Álvaro Luna

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Privacy Policy

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1. PRIVACY POLICY AND DATA PROTECTION

Respecting the provisions established in current legislation, Álvaro Luna (hereinafter also Website) undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security based on the risk of the collected data.

Laws incorporated into this privacy policy

This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the internet. Specifically, it complies with the following standards:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
  • Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
  • Royal Decree 1720/2007, of December 21, approving the Regulation developing Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

 

Identity of the Data Controller

The data controller for the personal data collected by Álvaro Luna Real Estate is: Álvaro Luna Huerta, holder of NIF: 28783410Z.

His contact details are as follows:

Address: Calle Almirante Lobo, 3. 1st floor. 41001. Seville.

Contact Telephone: 651555944

Contact Email: oficina@alvaroluna.net

Personal Data Register

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that personal data collected by Álvaro Luna Real Estate, via the forms available on its pages, will be included and processed in our file for the purpose of facilitating, expediting, and fulfilling the commitments established between Álvaro Luna Real Estate and the User or the maintenance of the relationship established in the forms that the latter fills out, or to address a request or inquiry from the same. Furthermore, in accordance with the GDPR and the LOPD-GDD, unless the exception provided in Article 30.5 of the GDPR applies, a processing activities register is maintained that specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles Applicable to the Processing of Personal Data

The processing of the User’s personal data will be subject to the following principles set out in Article 5 of the GDPR and in Article 4 and following of the Spanish Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

  • Lawfulness, fairness, and transparency: User consent will always be required with prior fully transparent information about the purposes for which personal data is collected.
  • Purpose limitation: personal data will be collected for specific, explicit, and legitimate purposes.
  • Data minimization: only personal data strictly necessary in relation to the purposes for which they are processed will be collected.
  • Accuracy: personal data must be accurate and kept up to date at all times.
  • Storage limitation: personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of its processing.
  • Integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.
  • Proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are complied with.

 

Categories of Personal Data

The categories of data processed by Álvaro Luna Real Estate are solely identifying data. Under no circumstances are special categories of personal data as defined in Article 9 of the GDPR processed.

Legal Basis for the Processing of Personal Data

The legal basis for the processing of personal data is consent. Álvaro Luna Real Estate undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User has the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawing consent will not condition the use of the Website.

On occasions when the User needs or may provide their data via forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if filling out any of them is mandatory because they are essential for the proper development of the operation performed.

Purposes of Data Processing

Personal data is collected and managed by Álvaro Luna Real Estate for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms that the latter fills out, or to address a request or inquiry.

Likewise, the data may be used for commercial, personalization, operational, and statistical purposes, and for activities related to the social object of Álvaro Luna Real Estate, as well as for the extraction, storage of data, and marketing studies to tailor the Content offered to the User, as well as to improve the quality, functioning, and navigation of the Website.

At the time personal data is obtained, the User will be informed about the specific purpose(s) of the processing their personal data will be used for; that is, the use(es) that will be given to the information collected.

Retention Periods for Personal Data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 4 years, or until the User requests its deletion.

At the time personal data is obtained, the User will be informed about the period during which personal data will be retained or, when that is not possible, the criteria used to determine that period.

Recipients of Personal Data

The User’s personal data will not be shared with third parties.

In any case, at the time personal data is obtained, the User will be informed about the recipients or the categories of recipients of the personal data.

Personal Data of Minors

Respecting the provisions of Articles 8 of the GDPR and 7 of the Spanish Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years old may lawfully give their consent for the processing of their personal data by Álvaro Luna Real Estate. If the person is under 14 years old, it will be necessary to obtain the consent of the parents or guardians for the processing, and this will only be considered lawful to the extent that they have authorized it.

Confidentiality and Security of Personal Data

Álvaro Luna Real Estate undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security based on the risk of the collected data, so that the security of personal data is guaranteed and accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data is prevented.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as data transmission between the server and the User, and in feedback, is fully encrypted.

However, because Álvaro Luna Real Estate cannot guarantee the inviolability of the internet nor the total absence of hackers or other unauthorized access to personal data, the Data Controller undertakes to notify the User without undue delay when a violation of the security of personal data occurs that is likely to entail a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a violation of the security of personal data is understood as any infringement of security 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 ensure through a legal or contractual obligation that such confidentiality is respected by his employees, associates, and any person to whom the information is made accessible.

Rights Derived from the Processing of Personal Data

The User has rights over Álvaro Luna Real Estate and can, therefore, exercise the following rights recognized in the GDPR and the Spanish Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, against the Data Controller:

  • Right of access: It is the User’s right to obtain confirmation as to whether Álvaro Luna Real Estate is processing their personal data or not and, if so, to obtain information about their specific personal data and the processing that Álvaro Luna Real Estate has carried out or is carrying out, as well as, among others, the available information about the origin of such data and the recipients of the communications made or planned regarding them.
  • Right to rectification: It is the User’s right to have their personal data modified if they are inaccurate or, considering the purposes of processing, incomplete.
  • Right to erasure (“the right to be forgotten”): It is the User’s right, provided that current legislation does not establish otherwise, to obtain the deletion of their personal data when such data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis; the User opposes the processing and there is no other legitimate reason to continue it; the personal data have been unlawfully processed; the personal data must be deleted to comply with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a person under 14 years old. In addition to deleting the data, the Data Controller, considering the available technology and the cost of its application, must adopt reasonable measures to inform the data controllers who are processing the personal data of the data subject’s deletion request of any link to that personal data.
  • Right to restriction of processing: It is the User’s right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the processing.
  • Right to data portability: In cases where processing is carried out by automated means, the User has the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit them to another Data Controller. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.
  • Right to object: It is the User’s right to prevent the processing of their personal data or to stop such processing by Álvaro Luna Real Estate.
  • Right not to be subject to a decision based solely on automated processing, including profiling: It is the User’s right not to be subject to an individual decision based solely on automated processing of their personal data, including profiling, unless current legislation establishes otherwise. Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference “GDPR-https://alvaroluna.net/”, specifying:
  • Name, surnames of the User, and a copy of their ID. In cases where representation is admitted, it will also be necessary to identify, by the same means, the person representing the User, as well as the document certifying the representation. A photocopy of the ID can be replaced by any other legally valid means that certifies the identity.
  • Request with the specific reasons for the request or information to be accessed.
  • Address for notifications.
  • Date and signature of the requester.
  • Any document that accredits the request being made.

This request and any other attached document may be sent to the following address and/or email:

Postal Address: Calle Almirante Lobo, 3. 1st floor. 41001. Seville.

Email: oficina@alvaroluna.net

Links to Third-Party Websites

The Website may include hyperlinks or links that allow access to third-party websites different from Álvaro Luna Real Estate, and therefore not operated by Álvaro Luna Real Estate. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the Supervisory Authority

If the User considers that there is a problem or infringement of current regulations in the way their personal data is being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the country where they have their habitual residence, place of work, or place of the alleged infringement. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

2. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agree to the conditions regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data for the Data Controller to proceed with it in the manner, for the periods, and for the purposes indicated. Use of the Website will imply acceptance of its Privacy Policy.

Álvaro Luna Real Estate reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User periodically consult this page to stay informed of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and to Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.