PRIVACY POLICY

IDENTIFICATION
- Data controller: MADRID365 LIVING, S.L. (hereinafter, “CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID“)
- Tax ID: B16483562
- Registered office: Street Núñez de Balboa, 12, 28001, Madrid (Spain)
- Email: [email protected]
- Data Protection Officer: [email protected]
INFORMATION
- By accepting this Privacy Policy, the user (hereinafter, the “User”) is informed that the personal data, data derived from their browsing and any other data that they may provide in the future, that they provide or are collected through the website located at URL https://www.christiesrealestate-madrid.com/ (hereinafter, the “Website“) or through any other computer or conventional means, will be processed by CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID.
  The User must carefully read this Privacy Policy, which has been drafted in a clear and simple way to facilitate its understanding, and the User may determine, freely and voluntarily, if they wish to provide their personal data to CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID.
OBLIGATION TO PROVIDE DATA
- The data requested in the forms on the Website are, in general, mandatory (unless otherwise specified in the required field) in order to comply with the purposes for which they are being collected.
  Therefore, if the User does not provide them or does not provide them correctly, the User’s requests will not be able to be attended, without prejudice to the fact that they will be able to freely view certain contents of the Website
SOURCE OF DATA
- The data processed by CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID for the purposes listed in the following section come from:
  - From the User himself: the data provided by the User through the different forms on the Website, provided by the User himself through electronic or conventional means, data obtained from the User’s use of the Website and from his or her browsing of the Website (through cookies or data storage and retrieval devices), as well as the information obtained from the User’s mobile device, in accordance with the consents that, where appropriate, they give to CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID.
  - Provided by third parties responsible for the data: in those cases in which a person other than the User provides personal data of third parties, said person guarantees that they have the necessary legitimacy to provide this information and that they have previously informed the owners of the data about the purpose of communicating the same to CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID.
- In these cases, the responsibility derived from the veracity, accuracy and legality of the data falls exclusively on the person who provides them.
FOR WHAT PURPOSE WILL CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID PROCESS THE USER’S DATA?
- CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID will process the User’s data for the following specific purposes:
  - Management and attention to requests for information, contact or any other query related to the properties selected by the User.
  - Sending commercial communications: managing the sending of commercial communications to Users, by electronic and/or conventional means.
  - Sending commercial communications to CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID client Users: to manage the sending of commercial communications to CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID client Users or collaborators, related to services similar to those already contracted, by electronic and/or conventional means.
  - Collection and storage of the User’s data based on their browsing preferences, resorting to their behaviors on the Website through cookies or similar storage technologies.
  - Comply with legally established obligations: when the processing is necessary to comply with a legal obligation arising from Spanish law or European Union law and which may be applicable to CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID.
  - Preparation of reports, statistics and internal analysis to improve services and detect misuse on the Website: analyse, manage and prepare internal reports and statistics on the behaviour of Users in order to implement improvements to the Website.
  - Management and selection of candidates registered for job offers available on the Website: to manage, process, contact and select the data of Users who register for a job offer available on the Website
WHAT USER DATA WILL CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID PROCESS?
- During the use of the Website, the following personal data may be processed:
  - Management and attention to requests for information, contact or any other query related to the properties selected by the User:
    - Identification data: name, surname, ID number, passport or similar document.
    - Contact details: email address, telephone number.
    - Economic data.
    - Location data: User’s address, country.
    - Browsing data on the Website.
    - Additional data: any other data that the User provides.
  - Sending commercial communications:
    - Identification data: name, surname.
    - Contact details: email, phone number.
  - Sending commercial communications to CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID client Users:
    - Identification data: name, surname.
    - Contact details: email, phone number.
  - Collection and storage of the User’s data based on their browsing preferences, resorting to their behaviors on the Website through cookies or similar storage technologies:
    - Identification data: name, surname.
    - Contact details: email, phone.
    - Data on social circumstances: language.
    - Location data: country.
    - Data about the services requested.
    - Browsing data on the Website and on other portals: IP, advertising ID, your behaviour on the Website and on other portals.
  - Comply with the legally established obligations:
    - Identification data: name, surname, identification documents.
    - Contact details: email address, telephone number.
    - Other data: any other personal data that may be legally required.
  - Preparation of reports, statistics and internal analysis to improve the services and detect improper use on the Website:
    - Location data: country.
