Data Protection Information

Data Controller	MAROSLO, S.L. ("SOLVILLA") Avda. Boulevar Príncipe Alfonso de Hohenlohe,1, Puerta 7, Marbella CP: 29602 (Málaga) Telephone: 952 765060 Email: info@solvilla.es / www.solvilla.es
Data Protection Officer	dpo@solvilla.es

What data processing does SOLVILLA perform?

The processing of personal data by SOLVILLA is differentiated based on the service provided, as described below:

SOLVILLA processes personal data as a result of its residential property development and marketing activities.
In this case, there are two possible scenarios:
1.a) SOLVILLA develops and markets its own homes.
1.b) SOLVILLA markets properties owned by third parties who come to SOLVILLA to assist with the sale of the property.

SOLVILLA processes personal data as a result of its project management activities.
SOLVILLA's project management division provides property renovation services.

The purposes, the legal basis associated with the processing, the categories of data processed and the storage periods for the personal data processed are set out below.

In any case, the information and type of data and processing provided for in Articles one to four are essential for managing the relationship between SOLVILLA and the data subject or for fulfilling the contract with SOLVILLA, and therefore, if the data subject wishes to exercise the right to cancel the information or object to any of the purposes indicated in these sections, they must first terminate the contract.

1. Request for information and visits phase:

SOLVILLA will process the personal data of data subjects to process their request, whether they are interested in buying or selling a property or in project management services. In this interest, SOLVILLA will process data subjects' personal data for the purpose of scheduling meetings or visits to the different properties.

In this case, SOLVILLA may collect personal data in the following ways:

Directly from the data subjects, either in person, by telephone or through the different web forms on SOLVILLA's website.

From SOLVILLA's exclusive agent partners.

From the estate agents with whom SOLVILLA has collaboration agreements

From third party websites and social netwoks (e.g. Idealista) where properties marketed by SOLVILLA may be advertised.

Based on the request received, SOLVILLA will send the data subject information about the SOLVILLA service they are interested in or will arrange the necessary meetings or visits.

Lawfulness in processing personal data: SOLVILLA processes the information provided based on the processing necessary to address the requests of data subjects seeking information on the services or properties marketed by SOLVILLA. (Article 6(1)(b) GDPR).

Categories of personal data: The personal data that SOLVILLA will process at the time of the request for information are full name, address, email address, details of the service or property of interest, and, if applicable, the agent or agency involved in the request. These data are necessary for scheduling visits.

Data storage: SOLVILLA will store data subjects' personal data for the duration of the marketing period of the property in question. If the data subjects finally decide to buy the property, SOLVILLA will process the information corresponding to the reservation in accordance with the data processing envisaged for these phases. If, in the end, the data subjects do not buy the property, SOLVILLA will not process this information, except in the case envisaged in point 5 on commercial information. See point 5. Commercial Information.

2. Property reservation phase:

SOLVILLA will process data subjects' personal data to manage the reservation of the property. This reservation can be made through a reservation contract or through the formalisation of a deposit contract between the buyer and the property owner.

Lawfulness in processing personal data:

SOLVILLA processes the information provided based on the processing necessary to address the requests of data subjects to manage property purchase reservations, the marketing or sale of which (if SOLVILLA the developer) is performed by SOLVILLA (Article 6(1)(b) GDPR).

SOLVILLA will manage the execution of the reservation agreement, which will include the seller's personal information (when SOLVILLA is not the owner of the property) and the buyer's details.

SOLVILLA will hold the deposit for the reservation of the property.

SOLVILLA will inform all the designated sales agents of this reservation so that they can take the necessary steps to cease marketing the property.

If SOLVILLA is also the developer, it will process the data resulting from the payment of the agreed earnest money or the specific refund of the different amounts of the reservation on the agreed terms.

