Thank you for your interest in our company. The protection of your data has a particularly high priority for our company. The use of our website is possible without any indication of personal data. However, if a data subject wants to use special services of our enterprise via our website, processing of personal data could become necessary. If the processing of personal data is necessary, we will generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the GDPR, and in accordance with the country-specific data protection regulations applicable to our enterprise. By means of this data protection declaration, our company would like to inform data subjects about the rights to which they are entitled.
As the controller, we have implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website and our e-mail traffic. Nevertheless, Internet-based data transmissions can always have security vulnerabilities, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.
1. definitions of terms relating to our data protection policy
The data protection declaration is based on the terms used by the European Directive and Ordinance Maker when enacting the General Data Protection Regulation (GDPR/ GDPR). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
We use the following terms, among others, in this data protection declaration:
(a) personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject means any identified or identifiable natural person whose personal data are processed by the controller.
Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.
Profiling shall mean any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.
Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller or data controller
The controller or person responsible for processing is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided for under Union or Member State law.
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.
j) Third party
Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or the processor.
Consent is any freely given specific and informed indication of his or her wishes, in the form of a statement or other unambiguous affirmative act, by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.
2. person responsible
The person responsible within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:
Personal Property Consult, S.L.
Gran Via Puig de Castellet 1, Bloque 6
07180 Santa Ponsa
Tel +34 871 967 967
We process data in the context of administrative tasks as well as organisation of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. RGPD/DS-GVO, Art. 6 para. 1 lit. f. RGPD/DS-GVO. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.
In this context, we disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, organisers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. This data, most of which is company-related, is stored permanently until revoked.
4. rights of the user – rights of our customers
You can exercise the following rights at any time using the contact details provided by our data protection officer:
Information about your data stored by us and its processing,
Correction of incorrect personal data,
deletion of your data stored by us,
Restriction of data processing if we are not yet allowed to delete your data due to legal obligations,
objection to the processing of your data by us, and
Data portability, provided you have consented to the data processing or have concluded a contract with us.
If you have given us consent, you can revoke this at any time with effect for the future.
5 Legal basis for processing
Art. 6 I lit. a RGPD/DS-GVO serves as the legal basis for our company for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 I lit. b RGPD/DS-GVO. The same applies to processing operations that are necessary for the implementation of pre-contractual measures, for example in the case of enquiries about our products or services. If our company is subject to a legal obligation by which the processing of personal data becomes necessary, such as for the fulfilment of tax obligations, the processing is based on Art. 6 I lit. c RGPD/DS-GVO. In rare cases, the processing of personal data might become necessary in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result their name, age, health insurance details or other vital information needed to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d RGPD/DS-GVO.
Finally, processing operations could be based on Art. 6 I lit. f RGPD/DS-GVO. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47 sentence 2 RGPD/DS-GVO).
6 Duration of the storage of personal data
The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of the period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfilment or initiation of the contract. We reserve the right to store some data until revoked.
7. legal or contractual regulations
We inform you that the provision of personal data is sometimes required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner).
Sometimes, in order to conclude a contract, it may be necessary for a data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded.
8 Brokerage services
We process the data of our customers, contractual partners and interested parties (uniformly referred to as “customers”) in accordance with Art. 6 para. 1 lit. b. RGPD/DS-GVO in order to provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope and purpose and the necessity of their processing are determined by the underlying order. In principle, this includes inventory and master data of the customers (name, address, etc.), as well as contact data (e-mail address, telephone, etc.), contract data (content of the order, fees, terms, details of the brokered properties) and payment data (commissions, payment history, etc.). We may also process information on the characteristics and circumstances of persons or property belonging to them if this is part of the subject matter of our assignment. This may, for example, be information on mobile or immobile material goods.
If necessary for the performance of the contract or required by law, we disclose or transmit the clients’ data to providers of the brokered objects, service providers, such as cooperating companies, financial service providers, credit institutions, tax advisors, legal advisors and notaries within the scope of the conclusion and processing of contracts. Furthermore, we may engage subcontractors, such as sub-brokers. We obtain the consent of customers if this is required for the disclosure/transfer of customer consent (which may be the case, for example, in the case of special categories of data pursuant to Art. 9 RGPD/DS-GVO).
The deletion of the data takes place after the expiry of statutory warranty and comparable obligations, whereby the necessity of the storage of the data is reviewed every three years; otherwise, the statutory storage obligations apply.
