PRIVACY POLICY

ELIX ADVICE, S.L. (hereinafter and jointly, “ELIX”, “we”, “us” or “ours”), is a leading Spanish investment management group focused on value-added residential assets in tier-1 metropolitan areas.

We deem the privacy of persons to be important, which includes both visitors to our website, www.elix.group (hereinafter, the “Website”), and any other affected persons who provide us with information through the same, whose data are processed by ELIX as a part of providing services (hereinafter and jointly, “you” or the “user(s)”). In this regard, ELIX undertakes to process your data in compliance with personal data protection regulations that are applicable and in force at any given time. Specifically, ELIX shall comply with the provisions set forth in the Organic Act 3/2018 of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights; with the provisions set forth in Regulation (EU) 2016/679, of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC; and with the provisions set forth in any other correlated regulations that may be applicable and in force at any given time.

ELIX reports its Privacy Policy in order to make users aware of the processing of their data. If you’re a user of the Website, the following information may be of interest to you:

1. Who is the controller of your data?

Identity: ELIX ADVICE, S.L.

Tax ID Number (C.I.F.): B87995189

Address: C/ Montesa, 35, Esc. Dcha., 4ª planta - 28006 Madrid

Telephone: (+34) 91.838.00.4

E-mail: diana.salarich@elix.es

2. When do we collect your personal data?

The Website has a commercial nature showing you information about our company, and if you’re interested you can contact us to know more about our services.

Personal data means any information relating to an identified or identifiable natural person (like you), such as your name and last name, telephone number or e-mail address. From our website personal data can be collected through the contact form. The Website has a contact form with the purpose of contacting us for request information about or services and/or make any requests, questions and/or consultations. With this form we ask you to identify you and to provide us data contact.

We will not collect or process any special categories of personal data (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic or biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation), unless users have explicitly provided it to us.

3. What are the main purposes for processing your data?

When you send us data through the contact form, we will use it to (1) analyze and manage your requests, questions and consultations by contacting you with the purpose of giving you an answer and any information requested by you, and to (2) contact you in order to inform about our services.

4. What is the legal basis for processing your data?

The legal basis for processing your data is your consent when you’re sending us your data through the form.

5. Who could be the recipients of your data?

We hereby inform you that we will never transfer to or exchange your personal data with third parties without consent. Nevertheless, your data could be accessed and/or transferred to:

  • Authorized ELIX personnel or their representatives acting on behalf of ELIX, always being subject to the applicable data protection regulation.

  • Competent bodies and/or authorities in cases in which there is a legal obligation to do so.

  • Suppliers and/or outside service providers, with whom we have signed the legally required contracts according to which compliance with personal data protection legislation is guaranteed, in addition to their obligations as data processors.

  • Intra-group transfers: On the basis of the proper functioning of the corporate group and based on the legitimate interest pursued by all the entities of ELIX Group, it is necessary to transmit personal data within the corporate group for internal administrative purposes, which may include your personal data.

6. How long do we store your data?

ELIX will process your personal data during the necessary period to comply with the purposes set out in this Privacy Policy, as well as to keep your personal information in compliance with the provision of the applicable law and regulations, especially in relation to the legal statute of limitations. Our retention criteria are determined by:

  • The purpose of the collected data and the fulfilment of it.

  • The reasons why the data is collected: e.g. if the legal basis of processing is your consent, you can withdraw it at any time.

  • Obligatory retention periods according to contractual and/or regulatory requirements.

Please, bear in mind that in some cases ELIX will retain your data dully blocked for the period legally required for the compliance of any contractual and/or legal obligations.

7. What are your rights when you provide us with your data?

If we process your personal data, you’ve the following rights:

  • Right to request access to personal data: you may ask ELIX if it is processing your data, and if it is, you may have access to the same.

  • Right to request that data be rectified if they are inaccurate or that data be completed if they are incomplete.

  • Right to request the erasure of your data.

  • Right to request the restriction of processing: in this case, we will only keep data for exercising or defending against claims.

  • Right to object to processing: ELIX will cease to process personal data, unless they must continue to be processed for legitimate reasons or for exercising or defending against possible claims.

  • Right to the portability of data: in the event that a user would like for their data to be processed by another data controller, ELIX will facilitate the transfer of their data to the new controller.

