Culmia Desarrollos Inmobiliarios, S.L.U. (hereinafter, “the management company”), with its registered office in Madrid, at Calle Génova 27, 2ª Planta, with Tax ID number B-67186999, is a comprehensive property asset manager at the service of Polux Activos Inmobiliarios, S.L.U. , with the same registered address and Tax ID number B-88554282, which is the developer of its Group and the owner of the Finca Mossara development.

Basic information on data protection

Data controller and processor	The Developer is the controller of your data. The management company shall process your data as the Developer’s data processor. You can contact the management company by email at protecciondedatos@culmia.com.
Main purpose	The data provided by the data subjects shall be used, depending on each case, to establish, maintain and manage the commercial, contractual or pre-contractual relationship, to process your requests for information and to send advertising and commercial information.
Legitimising basis	The basis to legitimise the processing is the consent of the data subject and/or the preparation and development of the contractual relationship, as appropriate.
Retention period	The personal data provided shall be retained throughout the time required to fulfil the purpose for which they are collected and to determine any potential liabilities that may arise from the purpose, in addition to the periods established in the applicable regulations.
Potential recipients	Your data may be transferred to companies in the business group to which the management company belongs that are related to the property sector, other data processors employed by the management company or the Developer for the management of the commercial relationship and public bodies or authorities that so require in order to comply with the law or a court order.
Data protection rights	You may exercise your rights of access, rectification, erasure, portability and limitation and object to the processing of your data by contacting the management company at its registered office or protecciondedatos@culmia.com. Similarly, if you deem it necessary to do so, you may contact the Spanish Data Protection Agency (https://www.aepd.es) in order to safeguard your rights.

1.   Introduction

The Group undertakes to protect your privacy and process the personal data you provide us with solely for the purposes that you have indicated. We would like to explain how we collect these data and what we will do with them below. The Group complies with the requirements of the current data protection regulations and it is therefore aligned with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of the data of natural persons with regard to the processing of personal data and the free movement of said data and Organic Law 3/2018 of 5 December on the protection of personal data and guarantee of digital rights.

This privacy policy is applicable to the personal data of the customers and potential customers of the developers served by the management company. The data provided by the users of this website shall be processed by the management company as the data processor on behalf of the Developer, which is the data controller.

2.   Who is responsible for the processing of your data?

The management company shall process the data you provide us with as the data processor on behalf of the data controller, which is the property developer of the asset that you are interested in (Polux Activos Inmobiliarios, S.L.U.).

Moreover, if you consent to us sending you information on other property assets managed by the management company, your data will be managed on behalf of the owners of said assets. In any event, the management company shall act as the data processor of these developers.

3.   Why are we asking you for your data, what are we going to use them for and what is the legitimation for doing so?

The contact details we request from you are necessary for the purposes outlined in this Privacy Policy. Without them we wouldn’t be able to contact you to deal with your request for information or complete the procedures required to maintain a commercial relationship. We therefore ask you to constantly provide us with accurate information and update it if necessary.

We list the different purposes for which we are going to process your data and the bases that legitimise the processing below.

• Dealing with requests for information and managing the pre-contractual and contractual relationship. By virtue of providing your details in the contact spaces enabled on this website and accepting the privacy policy you consent to us contacting you to provide you with information on the products you are interested in. Should you continue your business relationship with us, the data provided may be used to complete the pre-contractual and contractual procedures required for the acquisition of the properties you are interested in.
• Sending of commercial correspondence by various means, including electronic means, in the event that you have expressly granted your consent by ticking the corresponding box. This commercial correspondence shall refer to the assets managed by the management company that belong to different developers, as well as events related to the property sector that may be of interest to you.

4.   Who do we transfer your data to?

Generally speaking, we do not transfer your data to third parties without your express consent. However, as indicated in this policy, the data are transferred to the owners of the assets, who are responsible for them.

They may also be transferred to the providers required for the provision of the services in question, with whom the management company has a data processing contract to guarantee both confidentiality and the relevant security measures. If required, you shall be contacted directly by these providers within the framework of the purposes set out in this privacy policy.

If necessary, they shall be transferred to public authorities in order to comply with the requirements of said authorities and the applicable regulations.

5.   Data retention

The retention periods vary, depending on your relationship with us:

• We shall retain the contact details you have provided us with until you opt out of receiving marketing correspondence from us.
• Should you enter into a pre-contractual or contractual relationship with us, we shall retain them throughout the legal periods established by the applicable regulations. The data shall be appropriately blocked while they are retained for as long as any liabilities regarding our contractual or pre-contractual relationship may arise, as well as for the fulfilment of any other legal obligations.

6.   Data protection rights

These rights include:

• Access: knowing which of your data we are processing
• Rectification or erasure: correcting incorrect or inaccurate data or deleting them
• Portability of your data: requesting that we provide you with your data in a structured, commonly used and machine-readable format.
• Limitation: limiting the purposes for which you have provided us with the data
• Objecting to the processing: withdrawing the consent given or objecting to the processing.

To exercise these rights you should send a request to the management company at Calle Génova, nº 27, 2ª planta, 28004, Madrid or protecciondedatos@culmia.com, indicating the right you wish to exercise and enclosing/attaching a copy of your ID card or any other document that proves your identity.

In order to resolve any queries regarding the processing of your personal data, you can contact the Data Protection Officer of the management company at protecciondedatos@culmia.com.

Similarly, if you deem it necessary to do so, you may contact the Spanish Data Protection Agency (https://www.aepd.es) in order to safeguard your rights.