Personal Data Policy

Information on the processing of personal data of customers by GYRPROMLUX

Data controller

GYRPROMLUX, S.L. or any of the companies managed by Kronos depending on the Project (hereinafter “GYRPROMLUX”)

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

Data Protection Officer contact: altair.madrid@yahoo.es

¿What data processing does GYRPROMLUX carry out? 

The processing of personal data by GYRPROMLUX will depend on the nature of the relationship with the data subject. Below, we detail the purposes, legal bases for processing, categories of data processed, and retention periods for the personal data processed.

1. Information request phase:

GYRPROMLUX will process the personal data it collects directly from interested parties or through information request forms in order to respond to inquiries regarding the indicated promotion. In this regard, based on the request received, GYRPROMLUX will send the interested party information about the property promotion they are interested in. Finally, the application form requests the interested party’s consent to: (i) receive information about other promotions marketed by GYRPROMLUX and (ii) share their data with other real estate companies managed by Kronos so that they can send information about their products. This processing is detailed in section 5 of this document, “Commercial Information.”

Lawfulness in the processing of personal data: GYRPROMLUX processes the information provided based on:

  • The processing necessary for the application, at the request of the interested party, of a request for information on a property whose marketing and sale is the responsibility of GYRPROMLUX. (art. 6.1.b) of the General Data Protection Regulation).
  • The express consent of the interested party, given through the boxes established for this purpose in the information request form. (Art. 6.1.a) of the General Data Protection Regulation)

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

Data Retention: GYRPROMLUX will retain the personal data of interested parties for the duration of the marketing period for this promotion. If interested parties ultimately decide to purchase the property, GYRPROMLUX will process the information relating to the deposit or purchase in accordance with the data processing procedures established for those phases. If interested parties ultimately do not purchase the property, GYRPROMLUX will not process this information, except as provided in point 5 regarding commercial information. See point 5. Commercial Information.

2. Property selection phase:

GYRPROMLUX tratará sus datos personales con el fin de gestionar la elección del inmueble por parte del interesado. Esta elección podrá realizarse a través de un documento de señal. 

Licitud en el tratamiento de datos personales:

GYRPROMLUX tratará toda la información facilitada por el interesado con el fin de gestionar la elección de un inmueble para su futura compra (art.6.1.b) del RGPD). 

In this sense:

  • GYRPROMLUX will inform the designated marketers of this choice in order to carry out the formalization thereof.
  • GYRPROMLUX may carry out the processing of data derived from the execution of this document or from any management derived from the guarantee signal

Furthermore, from the moment the signal is received, KRONOS initiates all obligations arising from regulations on the prevention of money laundering and terrorist financing regarding the processing of personal data related to identification requirements (Article 6.1.c of the General Data Protection Regulation). In this case, the interested party is informed that KRONOS may share this information with the other companies it manages in the real estate sector for the sole purpose of expediting and managing the obligations incumbent upon those companies in this area. Details of these companies can be obtained by contacting altair.madrid@yahoo.es

On the other hand, only if the interested party has expressly consented to the financing option for the property (Art. 6.1.a) of the General Data Protection Regulation) may their data be shared with the financial institution with which GYRPROMLUX has a relationship to facilitate financing for this development, for the purpose of contacting them to discuss and manage the potential financial transaction for the purchase of the aforementioned property. This consent will, in turn, imply that the chosen financial institution will share their data with GYRPROMLUX once the transaction has been approved or denied, in order to proceed with the potential purchase of the property as appropriate.

Categories of personal data: The personal data that GYRPROMLUX will process when you select a property will be your name and surname, address, email address, details of the property of interest, the agent assigned to your information request, the deposit, bank account information, signed deposit documents, the expected timeframe for formalizing the purchase agreement, and identification documents required by GYRPROMLUX for compliance with anti-money laundering obligations. GYRPROMLUX may also obtain additional data from shared anti-money laundering databases and official public registries.

