Personal data policy

Information on the processing of personal data of customers by GYRPROMLUX

Responsible for the data processing 

GYRPROMLUX, SL or any of the companies that are managed by Kronos depending on the Project (hereinafter “GYRPROMLUX”)

Registered address: Avenida Alameda del Mar, 47, 29603, Marbella, Malaga 

Contact Data Protection officer: altair.madrid@yahoo.es 

What are the treatments of data takes place GYRPROMLUX? 

The treatment of the personal data that will be GYRPROMLUX depend on the state of the temporal relationship maintained with the interested party. Below we detail the purposes, legal bases associated to the processing, categories of data processed, as well as the terms of conservation of personal data processed

1. Phase request for information: 

GYRPROMLUX will treat the personal data collected directly from the interested parties, or through the application forms of information to be able to serve the application on the promotion stated. In this sense, according to the received request, GYRPROMLUX be forwarded to the party concerned, information on the promotion of the property that you are interested in. Finally, in the application form is requested from the interested your consent to: (i) to receive information about other promotions marketing GYRPROMLUX and (ii) disclose your information to other companies in the real estate sector managed by Kronos so that they can send you information about their products. This treatment is developed in section 5 of this document “business Information”

Legality of the processing of personal data: GYRPROMLUX is the information provided on the following basis:

  • The treatment needed for the application to request information request of a property of the marketing and sale of GYRPROMLUX. (art.6.1.(b) of the General Regulation on Data Protection).
  • The express consent of the person concerned through the boxes laid down to the effect tab in the application of information. (art.6.1.(a) of the General Regulation of Data Protection)

Categories of personal data: The personal data that GYRPROMLUX treated at the time of the request for information are: name and surname, home address, email address, data of the property of interest, as well as the contact of the marketer assigned to your request for information. 

Data retention: GYRPROMLUX will keep the personal data concerned during the period of commercialization of such promotion. If, finally, the interested parties decide to proceed with the purchase of the property, GYRPROMLUX will treat the information related to the signal or purchase according to the treatments of data intended for those phases. If finally, the interested parties do not proceed to the purchase of the property, GYRPROMLUX will not treat such information, except the case referred to in point 5 on business information. See item 5. Business Information. 

2. Phase selection of the property:

GYRPROMLUX will handle your personal data in order to manage the selection of the property by the interested party. This election may be conducted through a document of signal. 

Legality of the processing of personal data:

GYRPROMLUX will treat all of the information provided by the person concerned in order to manage the choice of a property for your future purchase (art.6.1.(b) of the RGPD). 

In this sense:

  • GYRPROMLUX inform you of such election to the marketers designated in this promotion to carry out the execution of the same.
  • GYRPROMLUX will be able to carry out the data processing arising from the execution of this document or of any management derived from the signal of warranty

Also, from the moment that occurs the signal, KRONOS puts all the obligations arising from the regulations governing the prevention of money laundering and the financing of terrorism with the processing of personal data arising from the obligations of identification. (art.6.1.c) of the General Regulation on Data Protection). In this case, we inform the interested party that the KRONOS may share such information with the other companies that manages the real estate sector for the sole purpose of streamline and manage the obligations in such matters fall on those societies. You can consult the details of these companies in altair.madrid@yahoo.es 

On the other hand, only in the case that the data subject has expressly consented to the choice of financing of the property (art.6.1.(a) of the General Regulation of Data Protection to the data of the person concerned may be communicated to the financial institution with which GYRPROMLUX maintain relationships to facilitate the financing of this promotion, with the purpose of putting them in contact with them for the study and management of the possible economic operation of the purchase of the said property. This consent shall imply that the entity has been chosen for possible funding communicate your data to GYRPROMLUX once it has been approved or denied the operation with the aim to continue the efforts of the possible purchase of the property on the terms that might be appropriate.

Categories of personal data: The personal data that GYRPROMLUX treated at the time of selection of the property will be your first and last name, address, email address, data of the property of interest, marketer assigned to your request for information, a signal of warranty, account information from financial institutions, documents signed signal, deadlines of execution of the contract of purchase and identification documents required by GYRPROMLUX in terms of fulfillment of obligations of prevention of money laundering. Also, GYRPROMLUX you can get additional data, either in files common information of the prevention of money laundering, as well as of public records officers.