In the case of statutory archiving obligations, deletion shall take place after their expiry. In particular, according to Spanish law, consultation protocols, broker contract notes and broker contracts must be kept for 5 years as well as generally 5 years for documents relevant under commercial law and 10 years for documents relevant under tax law.
9. CRM solution – onOffice
CRM system from onOfficeWe use the CRM system of the provider onOffice GmbH, Charlottenburger Allee 5, 852068 Aachen, in order to be able to process user enquiries more quickly and efficiently (legitimate interest pursuant to Art. 6 Para. 1 lit. f. RGPD/DS-GVO ).
onOffice only uses the users’ data for the technical processing of the enquiries and does not pass them on to third parties. In order to use onOffice, at least a correct e-mail address must be provided. Pseudonymous use is possible. In the course of processing customer enquiries or search requests, it may be necessary to collect further data (name, address).
If users do not agree to data collection via and data storage in onOffice’s external system, we offer them alternative contact options for submitting service requests by e-mail, telephone, fax or post.
The hosting services we use are for the provision of the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services, which we use for the purpose of operating this online offer.
In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer pursuant to Art. 6 (1) lit. f RGPD/DS-GVO in conjunction with Art. 28 RGPD/DS-GVO. Art. 28 RGPD/DS-GVO (conclusion of order processing agreement).
11. server log files
In server log files, our website provider collects and stores information that your browser automatically transmits to our website. These are:
Browser type and browser version
Operating system used
Host name of the accessing computer
Time of the server request
This data is not merged with other data sources. The data processing is based on Art. 6 para. 1 lit. b RGPD/DS-GVO, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.
12 SSL or TLS encryption
In order to protect your transmitted data in the best possible way, we use SSL encryption. You can recognise such encrypted connections by the prefix “https://” in the page link in the address line of your browser. Unencrypted pages are marked with “http://”.
Thanks to SSL encryption, all data that you transmit to this website – for example when making enquiries or logging in – cannot be read by third parties.
All e-mail traffic between you and our company is realised from our side via an encrypted connection (TLS).
13. contact form
Data transmitted via the contact form, including your contact details, are stored in order to process your enquiry or to be available for follow-up questions. This data will not be passed on without your consent.
The data entered in the contact form is processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a RGPD/DS-GVO). The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable software. Revocation of your consent already given is possible at any time. An informal communication by e-mail is sufficient for the revocation. The legality of the data processing operations carried out until the revocation remains unaffected by the revocation.
Data transmitted via the contact form will remain with us until you request us to delete it, revoke your consent to store it or there is no longer any need to store the data. Mandatory legal provisions – in particular retention periods – remain unaffected.
If you do not want cookies to be stored on your terminal device for the purpose of measuring reach, you can object to the use of these files here:
Cookie deactivation page of the Network Advertising Initiative: http://optout.networkadvertising.org/?c=1#!/
Cookie deactivation page of the US website: http://optout.aboutads.info/?c=2#!/
Cookie deactivation page of the European website: http://optout.networkadvertising.org/?c=1#!/
Popular browsers offer the setting option to not allow cookies. Note: It is not guaranteed that you will be able to access all functions of this website without restrictions if you make the corresponding settings.
15 Google Analytics
The controller has integrated the Google Analytics component (with anonymisation function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, compilation and evaluation of data about the behaviour of visitors to websites. Among other things, a web analysis service collects data on the website from which a data subject has accessed a website (so-called referrers), which sub-pages of the website have been accessed or how often and for how long a sub-page has been viewed. A web analysis is mainly used to optimise a website and to analyse the costs and benefits of internet advertising.
The operating company of the Google Analytics component is Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
The controller uses the addition “_gat._anonymizeIp” for web analysis via Google Analytics. By means of this addition, the IP address of the Internet connection of the data subject is shortened and anonymised by Google if access to our Internet pages is from a member state of the European Union or from another state party to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyse the flow of visitors to our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us showing the activities on our website and to provide other services in connection with the use of our website.
Google Analytics sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyse the use of our website. Each time one of the individual pages of this website operated by the data controller is called up and on which a Google Analytics component has been integrated, the internet browser on the data subject’s information technology system is automatically caused by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to track the origin of visitors and clicks and subsequently to enable commission calculations.
By means of the cookie, personal information, for example the access time, the location from which an access originated and the frequency of visits to our website by the data subject, is stored. Each time the data subject visits our website, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may share this personal data collected via the technical process with third parties.