    - Browsing data on the Website and on other portals: IP, advertising ID, your behaviour on the Website and on other portals.
  - Management and selection of candidates registered in the job offers available on the Website:
    - Identification data: name, surname.
    - Contact details: email address, telephone number.
    - Professional data: profession, company, professional history, duration.
    - Academic data: training, educational centre, duration.
    - Other data: any data that the User may provide in their CV.
- In the event that the User provides data from third parties, he/she declares that he/she has their consent and/or sufficient legitimacy and undertakes to transfer the information contained in the Privacy Policy to them, exempting CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID from any liability in this regard.
WHAT IS THE LEGITIMACY OF THE PROCESSING OF USER DATA BY CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID?
- CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID processes the User’s data in accordance with the following legal bases:
  - Management and attention to requests for information, contact or any other query related to the properties selected by the User: this data processing will be based on contractual performance.
  - Sending commercial communications: the processing derived from this purpose is legitimised by the consent that the User may withdraw at any time.
  - Sending commercial communications to CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID client Users: the processing derived from this purpose is legitimised by legitimate interest, based on the exception provided for in article 21.2 of Law 34/2002, of 11 July, on information society services and electronic commerce and the provisions of recital 47 of the GDPR. The legitimate interest is based on direct marketing in order to offer the User services that may be of interest to them and thus achieve their loyalty. However, the User has the right to object to this processing at any time.
  - Collection and storage of the User’s data based on their browsing preferences, using their behaviour on the Website through cookies or similar storage technologies: the processing derived from this purpose will have as a basis of legitimacy the consent, which the User provides by ticking the corresponding box and which may be withdrawn at any time.
  - Comply with legally established obligations: all processing derived from this purpose will be based on compliance with a legal obligation.
  - Preparation of reports, statistics and internal analyses to improve services and detect improper use on the Website: all processing derived from this purpose will be based on legitimate interest, recognised by data protection regulations. This legitimate interest is based on being able to offer Users the services of CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID with the best possible quality and experience.
  - Management and selection of candidates registered for the job offers available on the Website: the legal basis for the processing is the execution of precontractual measures.
- The consents obtained for the aforementioned purposes are independent, so the User may revoke only one of them, not affecting the others.
DATA RETENTION
- The User’s personal data will be kept by CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID for the following periods:
  - Management and attention to requests for information, contact or any other query related to the properties selected by the User: this data will be kept for the duration of the relationship with the User and, once it has ended, for the period of limitation of any legal actions that may arise from it.
  - Sending commercial communications: this data will be processed in accordance with this purpose until the User withdraws the consent previously granted.
  - Sending commercial communications to Users who are customers of CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID: this data will be processed until the User opposes the sending of commercial communications.
  - Collection and storage of the User’s data based on their browsing preferences, using their behaviours on the Website through cookies or similar storage technologies: this data will be processed until the User opposes the processing and, in no case, will it refer to a period exceeding one (1) year.
  - Comply with legally established obligations: this data will be kept for the legally established periods.
  - Preparation of reports, statistics and internal analysis to improve the services and detect improper use on the Website: this data will be kept for the period necessary to process and prepare the aforementioned reports, as well as to detect possible misuse and, once these periods have expired, during the limitation periods for possible legal actions.
  - Management and selection of candidates registered in the job offers available on the Website: the data will be kept for the period necessary to process the job application, however, in the event of not being selected, the data will be kept for a maximum period of one (1) year.
WITH WHOM WILL THE USER’S DATA BE SHARED?
- All personal data provided by the User through the Website may be communicated to:
  - Public Administrations, in the cases provided for by law, based on compliance with a legal obligation.
  - Courts and Tribunals, in the cases provided for by law, based on compliance with a legal obligation.
  - Companies belonging to the CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID business group, for internal administrative purposes, commercial management, coordination of real estate services, intermediation in operations, customer management and monitoring of business opportunities, based on the Group’s legitimate interest in the efficient and coordinated management of its activity, as well as, where appropriate, for the execution of the contractual relationship requested by the User. The entities of the Group will act as independent
    controllers.
  - Property owners, potential buyers or tenants, notaries, financial institutions, appraisers, insurers or other parties necessary in the real estate transaction, when the communication is necessary for the management and formalisation of the sale, lease or other operation requested by the User, on the basis of the execution of the pre-contractual or contractual relationship.