Data retention: GYRPROMLUX will keep your personal data during the election period of the property or may be extended in the event of formalization of the purchase. In the case that finally the purchase of the property does not materialize, their data will be kept locked during the term of ten years to comply with the obligations for the conservation of the documentation derived from the regulations governing the prevention of money laundering and the financing of terrorism.

3. Phase formalization of the Sale:

GYRPROMLUX treat the data of the buyers to be able to manage and formalizing the contract of sale. 

Legality of the processing of personal data: GYRPROMLUX is the information provided on the basis of the treatment necessary for the execution of a purchase contract between the data subject and GYRPROMLUX. (art.6.1.(b) of the General Regulation on Data Protection). In this sense, such a relationship will involve the following treatments of personal data:

  • Management necessary for the execution of the contract of sale.
  • Document management/contractual, accounting, tax and administrative.
  • Management, and in your case, communication of data with public records, agencies, insurance companies and notaries involved in the process.
  • Management pre-and post-sale. All of the activities that are carried out in function of the needs that may arise from the provision of housing.

Compliance obligations of identification derived from the rules of the applicable regulations (art.6.1.c) of the General Regulation of Data Protection):

  • prevention of money laundering and the financing of terrorism. In this case, it is reported that GYRPROMLUX can share that information with the other companies that manages and above have already been quoted for the sole purpose of streamline and manage the obligations in such matters fall on those societies.
  • Communications of the necessary data with the public agencies, or may require information or the communication of data arising from the regulation, such as tax regulations.

Only in the case that the person concerned has consented to the financing of the property, your information may be disclosed to the financial institution with which GYRPROMLUX keep relations to carry out the economic transaction of the purchase of the said property. (art.6.1.(a) of the General Regulation on Data Protection).

Categories of personal data: The personal data that GYRPROMLUX treated at the time of the selection of the property will be your first and last name, address, email address, data of the property of interest, marketer assigned to your request for information, a signal of warranty, account information from financial institutions, professional information, family information, information, financial situation, tax information, documents signed signal, deadlines of execution of the contract of purchase and identification documents required by GYRPROMLUX in terms of fulfillment of obligations of prevention of money laundering. Also, GYRPROMLUX you can get additional data, either in files common information of the prevention of money laundering, as well as of public records officers. Also, GYRPROMLUX can get you to treat personal data of third parties provided by the buyer as can be: legal representatives, partners, sponsors, family members, or other persons in the environment in the case of personal and real guarantees.

With regard to the processing of third party data cited above, the buyer confirms that such data are real and that the affected parties have been informed and have consented to the processing of your personal data by GYRPROMLUX.

Data retention: GYRPROMLUX will keep your personal data throughout the process of formalization of the purchase. Once the term of a year and a half (time limit provided for the possible efforts and post-sale), your data will be kept locked during the term of ten years to comply with the obligations for the conservation of the documentation derived from the regulations governing the prevention of money laundering and the financing of terrorism. 

4. Quality surveys:

Also, GYRPROMLUX will be sent, on the basis of its legitimate interest (art.6.1.f) of the General Regulation on Data Protection), quality surveys on the treatment offered, the real estate being offered in order to be able to learn from customer feedback, to improve the information and quality of the processes and thus the experience of all stakeholders in the promotions of GYRPROMLUX. GYRPROMLUX has carried out a test of the weighting of the above-mentioned legitimate interest in order to be able to verify that the shipment of these satisfaction surveys to those interested in promotions of GYRPROMLUX do not pose a threat to the rights of protection of data of the same. After this analysis, GYRPROMLUX understand that these rights are not weakened, due to the clear information contained in this information document, as well as the possibility of the data subject to object to the sending of such surveys either (i) via email at the time of the request, and (ii) the withdrawal procedure that exists in the communication. Also, GYRPROMLUX in advance will not send these surveys to those who have not consented to receive information about other promotions of the Group GYRPROMLUX. If You I would like to know the detail of such a test is weighting you can request this in altair.madrid@yahoo.es.

