Engel & Völkers Costa Dorada

Privacy Policy

Effective August 16, 2022. [1]

Responsible and their rights as interested parties*

(*Note on gender: for reasons of better readability, in the following text the simultaneous use of the linguistic forms masculine, feminine and diverse (m/f/d) is dispensed with. All the following names of persons apply equally to all sexes.)

1. Responsible

The person responsible for processing the data regulated by this privacy policy is "Albrem Group S.L" (hereinafter, "we" or "us"). Our contact details are:

Engel @Völkers Costa Dorada Dr. Fleming, 3B - 43850 Cambrils

costadorada@engelvoelkers.com

Engel & Völkers License Partner

2. Data Protection Officer[2]

If you have any questions about this privacy policy and data protection, please contact our data protection officer(s):

Miguel Angel Osuna

costadorada@engelvoelkers.com

3. Your rights as a data subject

You have the right to receive information about the processing of your personal data (for example, the origin of this data, the purpose of the processing, the modalities of data processing). Furthermore, under certain conditions, you have the right to object to future data processing, to limit it or to request the deletion of the data. Finally, you can prevent the sending of advertising material or the carrying out of market studies or commercial communications at any time.

In short, you have the right to

- access,

- rectification,

- deletion (or right to be forgotten),

- the limitation of treatment,

- data portability,

- oppose the processing of your personal data,

- file a claim with a supervisory authority.

Furthermore, you have the right to object at any time to the processing of your personal data for direct marketing purposes. If you object to processing for direct marketing purposes, we will stop processing your personal data for these purposes.

In accordance with art. 7 III of the EU General Data Protection Regulation (hereinafter "GDPR"), you can withdraw the consent you have given us at any time. This has the consequence that in the future we will no longer be able to continue processing data based on this consent.

Please note that your right to delete data is subject to restrictions. For example, we are not obliged or permitted to delete data that we must still retain due to legal retention periods. Data that we need to assert, exercise or defend legal claims are also excluded from your right to deletion.

If you have a complaint about the way we process your data, you have the possibility of filing a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or place of the alleged infringement.

If required by law, we reserve the right to disclose information about you if required to do so by legal authorities or law enforcement agencies. Legal basis: art. 6 I para. 1, let. c GDPR (legal obligation).

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Summary of our data processing procedures

Our following privacy policy is structured as follows and gives you an overview of the following data processing procedures:

I. You visit us on our company website.

II. You sign a search or marketing contract with us, request information from us or commission us to evaluate the property. [3]

III. We are looking for a property for you together with another license partner of Engel & Völkers (reference).

IV. You send us an application on your own initiative or respond to a job advertisement.

V. Storage and deletion of your data

I. Collection and processing of personal data when you visit our company website

In principle, we only process personal data if you send it to us via the contact forms on our company website. Personal data is only processed if you have given us your consent or if the processing is permitted by legal regulations. For certain services that we offer on our company website, we require a minimum amount of data. We have marked this mandatory information with an “asterisk”. Without the mandatory data, we cannot provide the indicated services.

1. What data do we process about you (hereinafter, “you” or “user”)?

In the course of your use of our company website, we process personal data, namely:

Email address, first name, surname, title, address, telephone number, property data (referred to as “data” or “personal data” in the context of this privacy policy) provided by you in the case of the services offered on our company website (for example, in the context of contact requests and newsletter shipments, as well as determining the market price ("valuation") of real estate).

__________________________________________________________________________________________

Please see the description of the processing of related data in relation to the use of cookies and other tracking technologies in the “Information about Cookies” of

Engel & Völkers GmbH

Vancouverstraße 2a

20457 Hamburg

Germany

Email: info@engelvoelkers.com

You will find information about cookies at the bottom of our company website.