  • Right to not be the object of automated decision-making regarding your personal data.

If you had given your consent for any specific purpose, you may withdraw that consent whenever you wish, without affecting the lawfulness of the processing based on the consent prior to withdrawal.

To exercise your rights, please send written notice to Diana Salarich, or send us an e-mail to diana.salarich@elix.es.

In order to exercise the above-mentioned rights, you can use the models and forms which are available through the Spanish Data Protection Agency on its official web page (https://www.aepd.es/reglamento/derechos/index.html).

We hereby inform you of your right to lodge a complaint with a Supervisory Authority, specifically the Spanish Data Protection Agency (https://sedeagpd.gob.es/sede-electronica-web/vistas/formNuevaReclamacion/reclamacion.jsf), and before all other public bodies that may hold jurisdiction over any claim derived from your personal data.

8. Links

The Website could contain links to other web pages. Keep in mind that we are not liable for the privacy and data processing of other web pages. This Privacy Policy is applicable solely to the information that is gathered on this Website. We recommend that you read the privacy and data processing policies of any other web pages that you may connect to from our Website or that you may otherwise visit.

9. How do we protect your personal data?

In order to ensure information security, ELIX has implemented different technical and organizational measures to ensure the appropriate security level in compliance with the applicable regulations. ELIX shall implement appropriate technical and organizational measures, both when designing the data processing system and at the time of the processing itself, to maintain security and prevent unauthorized processing. Nevertheless, users must be aware that, in the Internet environment, invulnerable security measures do not exist. ELIX isn’t responsible for the actions of any third parties who, in breach of these measures, access the aforementioned data and information.

10. Confidentiality

The professionals working at ELIX and who have any type of intervention in the services provided to the user, are committed not to disclose or make use of the information they have accessed. The information provided by the user will, in any case, be considered confidential, and may not be used for purposes other than those related to the management of their requests and the services contracted with ELIX, if any. ELIX undertakes not to disclose or reveal information about the user's claims, the reasons for the requested advice or the duration of the relationship with the user.

11. Social networks

ELIX is present on some of the main social networks on the Internet, for which it acts as the data controller in relation to the data published by ELIX.

ELIX will process the data on each social network according to the rules established for such purpose by each social network. Therefore, and unless otherwise stated, ELIX may inform its followers on the corresponding social network about its activities, events and other related subjects, including follower services, therefore using the channels that the social network provides for such purpose.

ELIX will not gather personal data from social networks, unless a user gives us their express consent.

12. Direct marketing

We do not use your personal data for direct marketing purposes without your prior, express consent.

If you’ve given us your consent and you want to stop receiving commercial or promotional information from us, you may, at any time, at no charge and without having to provide a justification, unsubscribe from direct marketing campaigns and object to future processing of your personal data for such purposes by sending us an email to diana.salarich@elix.es or by clicking on the “opt-out” (unsubscribe) button from any of our commercial or promotional e-mails.

Please note that even if you choose not to subscribe or unsubscribe from our promotional/commercial emails or newsletters we may still need to contact you regarding important non-commercial information to comply with the Legal Notice and/or legal requirements.

13. Child policy

The Website isn’t designed for or directed at children under the age of eighteen (18), without permission from a parent or a legal guardian. ELIX doesn’t knowingly collect information from children under the age of eighteen. If as a parent or legal guardian you believe that your children have submitted personal information to us without your consent, please contact us at 93 217 08 01.

14. Cookies

This website only uses technical-security third-party (Wix.com - our website building platform) cookies in order to guarantee a secure experience and browsing through the entire website, and controlling the traffic and communication of information. Please, for more information about those technical-security cookies visit our Cookies Policy.

15. Updates

We will only use your personal data in compliance with the provisions set forth in the Privacy Policy that is in force at the time when we obtain your personal data. ELIX reserves the right to modify this Privacy Policy at any time. Such modifications will be published on our website, and we therefore recommend that you consult the policy whenever you visit the website. If, at any time, we decide to use personal data in a manner other than what was stated when such data were obtained, we will inform you via e-mail, as long as we have your e-mail address. At that time, you will be given the option to authorize other uses or disclosures of the personal data that you had provided to use before updating our Privacy Policy.

Last update: 14/11/2019