The data subject can prevent the setting of cookies by our website at any time by means of an appropriate setting of the Internet browser used, as already described above, and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programmes.
Further information and the applicable data protection provisions of Google can be found at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail under this link https://www.google.com/intl/de_de/analytics/.
16 Google Fonts
In order to display our content correctly and graphically appealing across browsers, we use script libraries and font libraries such as Google Webfonts (https://www.google.com/webfonts/) on this website. Google Web Fonts are transferred to your browser’s cache to avoid multiple loading. If the browser does not support Google Web Fonts or prevents access, content will be displayed in a standard font and the display may differ from the actual display.
Calling up script libraries or font libraries automatically triggers a connection to the operator of the library. It is theoretically possible – although it is currently unclear whether and for what purposes – that the operators of such libraries collect data.
17 Google Maps
Detailed instructions on how to manage your own data in connection with Google products can be found here: http://www.dataliberation.org/.
18 Online presences in social media
We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users, because it could, for example, make it more difficult to enforce the rights of the users. With regard to US providers certified under the Privacy Shield, we point out that they thereby undertake to comply with the data protection standards of the EU.
Furthermore, user data is usually processed for market research and advertising purposes. For example, usage profiles can be created from the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data may also be stored in the usage profiles irrespective of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
The processing of users’ personal data is based on our legitimate interests in effectively informing users and communicating with users pursuant to Art. 6 para. 1 lit. f. RGPD/DS-GVO. If the users are asked by the respective providers for consent to the data processing (i.e. declare their consent e.g. by ticking a checkbox or confirming a button), the legal basis of the processing is Art. 6 para. 1 lit. a, Art. 7 RGPD/DS-GVO.
For a detailed description of the respective processing and the opt-out options, please refer to the information provided by the providers linked below.
In the case of requests for information and the assertion of user rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
– Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland)
Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com
Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active
– Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA)
Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
– Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA)
– LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) -.
Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy
Our website uses the visitor action pixel from Facebook, Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) for conversion measurement.
This makes it possible to track the behaviour of page visitors after they have been redirected to the provider’s website by clicking on a Facebook ad. This allows the effectiveness of the Facebook ads to be evaluated for statistical and market research purposes and future advertising measures to be optimised.
The data collected is anonymous for us as the operator of this website, we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with the Facebook data usage policy. This enables Facebook to serve advertisements on Facebook pages as well as outside of Facebook. This use of the data cannot be influenced by us as the site operator.
You can also deactivate the “Custom Audiences” remarketing function in the settings section for advertisements at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you must be logged in to Facebook.
If you do not have a Facebook account, you can disable usage-based advertising from Facebook on the European Interactive Digital Advertising Alliance website: http://www.youronlinechoices.com/de/praferenzmanagement/.
Deactivate Facebook Pixel. Here, a so-called “Opt-Out-Cookie” is set, which has the effect that the analysis of your page visit on our site will be prevented in the future. Please note that if you delete the cookies in your browser settings, this may result in the opt-out cookie also being deleted and you may have to reactivate it. The opt-out cookie remains active for 30 days.”
19 Newsletter data
To send our newsletter, we need an e-mail address from you. A verification of the given e-mail address is necessary and you have to agree to receive the newsletter. Additional data is not collected or is voluntary. The data is used exclusively for sending the newsletter.
The data provided when registering for the newsletter will be processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a RGPD/DS-GVO). You may revoke your consent at any time. For the revocation, an informal message by e-mail or you unsubscribe via the “unsubscribe” link in the newsletter is sufficient. The legality of the data processing operations already carried out remains unaffected by the revocation.
Data entered to set up the subscription will be deleted in the event of unsubscription. If this data has been transmitted to us for other purposes and elsewhere, it will remain with us.
The dispatch service provider may use the recipients’ data in pseudonymous form, i.e. without attribution to a user, to optimise or improve its own services, e.g. to technically optimise the dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
21 Newsletter performance measurement
The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or if we use a dispatch service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval are initially collected.
This information is used for the technical improvement of the services on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. The analyses serve us much more to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
As a responsible company, we do not use automatic decision-making or profiling.
We reserve the right to adapt this data protection declaration so that it always complies with the current legal requirements or in order to implement changes to our services in the data protection declaration, e.g. when introducing new services. The new data protection declaration will then apply to your next visit.
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