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2. Purposes of processing and legal basis

We process your data for the following purposes:

● Fulfillment of contact requests (legal basis is the fulfilment of the contract as well as your consent, in the event that user data is transmitted to other license partners of the Engel & Völkers Group (see definition below under point 3));

● If applicable, the fulfilment of the request for an appraisal of the property described by the user in accordance with the market price and the interest in selling it expressed (legal basis is fulfilment of the contract and, in the case of the entry of contact data by the user and its transmission to a responsible license partner or competent local Engel & Völkers Group (please see definition below under point 3) or to the company technically carrying out the appraisal, your consent, and in the case of the use of contact data for direct marketing, a legitimate interest in marketing our own services or your consent);

● Telephone contact by us (legal basis is fulfilment of the contract or, in the case of the use of the telephone number for advertising purposes, your consent);

● Sending an e-mail newsletter about our own offers as well as our own and third-party advertising, to the extent permitted by law or based on your consent (the legal basis is your consent or our legitimate interest in direct marketing, provided that the marketing is carried out in compliance with data protection and competition law requirements);

In summary:

The legal basis for the processing of personal data is Art. 6 I para. 1 lit. a GDPR, provided that the processing is based on consent, Art. 6 I para. 1 lit. b GDPR, provided that the basis for processing is a contractual (possibly pre-contractual) relationship, and Art. 6 I para. 1 lit. f GDPR, provided that the basis is our legitimate interest. If the processing of personal data is necessary for compliance with a legal obligation to which we are subject, Art. 6 I para. 1 lit. c GDPR serves as the legal basis.

If the legal basis is your consent, you have the right to revoke it at any time without affecting the lawfulness of the processing of your personal data carried out on the basis of consent until its revocation. If the legal basis is legitimate interest, you generally also have the right to object to the processing of personal data concerning you at any time for reasons arising from your particular situation. In this respect, Article 21 GDPR applies.

3. Transfer of your personal data

In principle, we will only pass on your personal data to third parties if this is necessary for the fulfillment of the contract, if we or a third party have a legitimate interest in the transfer, if there is a legal obligation or if you have given your consent. If the data is transferred to third parties on the basis of a legitimate interest, this will be explained in these data protection provisions.

If your contact request is related to offers from other companies in the Engel & Völkers Group, we will transfer the personal data you have provided in this case to the relevant company in the Engel & Völkers Group with your prior consent or, if legally permitted, on the basis of a so-called legitimate interest. We will not pass on your personal data beyond this.

When we refer to the Engel & Völkers Group in this privacy policy, we refer to the companies belonging to the Engel & Völkers Group as defined in Articles 15 et seq. of the AktG (German Corporation Act), as well as the (main) license partners who are directly or indirectly contractually affiliated with this group of companies and to which we also belong. You can find a current overview of the license partners here: https://www.engelvoelkers.com/es-de/empresa/oficines/.

4. Transfer of data to non-EEA countries

In addition to the above paragraph “Transfer of your personal data”, the following applies:

Recipients of personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which the personal data is transferred ensures an adequate level of protection (Art. 45 GDPR) or because the transfer is subject to adequate safeguards (e.g. standard contractual clauses) of the European Union agreed with the recipient (Art. 46 GDPR), unless the GDPR provides for an exception (Art. 49 GDPR). In addition, where necessary, we intend to agree additional measures with recipients to ensure an adequate level of data protection. Copies of appropriate safeguards (where we rely on them) and a list of recipients outside the EEA/UK are available on request. Please note that these copies may be redacted where necessary to protect trade secrets or other confidential information.

II. You enter into a search or marketing agreement with us, request information from us or commission a property valuation from us. [4]

1. What data do we process about you?

When searching for, selling or renting a property, when requesting information and in the case of a property valuation, we regularly process the following personal data about you:

● Name, surname, title, address, telephone number, details of the desired property (when searching for a property) or (when marketing or evaluating a property) details of the property;

● E-mail address, if you have agreed to receive advertising information, in particular the offer or valuation of properties, or if you would like to receive notifications by e-mail;

● and (in the case of buying/selling or renting a property) bank details, identity data, copy of identity card (in the case of buying/selling a property) and property registration, electricity bills e.g. oil or gas, general individual invoices, declarations of division, minutes of the owners' association (resolutions, purchase contract (when selling a property)) or (when renting a property) bank details, identity data, if applicable CV, proof of salary, proof of creditworthiness, landlord confirmation, rental agreement.

2. Purposes of processing and legal basis

We process this personal data for the following purposes:

● Compliance with the contractual relationship or a pre-contractual legal relationship - also by independent real estate consultants who work with us - including invoicing and credit checks (the legal basis is Art. 6 I lit. b GDPR, also). Our legitimate interest in passing on data to independent real estate consultants exists in accordance with Art. The legitimate interest in carrying out credit checks arises from the legitimate interest in securing against bad debts.