Data retention: GYRPROMLUX will retain your personal data for the duration of the property selection process, or for an extended period if the purchase is finalized. If the property purchase does not go through, your data will be blocked for ten years to comply with anti-money laundering and counter-terrorism financing regulations regarding the retention of documentation.

3. Formalization Phase of the Purchase and Sale:

GYRPROMLUX will process the buyers’ data in order to manage and formalize the purchase and sale agreement.

Lawfulness of processing personal data: GYRPROMLUX processes the information provided based on the processing necessary for the performance of a sales contract between the data subject and GYRPROMLUX (Art. 6.1.b) of the General Data Protection Regulation). In this regard, this relationship will involve the following processing of personal data:

  • Procedures required for the formalization of the purchase and sale agreement.
  • Document/contract management, accounting, tax and administrative management.
  • Management, and where applicable, communication of data with public registries, management companies, insurance companies and notaries involved in the process.
  • Pre- and post-sale management. All activities carried out based on the needs that may arise from making the property available.

Compliance with identification obligations arising from the applicable regulations (Art. 6.1.c) of the General Data Protection Regulation):

  • Prevention of money laundering and terrorist financing. In this case, it is reported that GYRPROMLUX may share this information with the other companies it manages, which have already been mentioned, for the sole purpose of expediting and managing the obligations that apply to these companies in this matter.
  • Data communications required with public bodies that may either require information or whose data communication derives from the regulations themselves, such as tax regulations.

Only if the interested party has consented to the financing of the property, their data may be communicated to the financial entity with which GYRPROMLUX maintains relations to carry out the economic operation of the purchase of the aforementioned property. (art. 6.1.a) of the General Data Protection Regulation).

Categories of personal data: The personal data that GYRPROMLUX will process when you select a property will be your name and surname, address, email address, details of the property of interest, the agent assigned to your information request, the deposit, bank account information, professional information, family information, financial situation information, tax information, signed deposit documents, the expected timeframe for formalizing the purchase agreement, and identification documents required by GYRPROMLUX for compliance with anti-money laundering regulations. GYRPROMLUX may also obtain additional data from shared anti-money laundering databases and official public records. Furthermore, GYRPROMLUX may process personal data of third parties provided by the buyer, such as legal representatives, collaborators, guarantors, family members, or other individuals in the buyer’s circle, in cases where personal and real guarantees are provided.

Regarding the aforementioned processing of third-party data, the buyer confirms that said data is real and that the affected subjects have been informed and have consented to the processing of their personal data by GYRPROMLUX.

Data retention: GYRPROMLUX will retain your personal data throughout the purchase process. After the initial 18-month period (the timeframe for any post-sales procedures), your data will be stored in a blocked state for ten years to comply with anti-money laundering and counter-terrorism financing regulations.

4. Quality surveys:

Furthermore, GYRPROMLUX will send you, based on its legitimate interest (Art. 6.1.f) of the General Data Protection Regulation), quality surveys regarding the service provided and the properties offered, in order to learn from customer feedback, improve the information and quality of processes, and consequently, the experience of all those interested in GYRPROMLUX promotions. GYRPROMLUX has conducted a weighting test of the aforementioned legitimate interest to verify that sending these satisfaction surveys to those interested in GYRPROMLUX promotions does not infringe upon their data protection rights. Following this analysis, GYRPROMLUX understands that these rights are not violated, given the clear information provided in this information document, as well as the possibility for interested parties to object to receiving these surveys either (i) by email at the time of the request and (ii) through the unsubscribe procedure included in that communication. Furthermore, GYRPROMLUX will not send these surveys to those who have not consented to receive information about other GYRPROMLUX Group promotions. If you would like more details about this weighting test, you can request them at altair.madrid@yahoo.es.

