Privacy Policy for personal data

DATA CONTROLLER INFORMATION

Identity: KINNISVARA, S.L.
NIF: B55369342
Address: Avinguda de Rhode, 95 (17480) Roses
Phone: 972977797
Website: https://www.remaxcostabrava.es/
Email: brava@remax.es
DPO contact details: dpd@dataprobcn.com

JOINT CONTROLLERS

KINNISVARA, S.L. and the social networks on which they have an account act as joint controllers of data processing.

PURPOSES FOR WHICH YOUR DATA IS PROCESSED

We process your personal data for the following purposes:

• Administrative and commercial management of customers and suppliers.
• Management of information and content on our website https://www.remaxcostabrava.es/ and our social media.
• Interacting in accordance with social network policies and managing virtual communities in accordance with the policies of each social network and our interests.
• Management and content of our social media.
• Human resources management of our employees and candidates.
• Management and communication of enquiries made on the website.
• Capturing images to ensure the safety of people and property.
• Managing, investigating and monitoring communications or reports received regarding possible irregularities, regulatory breaches or behaviour contrary to the law or to the ethical and conduct principles of the organisation, in compliance with the provisions of Law 2/2023 of 20 February, regulating the protection of persons reporting regulatory infringements and combating corruption, as well as in compliance with legal obligations regarding crime prevention and criminal liability of legal persons.

LEGAL BASIS FOR PROCESSING

• Processing is carried out on the basis of a contractual relationship.
• Processing is carried out on the basis of the data subject’s consent.
• In the case of candidates, the legal basis for processing their data will be informed consent.
• The capture of video surveillance images is carried out on the basis of legitimate interest.
• In the case of the internal reporting system, the legal basis is compliance with a legal obligation pursuant to Article 6.1.c of the General Data Protection Regulation (GDPR), in relation to the provisions of Law 2/2023 of 20 February, regulating the protection of persons reporting regulatory infringements and combating corruption.

DATA RETENTION PERIOD

Data will be retained:

• For as long as the commercial relationship is maintained.
• Your data may be retained after the end of any contractual relationship with the parties involved for a period of five (5) years to comply with legal obligations, without prejudice to data that must be retained for longer due to legal requirements and the limitation period for liabilities.
• In the case of CVs, they will be retained for a maximum period of 1 year from receipt. If the candidate joins the entity’s staff, the CV will be incorporated into their employment file.
• Data will only be retained for the minimum time necessary to decide whether to process information.

In the event that it has been verified that the information received is not truthful, it will be deleted immediately, unless this fact may constitute an unlawful criminal act, in which case all information will be retained for as long as necessary for the duration of the criminal proceedings.

Communications received without having been processed will be deleted within 3 months of receipt, unless the purpose is to leave evidence in the system. Such communications may be stored in anonymised form.

• Personal data provided will be retained until deletion is requested by the data subject, provided that such deletion is applicable.
• During the retention period due to legal obligation and limitation of liabilities, data will be kept blocked.
• In the case of social networks, data will only be retained for the time necessary to resolve your query, or for the duration of the interaction. Please note that your data may remain on the social network in accordance with the operating policy of each specific social network.
• Upon expiry of the retention periods, data will be destroyed.
• Video surveillance images will be retained for a maximum period of 30 days.

RECIPIENTS OF TRANSFERS OR DISCLOSURES

Data will be disclosed, where necessary, to: banks and savings banks, public administrations, processors providing various support services to KINNISVARA, S.L., as well as to necessary third parties with whom communication is legally required, for the purpose of fulfilling the provision of the aforementioned service.

DATA SUBJECTS’ RIGHTS

What are your rights?

• Any person has the right to obtain confirmation as to whether KINNISVARA, 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 erasure when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
• Data subjects have the right to object to the processing of their personal data.
• In certain circumstances provided for in Article 18 of the GDPR, data subjects may request the restriction of processing of their data; in this case, it will only be retained for the exercise or defence of claims.
• By virtue of the right to data portability, data subjects have the right to obtain their personal data in a structured, commonly used and machine-readable format and to transmit it to another controller.

How can you exercise your rights?

The exercise of rights may be carried out free of charge.

• By written request addressed to KINNISVARA, S.L., Avinguda de Rhode, 95 (17480) Roses.
• By written request addressed to KINNISVARA, S.L. at the email address brava@remax.es.

What complaint channels are available?