As soon as the property is reserved, SOLVILLA will also implement all the obligations derived from AML/CFT regulations on the processing of personal data as part of the identification obligations. (Article 6(1)(b) GDPR). In this case, the data subject will be informed that SOLVILLA can obtain this information from the different estate agencies with which it collaborates. We also inform you that SOLVILLA has performed a Data Protection Impact Assessment that includes the risks and controls defined to reduce or avoid these risks.

Categories of personal data: The personal data that SOLVILLA will process when you reserve the property will be your full name, address, email address, details of the property of interest, the sales agent assigned to your request for information, the amounts associated with the reservation, bank account information, reservation or deposit documents, the expected timeframe for executing the contract of sale and the identification documents required by SOLVILLA to comply with AML obligations. SOLVILLA may also obtain additional data from common information files for AML purposes, and from official public registers. All the personal data identified are necessary to process the reservation or to comply with the stated legal obligations.

Data storage: SOLVILLA will store your personal data during the reservation period, which may be extended if the sale goes through. If the sale of the property does not go through, your data will be blocked for a period of ten years to comply with the regulatory documentation storage regulations in AML/CFT matters.

3. Purchase formalisation phase

SOLVILLA will process the data of the buyers to manage and execute the contract of sale and its notarisation in a deed before the chosen notary.

Lawfulness in processing personal data: When SOLVILLA is a developer, it will process the information provided based on the processing necessary to execute a contract of sale and purchase and notarise the public deed before the notary chosen by the data subject and SOLVILLA. When SOLVILLA is only the marketer, it will send the information to the seller or the third party acting on behalf of the seller so that the seller and the buyer can completed the property sale transaction (both cases based on (Article 6(1)(b) GDPR). These legal relationships will involve the following processing of personal data:

The necessary steps to execute the conveyance deed/contract of sale.

Documentary/contractual, accounting, tax and administrative management.

Management and, where appropriate, communication of data with public registries, agencies, lawyers, insurance companies, banks and notaries involved in the process.

Pre-sales and post-sale management. All activities related to the needs that may arise from making properties available.

Compliance with identification obligations arising from AML/CFT regulations (Article 6(1)(c) GDPR). In this case, we inform you that, at this stage, SOLVILLA may complete this information, and report any necessary data to competent authorities that may require information.

SOLVILLA will also send personal data of its customers to the competent tax authority to comply with tax obligations (Article 6(1)(c) GDPR). Depending on the data subject's nationality, the Spanish tax authority may also communicate the personal data of SOLVILLA's clients to tax authorities in other countries, including outside the European Union.

Only in cases where the data subject has consented to the financing of the property may their data be communicated to the banks with which SOLVILLA works to perform the financial transaction to purchase the property in question. (Article 6(1)(a) GDPR).

Categories of personal data: The personal data that SOLVILLA will process on execution of the property conveyance will be first and last name, address, email address, details of the property of interest, the sales agent assigned to your request for information, amounts associated with the reservation, bank account information, employment information, family information, financial situation information, tax information, reservation or deposit documents, execution of the contract of sale and identification documents required by SOLVILLA to comply with AML obligations. SOLVILLA may also obtain additional data from common information files for AML purposes, and from official public registers. SOLVILLA may also process the personal data of third parties provided by the buyer, such as: legal representatives, lawyers, processing agents, collaborators, guarantors, family members or other associated individuals in the event that personal and proprietary guarantees are provided.

With respect to the above processing of third-party data, the buyer confirms that this data is real and that the data subjects concerned have been informed and have agreed to SOLVILLA's processing of their personal data.

Data storage: SOLVILLA will store your personal data throughout the purchase process. Once the period of one and a half years has elapsed (the period envisaged for possible post-sale procedures), your data will be blocked for a period of ten years to comply with the regulatory documentation storage regulations in AML/CFT matters.

4. Project management services

If SOLVILLA is engaged to perform a renovation project, SOLVILLA will process the data of its customers to prepare the service proposal, and to implement the renovation management project.