  - Third-party service providers who may have access to the User’s personal data, who will process the personal data provided in the name and on behalf of CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID, for the purpose of providing services. CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID follows rigorous supplier selection procedures in order to comply with its data protection obligations, including the signing of the corresponding data processing contract in accordance with Article 28 of the GDPR.
INTERNATIONAL DATA TRANSFERS
- Some of the third-party providers listed in the previous section may be located or provide their services from countries outside the European Economic Area. In these cases, an international transfer of personal data may take place in accordance with Articles 44 et seq. of the GDPR.
- When the destination countries do not have an adequacy decision, CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID guarantees that it will adopt adequate guarantees to protect the User’s data, by signing the corresponding Standard Contractual Clauses (the “SCCs”) approved by the European Commission. Transfers may also be covered by one of the exceptions provided for in Article 49 of the GDPR, such as
  the explicit consent of the data subject, the need for the transfer for the performance of a contract or the formulation, exercise or defence of legal claims.
RESPONSIBILITY OF THE USER
- The User guarantees that he/she is over fourteen (14) years of age and that the data he/she provides to CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID is true, accurate, complete and up-to-date. To this end, the User is responsible for the veracity of all the data provided and will keep the information provided suitably updated, so that it corresponds to their real situation.
- In the same way, it guarantees that it has informed the third parties of which it provides its data, if it does so, of the aspects contained in this document. You also guarantee that you have obtained your authorisation to provide your data to CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID for the purposes indicated.
EXERCISE OF RIGHTS
- As the owner of the data, the User may send a letter to CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID, at the address indicated in the heading of this Privacy Policy, or by email to the address: [email protected], at any time and free of charge. If
  CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID has reasonable doubts regarding your identity, it may request additional information or documentation that allows it to be verified before fulfilling your request:
  - Right of access:
    - You have the right to be informed by CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID as to whether or not it is processing your personal data and, if so, to be able to access such data and receive information on the purposes for which they are processed, the categories of data affected by the processing, the recipients to whom your personal data were communicated and the expected period of data retention, among other information.
  - Right of rectification:
    - You have the right to request the rectification of inaccurate data concerning you when, among other reasons, these are no longer necessary for the purposes for which they were collected.
  - Right to erasure:
    - You have the right to request the deletion of personal data provided that the legal requirements are met.
  - Right to restriction of processing:
    - In certain circumstances (for example, in the event that the applicant contests the accuracy of their data, while their accuracy is verified), they may request that the processing of their personal data be restricted, which will only be processed for the exercise or defence of claims.
  - Revocation of consent:
    - You have the right to revoke the consent given for reasons related to your particular situation, in case the processing is based on your consent previously given (including processing for the purpose of direct marketing).
  - Total or partial opposition to processing:
    - You have the right to object to processing at any time if the processing is based on our legitimate interest or the legitimate interest of a third party. In this case, CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID will cease processing, unless there are compelling legitimate reasons.
  - Portability of your data:
    - You will have the right to receive the personal data you have provided to CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID in a structured, common and machine readable format, and to be able to transmit them to another data controller without being prevented from doing so by the person responsible to whom they have been provided, in the cases legally provided for this purpose.
  - Automated individual decisions:
    - In addition, in addition to the above-mentioned rights, in the event of automated decisions, including profiling, you have the right to obtain human intervention from CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID, to express your point of view and to challenge the decision.
  - Others:
    - Likewise, you may file a claim regarding the protection of your personal data with the Spanish Data Protection Agency, with registered office at Calle Jorge Juan, 6, 28001 Madrid and website www.aepd.es, when the User considers that CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID has violated the rights recognized by the applicable data protection regulations.
SECURITY MEASURES
- CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID will treat the User’s data at all times in an absolutely confidential manner and will maintain the mandatory duty of secrecy with respect to them, in accordance with the provisions of the applicable regulations, adopting for this purpose the necessary technical and organisational measures to
  guarantee the security of their data and prevent their alteration. loss, processing or unauthorised access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed.
CHANGES
- CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID reserves the right to revise its Privacy Policy at any time it deems appropriate, in which case it will be communicated to Users.
  For this reason, we ask the User to regularly check this privacy statement to read the most recent version of the Privacy Policy of CHRISTIE’S INTERNATIONAL REAL ESTATE MADRID.
ACCEPTANCE AND CONSENT
- The User declares to have been informed of the conditions on the protection of personal data, accepting the content of this Privacy Policy.