● Compliance with a legal obligation, in particular with regard to the Money Laundering Act; (legal basis is Art. 6 I lit. c GDPR);

● Advertising information about properties that we or other license partners of the Engel & Völkers Group market (the legal basis is Art. 6 I lit. f GDPR; the processing of personal data for direct marketing purposes is based on our legitimate interest. The legal basis is also your consent in accordance with Art. 6 I a GDPR if the advertising information is sent to you by email, fax or telephone.

If the legal basis is your consent, you have the right to revoke it at any time without affecting the legality of the processing carried out on the basis of the consent until the revocation. If the legal basis is a legitimate interest, you also have the right to object to the processing of personal data concerning you at any time for reasons arising from your particular situation. In this respect, Article 21 GDPR applies.

3. Data transfer

If your request (e.g. in connection with a request for an evaluation) is related to offers from other license partners of the Engel & Völkers Group, Engel & Völkers will pass on the personal data you have provided in this case to the relevant company of the Engel & Völkers Group after your prior consent.

In this context, please also see our information on the reference in section III.

In addition, we transfer personal data to contractual partners (landlords, landlords, prospecting clients) and to providers of complementary services, such as notaries, lawyers, building managers, property developers, as part of the processing of a contractual relationship, as well as in the context of credit reports or to supervisory authorities (such as in the case of money laundering documentation). We may also transfer your data to third parties to the extent permitted by law. Third parties to whom we may disclose your personal data, independent of our provision of services, include external advisors (e.g. lawyers and accountants), public authorities within their jurisdiction to comply with legal obligations and protect our rights (e.g. tax authorities, police, prosecutors, courts), potential buyers or acquirers of all or part of our assets or activities, and other third parties to the extent that you direct us to disclose data or give your consent.

In addition, we will only share your personal data with employees (permanent staff such as employees and self-employed real estate advisors) and third-party companies (e.g. IT service providers, hosting providers, etc.) to whom we have subcontracted services involving processing operations within the framework of a contractual processing agreement.

4. Transfer of data to non-EEA countries

In addition to the above paragraph on “Transfer of your data”, the following applies:

The recipients of the personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which the personal data is transferred ensures an adequate level of protection (Art. 45 GDPR) or because the transfer is subject to adequate safeguards (e.g. standard contractual clauses) of the European Union agreed with the recipient (Art. 46 GDPR), unless the GDPR provides for an exception (Art. 49 GDPR). In addition, where necessary, we intend to agree additional measures with recipients to ensure an adequate level of data protection. Copies of the appropriate safeguards (where we rely on them) and a list of recipients outside the EEA/UK are available on request. Please note that these copies may be redacted where necessary to protect trade secrets or other confidential information.

If your request is related to Engel & Völkers Group license partners outside the European Union, we will transfer your data to the responsible or local license partner with your consent.

III. We are looking for a property for you together with another Engel & Völkers Group license partner (referral).

If we are looking for a property for you together with another Engel & Völkers Group license partner, your data will only be passed on based on your prior consent. Please note that both we, your initial contact, and the Engel & Völkers Group license partner to whom your data is transferred, process your personal data. Both we and this license partner are independently responsible for the respective data processing. We and this other license partner do not have access to each other's data and do not process your data jointly. If you wish to assert your rights as a data subject, please check in advance whether you wish to assert them against us or against the other Engel & Völkers Group license partner who also processes your data.

Please see the information above on how we process your data in connection with the marketing of your property, what rights you have in this regard and who your contact persons are should you wish to assert your rights as a data subject.

IV. You send us an application on your own initiative or respond to a job advertisement.

2. Purposes of processing and legal basis

If the legal basis is your consent, you have the right to revoke it at any time without affecting the lawfulness of the processing carried out on the basis of consent until its revocation. If the legal basis is legitimate interest, you generally also have the right to object to the processing of personal data concerning you at any time for reasons arising from your particular situation. In this respect, Article 21 GDPR applies.

3. Data transfer

In principle, we will only pass on your personal data to third parties if this is necessary for the performance of the contract, if we or a third party have a legitimate interest in the transfer, if there is a legal obligation or if you have given your consent. If data is transferred to third parties on the basis of a legitimate interest, this will be explained in these data protection provisions.

4. Transfer of data to non-EEA countries

In addition to the above paragraph on “Transfer of your data”, the following applies:

5. Storage and deletion of your data