Lawfulness in processing personal data: SOLVILLA will process its customers' personal data for contractual purposes (art. 6.1.b) of the GDPR) and to put the project into operation. This relationship will involve the following personal data processing:

Documentary/contractual, accounting, tax and administrative management.

Arranging meetings.

Obtaining data from public registries.

Processing administrative permits.

Providing data to architects, designers, operators, and other professionals involved in the renovation project.

Data storage: SOLVILLA will store the personal data throughout the project. Once it has been completed, this information will be blocked and deleted once the legal limitation period for any claims that may arise has elapsed.

5. Newsletters and commercial information

SOLVILLA has established a specific procedure through the website so that data subjects can subscribe to receive commercial information and the SOLVILLA Newsletter. The content of these communications will include market reports, lifestyle newsletters, property updates and event invitations and will be sent by email. This processing will be performed based on the data subject's consent when they are not yet SOLVILLA customers and when they are customers, they are given the option to refuse these communications (based on the provisions of section 22 of the Spanish Information Society Services Act) through the reservation agreements.

If there is interest in receiving commercial communications, SOLVILLA, either through calls from its agents or by email, will contact and inform you about other properties that it markets, other services related to the property sector and about works and repairs, events, or other products in the property sector to which SOLVILLA is a party. These commercial communications may be customised in advance according to your preferences or the history of transactions you may have with SOLVILLA.

Only if the data subject has consented to this processing or has not objected to it, SOLVILLA will process this information in any of its phases to send information about other exclusive properties. The data subject may always revoke the consent granted in writing sent together with a copy of their national identification document to the indicated address.

6. Whistleblower Channel

In accordance with the applicable regulations, SOLVILLA is obliged to implement a procedure so that relevant information regarding possible legal non-compliance can be communicated to the entity, even anonymously. SOLVILLA may process personal data derived from the possible communications that may exist in said channel. For more information, please consult with SOLVILLA's Data Protection Officer.

Who are your personal data communicated to?

Based on the time phase of the relationship with the data subject:

During the information request phase, SOLVILLA will not communicate your data to any third parties other than SOLVILLA's suppliers, as stated in the last paragraph of this section.

At the property reservation stage, SOLVILLA may communicate data subjects' information to:

To the marketing agents assigned to the property to reserve the property.

To the seller to execute the reservation agreement, or, where applicable, earnest money agreement.

At the conveyance stage:

Insurers of the contract.

Public bodies and institutions of the General State Administration, Regional and Local Administrations (they may also request information in the reservation phase).

Security forces and bodies if SOLVILLA is required to provide certain information.

Courts in the event of any proceedings or disputes arising from the contract of sale.

Companies involved in preparing the property, either utilities or fitters, both before the handover of the property, or at a later stage if any repairs, modifications or additional materials are required.

Lastly, SOLVILLA has third party service providers that may have access to data subjects' personal data in the course of providing their services, including maintenance companies, architects, building technicians, auditors, surveyors, lawyers, managers, IT maintenance, financing services, potential investors and administrative services, among others. SOLVILLA pre-selects these suppliers based on data protection compliance criteria, has signed data protection agreements with all of them and monitors their compliance with their data protection obligations.

International data transfers

The data subject is informed that SOLVILLA does not make international transfers of its data.

Where can I file complaints or exercise my data protection rights?

Data subjects may exercise their rights of access, rectification, erasure, restriction, objection and portability of their personal data, and the right to withdraw their consent, by writing to the following email address: protecciondedatos@solvilla.es or by letter addressed to SOLVILLA's registered office indicated above, enclosing a copy of their national identification document. You can also file any kind of data protection complaint at the above address or contact the Spanish Data Protection Agency, as the regulatory authority, http://www.agpd.es

In any case, the information and type of data and processing provided for in sections one to four are essential for managing the relationship between SOLVILLA and the data subject or for fulfilling the contract with SOLVILLA, and therefore, if the data subject wishes to exercise the right to cancel the information or object to any of the purposes indicated in these sections, they must first terminate the contract.