect for the right to honor and privacy in the processing of personal data of all persons who relate to ZONA ALTA MG REAL ESTATE S.L.

In development of what is set forth in this Policy, the Principles that govern data processing in the organization are established and, consequently, the procedures and organizational and security measures that the persons affected by this Policy commit to implementing in their area of responsibility.

In relation to the above, ZONA ALTA MG REAL ESTATE S.L. will ensure compliance with the following principles:

– Lawfulness, fairness, transparency and purpose limitation.

Data processing must always be informed to the affected person, through established clauses and procedures; and it will only be considered legitimate if there is consent for data processing (with special attention to that given by minors), or has another valid legitimacy, and its purpose is in accordance with applicable regulations.

– Data minimization.

The data processed must be adequate, relevant and limited to what is necessary in relation to the different purposes of processing.

– Accuracy.

Data must be accurate and, if necessary, updated. In this regard, the necessary measures will be adopted so that personal data that are inaccurate with respect to the purposes of processing are deleted or rectified without delay.

– Limitation of retention period.

Data will be maintained in such a way as to allow the identification of data subjects for no longer than necessary for the purpose of the processing in question.

– Integrity and Confidentiality.

Personal data will be processed in such a way as to ensure adequate security, including protection against unauthorized or unlawful processing, and against their loss, destruction or accidental damage, through the application of appropriate technical or organizational measures.

– Data transfers.

The purchase or obtaining of personal data whose origin comes from illegitimate sources is prohibited, or in those cases where such data have been collected or transferred in violation of the law or their legitimate origin is not sufficiently guaranteed.

– Hiring of providers with access to data.

Only providers that offer sufficient guarantees to apply appropriate technical and security measures in data processing will be chosen for their hiring. With these, the due contract in this regard will be documented.

– International data transfers.

Any processing of personal data subject to European Union regulations that involves a transfer of data outside the European Economic Area must be carried out in strict compliance with the requirements established in applicable law.

– Rights of affected persons.

The Organization will facilitate to affected persons the exercise of the rights of access, rectification, deletion, limitation of processing, opposition and portability, establishing for this purpose internal procedures, and in particular, the models that are necessary and appropriate for their exercise, which must satisfy, at least, the applicable legal requirements in each case.

ZONA ALTA MG REAL ESTATE S.L. will promote that the principles set forth in this Personal Data Protection Policy are taken into account:

  • 1. In the design and implementation of all work procedures
  • 2. In the products and services offered
  • 3. In all contracts and obligations that are formalized or assumed
  • 4. In the implementation of any systems and platforms that allow access by their workers or third parties and/or the collection or processing of personal data.

IV. PERSONAL DATA OF MINORS

Respecting what is established in articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights, only those over 14 years of age may grant their consent for the processing of their personal data in a lawful manner by ZONA ALTA MG REAL ESTATE S.L.. If it is a minor under 14 years of age, the consent of parents or guardians will be necessary for processing, and this will only be considered lawful to the extent that they have authorized it.

V. SECRECY AND SECURITY OF PERSONAL DATA

ZONA ALTA MG REAL ESTATE S.L. undertakes to communicate to the user, without undue delay, when a personal data security breach occurs that is likely to entail a high risk to their rights and freedoms. Following what is established in article 4 of the GDPR, a personal data security breach is understood to be any security breach that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee through a legal or contractual obligation that such confidentiality is respected by its workers, associates, and any person to whom it makes the information accessible.

VI. COMMITMENT OF ZONA ALTA MG REAL ESTATE S.L. STAFF

For the above, we express that the workers of ZONA ALTA MG REAL ESTATE S.L. are informed of this Policy, and declare themselves aware that personal information is an asset of ZONA ALTA MG REAL ESTATE S.L., and in this regard they adhere to it, committing to the following:

  • – Carry out the awareness training in Data Protection that ZONA ALTA MG REAL ESTATE S.L. makes available to them.
  • – Apply the user-level security measures that apply to their job position, without prejudice to the responsibilities in their design and implementation that could be attributed to them based on their role within ZONA ALTA MG REAL ESTATE S.L.
  • – Use the established formats for the exercise of Rights by affected users, and inform ZONA ALTA MG REAL ESTATE S.L. immediately, so that the response can be made effective.
  • – Inform ZONA ALTA MG REAL ESTATE S.L., as soon as they become aware, of deviations from what is established in this Policy, in particular of 'Personal data security breaches', using for this purpose the format established for this purpose.

VII. CONTROL AND EVALUATION

ZONA ALTA MG REAL ESTATE S.L. will carry out an annual verification, evaluation and assessment, as well as whenever there are significant changes in data processing, of the effectiveness of technical and organizational measures to guarantee processing security.