5. Business information: 

In the application forms of information, GYRPROMLUX will be a mechanism for those who are interested, you expressly consents to the following treatments (art.6.1.(a) of the General Regulation of Data Protection): 

  • A specific consent for that GYRPROMLUX, either through calls from their managers or via e-mail, to send you commercial information about events or other promotions that marketed GYRPROMLUX or other products in the real estate sector of which it is a part GYRPROMLUX. For the development of such communications, GYRPROMLUX customize the same on the basis of profiles based on the preferences of promotions that have been expressed, or, in the case that you are customers, on the basis of the personal data with which you have GYRPROMLUX relating to your preferences and history of operations.
  • Another specific consent for that GYRPROMLUX can send the contact details of the interested parties to other companies that are managed by GYRPROMLUX so that they can send you commercial information of its products in the real estate sector. 

Only if the person concerned has consented to such treatment, GYRPROMLUX shall treat such information in any of its phases in order to keep you informed of other promotions or that other companies can learn about your data to send information associated with it. The data subject always can revoke the consent given. GYRPROMLUX in the rest of the documentation associated with the sale of the property includes mechanisms of revocation of consent, but, in any case, you can always revoke such consents, through a written communication, along with a copy of your ID, to the following address : Avenida Alameda del Mar, 47, 29603, Marbella, Malaga or via e-mail : altair.madrid@yahoo.es. 

6. Data processing Web:

If the interested party wants to know the treatments of personal data that GYRPROMLUX carried out through altair.madrid@yahoo.es you can go to the following pieces of information:

  • Privacy policy
  • Cookie policy

If the interested party wants to know the treatments of personal data that GYRPROMLUX carried out through altair.madrid@yahoo.es you can go to the following pieces of information:

  • Privacy policy
  • Cookie policy

Who will communicate your personal data?

  • Only in the case that the person concerned has given his explicit consent, through the mechanism provided for such purpose, GYRPROMLUX can send the contact information to the rest of companies that are managed by GYRPROMLUX so that they can refer the interested commercial information.
  • According to the temporal phase of the relationship with the interested: 
  • In the phase of request of information, GYRPROMLUX will not communicate your data to any third party, beyond the providers of GYRPROMLUX, as stated in the last paragraph of this section.
  • At the stage of choosing the property, GYRPROMLUX can communicate data of the interested party: 
  • Group companies GYRPROMLUX for purposes related to the prevention of money laundering and financing of terrorism.
  • In the case that the data subject is interested in the financing of the property, your information may be disclosed to the financial institutions.
  • At the stage of sale:
  • Financial institution for the management of the funding and potential subrogation of rights in rem. 
  • Insurance entities of the contract.
  • Agencies and public institutions of the General State Administration, the Autonomous and Local Administrations.
  • Security forces and Bodies in the case of GYRPROMLUX be required to provide certain information.
  • Courts and tribunals in the case that there is any proceeding or dispute of the contract of sale
  • Entities involved in the process of the preparation of the property, either utilities or assemblies both in a phase prior to the delivery of housing, as in a later phase in the event that it is necessary to some arrangement, modification, or additional material. 
  • Finally, GYRPROMLUX account with third party service providers who may have access to personal data of the interested parties on the occasion of the delivery of their services, such as suppliers, materials, maintenance, control and monitoring of works, architects, technical work, auditors, experts, lawyers, managers, computer maintenance, financing services, potential investors, administrative services and destruction of documentation, among others. GYRPROMLUX pre-selected these vendors on the basis of criteria of compliance in terms of data protection, has signed with them all contracts in the field and controls that they comply with their obligations in the matter. 

International Data transfers 

It informs the interested party that GYRPROMLUX does not make international transfers of your data.

Potential claims or exercise of data protection rights

The interested party can exercise the rights of access, rectification, suppression, limitation, opposition, portability concerning their personal data, as well as the right to withdraw the consent given, by requesting in writing by e-mail: altair.madrid@yahoo.es or letter addressed to the registered office of GYRPROMLUX indicated above, attaching a copy of your ID card. You can also bring any type of claim of protection of data at the above address or you can go to the Spanish Agency of Data Protection supervisory authority in the matter of data protection, http://www.agpd.es