Privacy policy

WEBSITE PRIVACY POLICY

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, Sky Solutions Group (hereinafter also referred to as the SKY REAL ESTATE Website) undertakes to adopt the necessary technical and organisational measures according to the level of security appropriate to the risk of the data collected.

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 rules:

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

Identity of the personal data controller

SKY REAL ESTATE & FINANCIAL SERVICES S.L. B-87851150

Address: Avenida Manuel Fraga Iribarne 38. 1ºPlanta, Oficina 3, 28055, Madrid.

Contact telephone number: (+34) 913 60 60 06

Contact email: gdpr@skyrealestate.es

Activity: Legal, Real Estate, Financial and Real Estate Capital Investment Services

Register of Personal Data

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Sky Solutions Group through the forms provided on its pages will be incorporated into and processed in our filing system in order to facilitate, expedite and fulfill the commitments established between Sky Solutions Group and the User, or to maintain the relationship established in the forms filled out by the User, or to respond to a request or query from the User. Furthermore, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in Article 30.5 of the RGPD applies, a record of processing activities is maintained specifying, according to their purposes, the processing activities carried out and the other circumstances set out in the RGPD.

Principles applicable to the processing of personal data

The processing of the User's personal data shall be subject to the following principles set out in Article 5 of the RGPD and in Article 4 et seq. of Organic Law 3/2018, of 5 December, on Personal Data Protection and Guarantee of Digital Rights:

  • Principle of lawfulness, fairness and transparency: the consent of the User shall be required at all times following fully transparent information regarding the purposes for which the personal data are collected.
  • Principle of purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes.
  • Principle of data minimisation: personal data collected shall be strictly limited to what is necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: personal data must be accurate and always kept up to date.
  • Principle of storage limitation: personal data shall only be kept in a form which permits identification of the User for no longer than is necessary for the purposes of their processing.
  • Principle of integrity and confidentiality: personal data shall be processed in a manner that ensures appropriate security and confidentiality.
  • Principle of accountability: the Controller shall be responsible for, and be able to demonstrate compliance with, the above principles.

Categories of personal data

The categories of data processed by Sky Solutions Group are strictly identifying data. Under no circumstances are special categories of personal data within the meaning of Article 9 of the RGPD processed.

The legal basis for the processing of personal data is consent. Sky Solutions Group 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 shall have the right to withdraw their consent at any time. It shall be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent shall not condition the use of the Website.

On occasions when the User must or may provide their data through forms to make enquiries, request information or for reasons related to the content of the Website, they will be informed if the completion of any of these forms is mandatory because they are essential for the proper conduct of the operation carried out.

Purposes of processing for which personal data are intended

Personal data are collected and managed by Sky Solutions Group 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 filled out by the latter, or responding to a request or query.

Likewise, the data may be used for commercial personalisation, operational and statistical purposes, and activities related to the corporate purpose of Sky Solutions Group, as well as for data extraction, data storage and marketing studies to tailor the Content offered to the User and to improve the quality, operation and navigation of the Website www.skyrealestate.es.

At the time the personal data are obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data are intended; that is, the use or uses to which the collected information will be put.

Retention periods for personal data

Personal data will only be retained for the minimum period necessary for the purposes of their processing and, in any event, only for the following period: 24 Months, or until the end of the commercial relationship, or until the User requests their erasure.

At the time the personal data are obtained, the User will be informed of the period for which the personal data will be stored or, where that is not possible, the criteria used to determine this period.

Recipients of personal data

The User's personal data will be shared with the following recipients or categories of recipients:

Group Companies: Sky Real Estate, Sky Law Bufete y Despacho de Abogados, Sky Financial Services and Sky Top Capital.

Where the Controller intends to transfer personal data to a third country or international organisation, at the time the personal data are obtained, the User will be informed of the third country or international organisation to which the data are intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In compliance with the provisions of Article 8 of the RGPD and Article 7 of Organic Law 3/2018, of 5 December, on Personal Data Protection and Guarantee of Digital Rights, only individuals over 14 years of age may lawfully give their consent for the processing of their personal data by Sky Solutions Group. In the case of a minor under 14 years of age, the consent of parents or legal guardians shall be required for the processing, and such processing shall only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

Sky Solutions Group undertakes to adopt the necessary technical and organisational measures, according to the security level appropriate to the risk of the data collected, in order to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised disclosure of or access to such data.

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

However, because Sky Solutions Group cannot guarantee the invulnerability of the internet nor the total absence of hackers or others who fraudulently access personal data, the Controller undertakes to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the RGPD, a personal data breach is understood as any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Personal data shall be treated as confidential by the Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.

Rights arising from the processing of personal data

The User has the following rights in relation to Sky Solutions Group and may therefore exercise them against the Controller, as recognised in the RGPD and Organic Law 3/2018, of 5 December, on Personal Data Protection and Guarantee of Digital Rights:

  • Right of access: This is the User's right to obtain confirmation as to whether or not Sky Solutions Group is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Sky Solutions Group has carried out or is carrying out, as well as, among other things, the available information on the origin of said data and the recipients of the communications made or planned for them.
  • Right to rectification: This is the User's right to have their personal data rectified if they prove to be inaccurate or, taking into account the purposes of the processing, incomplete.
  • Right to erasure ("the right to be forgotten"): This is the User's right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when these 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 objects to the processing and there is no other legitimate overriding ground to continue with it; the personal data have been unlawfully processed; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to erasing the data, the Controller, taking into account available technology and the cost of implementation, shall take reasonable steps to inform controllers processing the personal data of the data subject's request to erase any links to those personal data.
  • Right to restriction of processing: This is the User's right to limit the processing of their personal data. The User has the right to obtain restriction of processing where they contest the accuracy of their personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User requires them for making claims; or where the User has objected to processing.
  • Right to data portability: Where the processing is carried out by automated means, the User shall have the right to receive their personal data from the Controller in a structured, commonly used and machine-readable format, and to transmit them to another controller. Wherever technically feasible, the Controller shall transmit the data directly to that other controller.
  • Right to object: This is the User's right to prevent or cease the processing of their personal data by Sky Solutions Group.
  • Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individualised decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Thus, the User may exercise their rights by means of a written communication addressed to the Controller with the reference "RGPD-https://skyrealestate.es/", specifying:

  • First name, surname of the User and a copy of their DNI (national identity document). In cases where representation is admitted, identification of the person representing the User by the same means shall also be necessary, as well as the document proving representation. The photocopy of the DNI may be replaced by any other legally valid means proving identity.
  • Request with the specific reasons for the application or information to be accessed.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document supporting the request submitted.

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

Postal address: Avenida Manuel Fraga Iribarne 38. 1ºPlanta, Oficina 3, 28055, Madrid.

Email address: gdpr@skysolutionsgroup.es

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party web pages other than Sky Solutions Group, which are therefore not operated by Sky Solutions Group. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and privacy practices.

Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement of current regulations in the way their personal data are being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State in which they have their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Agencia Española de Protección de Datos (http://www.agpd.es).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions on personal data protection contained in this Privacy Policy, as well as accepts the processing of their personal data so that the Controller can proceed with it in the manner, during the periods and for the purposes indicated. The use of the Website shall imply acceptance of its Privacy Policy.

Sky Solutions Group reserves the right to modify its Privacy Policy according to its own criteria, or motivated by a legislative, case-law or doctrinal change by the Agencia Española de Protección de Datos. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware 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 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (RGPD) and Organic Law 3/2018, of 5 December, on Personal Data Protection and Guarantee of Digital Rights.