If you consider that your rights have not been duly attended to, you have the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

ACCURACY OF DATA

The information provided by the data subject must be truthful; otherwise, they will be responsible for any damage caused to the entity or to third parties by failing to provide accurate data.

ADDITIONAL INFORMATION

We will process data in a lawful, fair, transparent, adequate, relevant, limited, accurate and up-to-date manner. We therefore undertake to take all reasonable measures to ensure that data is deleted or rectified without delay when inaccurate.

Unless data subjects inform us otherwise, we will assume that their data has not been modified and they will be responsible for notifying us of any changes.

PROCESSING OF DATA OF MINORS

It is prohibited to provide data through this portal relating to persons under the age of fourteen (14). If a person under this age provides data, their parents or guardians will be solely responsible for this situation.

VALIDITY AND MODIFICATION OF THIS DATA PROTECTION POLICY

The owner of the site https://www.remaxcostabrava.es/ reserves the right to modify its privacy policy in the event of a change in current legislation, case law or its own business criteria. If any change is made to this policy, the new text will be published at this same address.

SOCIAL MEDIA

KINNISVARA, S.L. informs users that it has created a profile on the following social networks: Facebook, LinkedIn and Instagram, with the main purpose of advertising its products and services.

Users can access the privacy policies of the social network itself at any time, as well as configure their profile to ensure their privacy.

KINNISVARA, S.L. has access to and processes the user’s public information, in particular their contact name. This data will only be used within the social network itself and is not incorporated into any processing system.

In accordance with the rights conferred upon you by current data protection regulations, you may exercise your rights of access, rectification, erasure and objection before KINNISVARA, S.L., by directing your request to the postal address indicated above or via email to brava@remax.es. In accordance with the GDPR, please take into account the following:

• Access: This will be defined by the functionality of the social network and the ability to access user profile information.
• Rectification: This can only be satisfied in relation to information under the control of KINNISVARA, S.L., for example, deleting comments published on the page itself. Normally, this right must be exercised directly with the social network.
• Erasure and/or Objection: As in the previous case, this can only be satisfied in relation to information under the control of KINNISVARA, S.L., for example, ceasing to be connected to the profile.

KINNISVARA, S.L. will carry out the following actions:

• Access to the public information of the profile.
• Publication on the user’s profile of all information already published on KINNISVARA, S.L.’s page.
• Sending personal and individual messages through the social network’s channels.
• Page status updates that will be published on the user’s profile.

Users can always control their connections, delete content they are no longer interested in and restrict who they share their connections with; to do so, they must access their privacy settings.

Publications

Once connected to KINNISVARA, S.L.’s page, the user may publish comments, links, images or photographs or any other type of multimedia content supported by the social network. In all cases, the user must be the owner of such content, hold the copyright and intellectual property rights, or have the consent of the affected third parties. Any publication on the page, whether texts, graphics, photographs, videos, etc., that infringes or may infringe upon morality, ethics, good taste or decency, and/or that infringes, violates or breaches intellectual or industrial property rights, the right to one’s image or the law, is expressly prohibited. In such cases, KINNISVARA, S.L. reserves the right to immediately remove the content and may request the permanent blocking of the user.

KINNISVARA, S.L. will not be held responsible for content freely published by a user.

Users must bear in mind that their publications will be visible to other users, and they are therefore primarily responsible for their own privacy.

Images that may be published on the page will not be stored in any file by KINNISVARA, S.L., but will remain on the social network.

Contests and promotions

KINNISVARA, S.L. reserves the right to run contests and promotions in which users connected to its page may participate. The terms and conditions of each, when the social network platform is used for this purpose, will be published thereon, always in compliance with the LSSI-CE and any other applicable regulations.

The social network does not sponsor, endorse or administer, in any way, any of our promotions, nor is it associated with any of them.

Advertising

KINNISVARA, S.L. will use the social network to advertise its products and services; in any case, if it decides to process your contact details to carry out direct commercial prospecting activities, this will always be done in compliance with the legal requirements of current data protection regulations and the LSSI-CE.

Recommending KINNISVARA, S.L.’s page to other users so that they can also enjoy promotions or be informed of its activity will not be considered advertising.

Below we provide links to the privacy policies of the social networks:

• Facebook: https://www.facebook.com/help/323540651073243/
• LinkedIn: https://www.linkedin.com/legal/privacy-policy
• Instagram: http://instagram.com/about/legal/privacy/#
• TikTok: https://www.tiktok.com/legal/page/row/privacy-policy/es