Privacy Policy

Effective from 03 August 2022.

Controller and your rights as a data subject*

(*Note on gender: for reasons of better readability, the following text does not use the simultaneous linguistic forms masculine, feminine and diverse (m/f/d). All the following personal names apply equally to all sexes.)

1. Controller

The controller of the data regulated by this privacy policy is «EGONE CONSULTING S.L.U.» (hereinafter «we» or «us»). Our contact details are:

Name of the licensee partner: Santiago Castañera Salomón

Address: Calle Nuria 10 (28034, Madrid)

Email: madridmirasierra@engelvoelkers.com

Licensee partner of Engel & Völkers Residential GmBH

2. 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 the data processing). In addition, under certain conditions, you have the right to object to the processing of your data in the future, to restrict it or to request the deletion of your data. Finally, you can prevent the sending of advertising materials or the carrying out of market research or commercial communications at any time. In summary, you have the right to - access, - rectification, - deletion (or the right to be forgotten), - restriction of processing, - data portability, - object to the processing of your personal data, - lodge a complaint with a supervisory authority.

In addition, 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 no longer process your personal data for these purposes.

In accordance with Art. 7 III of the EU General Data Protection Regulation (hereinafter "GDPR"), you may withdraw your consent at any time. This means that we will no longer be able to continue processing data based on this consent in the future. Please note that your right to erasure is subject to restrictions. For example, we are not obliged or permitted to erase data that we still need to retain due to statutory retention periods. Data that we need to assert, exercise or defend legal claims are also excluded from your right to erasure.

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

In the event of a legal obligation, 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 lit. c GDPR (legal obligation).

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Overview 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 enter into a search or marketing contract with us, request information from us or commission a property valuation from us.

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

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 to do so or if the processing is permitted by law. For certain services that we offer on our company website, we require a minimum amount of data. We have marked these mandatory data with an "asterisk". Without the mandatory data, we cannot provide the indicated services.

1. What data do we process about you (hereinafter referred to as "you" or "user")?

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

Email address, first name, last name, 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 services offered on our company's website (e.g. in the context of contact requests and newsletter dispatches, as well as determining the market price ("valuation") of real estate).

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Please see the description of the processing of related data in connection with the use of cookies and other tracking technologies in the "Cookie Information" of

Engel & Völkers GmbH

Vancouverstraße 2a

20457 Hamburg

Germany

Email: contact@engelvoelkers.com

You will find the information about cookies at the bottom of our company's 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 fulfilment of the contract and your consent if the user's data is passed on to other license partners of the Engel & Völkers Group (see definition below under point 3));

● If applicable, fulfillment of the request for an appraisal of the property described by the user in accordance with the market price and the interest in the sale transmitted (legal basis is fulfilment of the contract and if contact data is entered by the user and sent to a responsible license partner or competent office of the Engel & Völkers Group (please see definition below under point 3) or to the company that technically carries out the evaluation, your consent, as well as, 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 from us (legal basis is fulfilment of 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 (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 for processing 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 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 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 so-called legitimate interest. We will not pass on your personal data beyond this.

When we talk about the “Engel & Völkers Group” in this privacy policy, we mean companies belonging to the Engel & Völkers Group. Völkers as defined in §§ 15 et seq. AktG (German Stock Corporation Act) as well as the (principal) 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/en-de/company/offices/.

4. Transfer of data to non-EEA countries

In addition to the above paragraph “Transfer of your personal 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) in 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 with hidden information where necessary to protect trade secrets or other confidential information.

II. You enter into a search or marketing contract with us, request information from us or commission a property valuation.

1. What data do we process about you?

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

● first name, surname, title, address, telephone number, details about the desired property (in the case of a property search) or (in the case of a property marketing or property valuation) details about the property;

● email address, provided that you have agreed to receive promotional information, in particular the offer or valuation of properties, or wish to receive communications by email;

● as well as (in the case of the purchase/sale or rental of property) bank details, identity data, copy of the ID (in the case of the purchase/sale of a property), as well as property registration, electricity, oil or gas bills, general itemized bills, partition declarations, protocols of the community of owners (resolutions, purchase contract (in the case of the sale of a property)) or (in the case of the rental of a property) bank details, identity data, if applicable CV, proof of salary, proof of solvency, confirmation from the landlord, rental contract.

2. Purposes of processing and legal basis

We process this personal data for the following purposes:

● Fulfilment of the contractual relationship or a pre-contractual legal relationship - also by independent real estate agents cooperating with us - including billing and credit assessment (legal basis is Art. 6 I lit. b. GDPR as well as Art. 6 I lit. f GDPR; our legitimate interest in the transfer of data to independent real estate agents arises from the freedom of choice to also fulfil contractual relationships with independent real estate agents or sub-agents. The legitimate interest in carrying out credit checks arises from the legitimate interest in protection against bad debts);

● Fulfilment of a legal obligation, in particular in connection with the German Money Laundering Act; (legal basis is Art. 6 I lit. c GDPR);

● Advertising information about real estate that we or other licensed partners of the Engel & Völkers Group market (legal basis is Art. 6 I lit. f GDPR; the processing of personal data for direct marketing purposes is in our legitimate interest. The legal basis is also your consent according to 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 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

If your request (e.g. in connection with a request for a review) 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 complementary service providers, 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 reporting or to supervisory authorities (such as in the case of anti-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, independently 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 you instruct 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 consultants) 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 countries outside the EEA

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

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 license partner (referral).

If we are looking for a property for you together with another 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 processing

of data. 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 licensee partner of the Engel & Völkers Group 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 if 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.

1. What data do we process about you?

If you apply via our website or a job advertisement, we process your name as well as your address, your telecommunication data and your application. The provision of your address and telecommunications data, which are mandatory data, is necessary in order to be able to contact you regarding your request and to be able to attribute the request to you.

2. Purposes of processing and legal basis We process your personal data for the following purposes:

● Checking your application for an employment relationship within our company (legal basis is Art. 6 I lit. b GDPR, if necessary in conjunction with Section 26 BDSG (for the scope of application of the Federal Republic of Germany)).

● Defence of any legal claims asserted against us arising from the application process if this becomes necessary (legal basis is our legitimate interest in fulfilling our obligation to provide evidence in proceedings under the General Equal Treatment Act (AGG); Art. 6 I lit. f GDPR).

● In addition, we process your personal data on the basis of previously granted consent in order to inform you about job offers (legal basis is Art. 6 I lit. a GDPR).

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. We need your personal data in order to fulfil the processing purposes mentioned above. You are free not to provide us with any personal data. In this case, we will not be able to allow you to participate in the application process for available vacancies.

3. Data transfer

In principle, we will only pass on your personal data to third parties if this is necessary for the fulfilment 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. If you have applied via the global online career portal of Engel & Völkers Holding GmbH, then Engel & Völkers Holding GmbH will transmit your application documents for a job to us. You have been informed of how Engel & Völkers Holding GmbH processes your personal data during the application process and can read it at any time via the global online career portal on the corresponding Engel & Völkers Holding GmbH website.

4. Transfer of data to non-EEA countries

In addition to the above paragraph on “Transfer of your 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.

5. Storage and deletion of your data

We store your personal data for as long as necessary to achieve the purposes for which the data is collected and processed, including any retention period required by applicable law (e.g. retention of accounting records). In the context of application procedures that end without employment/recruitment, your data is normally stored for a further six months for documentation purposes and then deleted or destroyed, together with any documents you have sent us. With your consent to the processing of data for future application procedures, we also retain it for a correspondingly longer period.