1. Identity of the data controller

Cupatena Servicios y Gestiones, S.L.U., with registered office at calle Albacete nº 3, 28027 Madrid and with CFI B88153242 (‘Cupatena’) is the owner and administrator of the name www.villasaltaona.com (hereinafter, the ‘Website’):

2. Aceptación e identificación del usuario

By accessing and browsing this Website, the User acknowledges having read and accepted our Privacy Policy and expressly accepts its application to the use of the Website while browsing.

Cupatena may offer, through the Website, services that may be subject to their own particular conditions, about which Users will be informed in each specific case.

The User must always identify him/herself with his/her personal e-mail address.

The User guarantees both to Cupatena and to third parties the quality of the information provided, that is to say, that the data and information provided are real, truthful, up to date and also belong to the User and not to third parties. The User will be responsible for the veracity of the personal data provided and will hold Cupatena harmless against claims from third parties or against sanctions or damages that may be suffered in the event of non-compliance.

In accordance with current legislation in Spain, in order to use the Website, the User must be over 18 years of age, or have the authorisation of their parents and/or legal guardians if they are over 14 years of age and under 18. Therefore, by accepting this Privacy Policy, the User guarantees that they are over that age or that they have the aforementioned parental authorisation to register with Cupatena, and they take full responsibility for this declaration.

3. Purpose of the treatments
   
   A) Provision of the services offered by Cupatena in the marketing of real estate assets

By means of your request and interest in any of the properties that we market, your personal data will be processed for:

• process your registration as an interested customer and potential buyer;
• to process your request for a visit to the property you are interested in;
• process the submission of your bid for the property you are interested in;
• process and respond to your questions, queries or complaints.
• process your registration as a web user;
• to process your contact request to find out more about the property you are interested in or to arrange a viewing;
• process the submission of your bid for the property you are interested in;

1. B) communication of data to Public Bodies and Public Administrations in compliance with legal obligations.

Cupatena has to comply with the obligations established by the regulations on the Prevention of Money Laundering and Financing of Terrorism, which could involve requesting data from Public Bodies in order to verify the information provided, in the cases established by law.

C) communication of data to the company that owns the property and to the other companies in its Group.

Based on the execution of the contractual relationship, Cupatena may communicate your data to the company that owns the real estate asset in which you have shown interest, as well as to the other companies belonging to its Group, in order to manage the marketing of said property by Cupatena.

 D) sending commercial communications about similar properties and Cupatena offers and promotions.

If you give your consent, Cupatena may send you segmented commercial information about the properties in which you have previously shown interest, as well as offers and promotions from Cupatena that may be of interest to you, either directly or because they are related to the provision, improvement and updating of our services.

At any time and free of charge, you may object to this purpose in order not to receive new commercial information, offers and promotions, indicating this by post to the above address or by e-mail to the address dpo@hipoges.com. Likewise, in any electronic commercial communication you will be informed, once again, of your right to object to the sending of commercial communications.

 E) communication of data to other Group companies, to third parties providing services related to the real estate sector and to Partner companies

 Cupatena may communicate your data to:

1. Other Group companies that provide services related to the sectors related to the marketing of real estate assets, including their financing, promotion, securitisation and others of added value to the same.
2. Third-party companies that provide services related to the sectors related to the marketing of real estate assets, including their financing, development, securitisation and other value-added services.

The communication of your data will be carried out so that these companies can send you, directly and without the intermediation of Cupatena, offers and promotions relating to their products and services, or manage with you, upon request, the marketing or provision of any of their products or services.

4. Legitimación
   
   

   The legitimacy for the processing is the contractual relationship for the provision of the requested service, the legitimate interest in the maintenance of the existing relationship and/or, in certain cases, consent.

   The processing of your data for the ‘Sending of commercial communications’ and ‘Cupatena offers and promotions’ is based on the consent given by the user in each case.

5. Duración

Cupatena will retain your personal data for the time necessary to provide the requested service and/or to achieve the intended purpose of the processing.

Subsequently, provided that the user has not exercised his/her right to deletion, his/her data will be kept for the legal periods that may be applicable in each case, taking into account the type of data, as well as the purpose of the processing and, where appropriate, the time during which any type of liability may be demanded as a result of the relationship maintained between the User and Cupatena.

In the event that the Prevention of Money Laundering and Terrorist Financing regulations apply to the processing of your data, Cupatena is obliged to retain your personal data for a period of ten years.

6. Data communication

Cupatena may communicate your data to:

Authorities or official bodies in the framework of the fight against fraud, the financing of terrorism and the prevention of money laundering, such as SEPBLAC when so required.

Courts and tribunals, if Cupatena is required to disclose personal data in the context of a judicial investigation.

To the companies that own the property and to the Group companies.

To the companies and Partners for which you have given your consent.

7. Security

In relation to the personal data collected, Cupatena has adopted and will adopt the necessary technical and organisational measures to guarantee their protection and prevent their alteration, loss, processing and/or unauthorised access, taking into account the state of the art, the nature of the data stored and the risks to which they are exposed, complying at all times with the applicable regulations.

In particular, measures have been adopted to achieve the basic security objectives, such as confidentiality (limiting access to information by unauthorised persons), integrity (maintaining reliable and quality information) and availability (guaranteeing access to the information system on request by an authorised user).

8. User rights

Users have the right to exercise at any time, under the terms provided by the regulations in force at any time, the rights of access, rectification or deletion of data, as well as to request that the processing be limited, oppose the same, or request the portability of their data.

Likewise, Users may revoke the consent given at any time.

To exercise any of these rights, you must send a written communication to Cupatena, enclosing a copy of your ID card/passport. You may send such communication (a) by post to the attention of the Data Protection Delegate and to the address indicated in the first section of this document, or (b) by sending an e-mail to the following address: dpo@hipoges.com

You can contact our Data Protection Delegate (a) by post at the address indicated in the previous section of this document, or (b) by sending an e-mail to the following address: dpo@hipoges.com.

In addition, we inform you that you can always turn to the Spanish Data Protection Agency (www.agpd.es) to request protection or lodge a complaint in relation to the processing of your personal data.

9. Applicable law and jurisdiction

The relationship between Cupatena and the User shall be governed by Spanish law.

Any dispute shall be submitted to the Courts and Tribunals of Madrid.