5. Commercial information:

In the information request forms, GYRPROMLUX will enable a mechanism for those who are interested to expressly consent to the following processing (art. 6.1.a) of the General Data Protection Regulation):

  • Specific consent for GYRPROMLUX to send commercial information about events or other promotions marketed by GYRPROMLUX, or other real estate products of which GYRPROMLUX is a part, either through calls from its representatives or via email. To prepare these communications, GYRPROMLUX will personalize them based on profiles derived from the promotional preferences expressed, or, if the recipient is a client, based on the personal data GYRPROMLUX holds regarding their preferences and transaction history.
  • Another specific consent for GYRPROMLUX to send the contact details of interested parties to other companies managed by GYRPROMLUX so that they can send them commercial information about their products in the real estate sector.

Only if the interested party has consented to such processing will GYRPROMLUX process this information at any stage in order to keep them informed of other promotions or so that other companies can access their data to send them related information. The interested party may always revoke the consent given. GYRPROMLUX includes mechanisms for revoking consent in the rest of the documentation associated with the sale of the property, but, in any case, this consent may always be revoked by sending a written communication, along with a copy of their ID, to the following address: Avenida Alameda del Mar, 47, 29603, Marbella, Malaga, or via email to: altair.madrid@yahoo.es.

6. Web Data Processing:

If the interested party wishes to know about the processing of personal data carried out by GYRPROMLUX through altair.madrid@yahoo.es, they can refer to the following information texts:

  • Privacy Policy
  • Cookies Policy

If the interested party wishes to know about the processing of personal data carried out by GYRPROMLUX through altair.madrid@yahoo.es, they can refer to the following information texts:

  • Privacy Policy
  • Cookies Policy

To whom is your personal data disclosed?

  • Only if the interested party has given their express consent, through the mechanism enabled for this purpose, can GYRPROMLUX send the contact information to the other companies managed by GYRPROMLUX so that they can send the interested party commercial information.
  • According to the time phase of the relationship with the interested party:
  • During the information request phase, GYRPROMLUX will not share your data with any third party, other than GYRPROMLUX’s suppliers, as stated in the last paragraph of this section.
  • During the property selection phase, GYRPROMLUX may share the interested party’s data with:
  • GYRPROMLUX Group companies for purposes related to the prevention of money laundering and terrorist financing.
  • If the interested party is interested in financing the property, their data may be communicated to financial institutions.
  • In the buying and selling phase:
  • Financial entity for the management of financing and possible subrogations of real rights.
  • Insurance entities of the contract.
  • Public bodies and institutions of the General State Administration, the Autonomous and Local Administrations.
  • Security forces and agencies in case GYRPROMLUX is required to provide certain information.
  • Courts and Tribunals in the event of any proceedings or dispute regarding the purchase agreement
  • Entities that participate in the process of preparing the property, whether supply or assembly companies, both in a phase prior to the delivery of the home, and in a later phase in case any repair, modification or additional material is necessary.
  • Finally, GYRPROMLUX uses third-party service providers who may access the personal data of interested parties in the course of providing their services. These providers include suppliers of materials, maintenance, construction monitoring and supervision, architects, construction technicians, auditors, experts, lawyers, managers, IT maintenance, financing services, potential investors, administrative services, and document destruction, among others. GYRPROMLUX pre-selects these providers based on their compliance with data protection regulations, has signed data protection agreements with all of them, and monitors their compliance with these obligations.

International Data Transfers

The interested party is informed that GYRPROMLUX does not carry out international transfers of their data.

Possible claims or exercise of data protection rights

The data subject may exercise their rights of access, rectification, erasure, restriction of processing, objection, and data portability with respect to their personal data, as well as the right to withdraw their consent, by submitting a written request via email to altair.madrid@yahoo.es or by letter to the registered office of GYRPROMLUX indicated above, attaching a copy of their national identity document. They may also file any type of data protection complaint with the address indicated above, or they may contact the Spanish Data Protection Agency, the supervisory authority for data protection matters, at http://www.agpd.es