Your privacy is of the highest importance to us, and we are committed to protecting and respecting your personal information.
This privacy statement applies to the services provided by Hot Properties Spain part of the group Hot Properties in Spain (“HPS”) (and associated trading names and describes how HPS collects and uses the personal information you provide when you use our websites or via the online registration or via our technology providers (data processors), face to face and/or through other interactions and communications you have with us. The sites are jointly referred to as the “Services “. Estate Agency services provided by HPS is referred to as a “Estate Agency Site”. It also describes the rights and choices you have regarding our processing of your personal information.
HPS and HPIS will both share this data.
When do we collect information about you?
We collect personal information from you when:
· you visit our websites.
· you create an account on our websites.
· you make an enquiry on our websites.
· you make a purchase or a reservation via a third-party website.
· you sign up for one of our programmes or promotions or events.
· you participate in special operations, in particular games, competitions, product tests, customers surveys or market research.
· you share content on social networks such as Instagram, Facebook, Pinterest or Twitter using one of our hashtags.
· you are visiting one of our offices, or some approved points of sale within our business.
· you contact us, when you call or submit a request or a complaint, when you rate or review our products and/or services or other communication regarding any of our services.
· you have given your consent to third parties to send us personal information about you.
HPS may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this privacy statement regarding notice and choice and the service agreements with our Clients.
We partner with several third-party software & technology providers who handle data on our behalf and who operate under this policy. This may include personal information such as name, contact details, the names of guests travelling with the customer and any customer preferences specified when making an enquiry.
A customer of a Client who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to our Client (data controller).
HPS will retain personal data we process and control on behalf of our Clients for as long as needed to provide services to our Client. HPS will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
What kind of personal information does HPS collect?
We consider that all information that could identify you directly or indirectly is "personal information".
When entering the Sites, HPS automatically collects data using cookies, such as IP addresses, browser types, operating systems, application versions, language settings and page visits. To register your information or to make an enquiry HPS requests the following information: contact details (name, email address, mailing address and phone number)
· information about your identity, in particular your gender, last name, first names, address, telephone number, email addresses, date of birth or age.
· information about our transactions, such as numbers, history of your communications, events and purchases, your preferences and your activity on the web.
· your email address for the purpose of Wi-Fi access.
· content information (photos, videos, reviews, comments, etc.).
· cctv imagery from our premise's security.
· information about your social media accounts (username, caption information, location, etc.), uploads and posts when you share content or use the hashtags, we offer.
· technical information, in particular your IP address or information about how your device navigates through our website.
· other information you provide when you contact us, or we have received from external providers.
Please make sure that the personal information we process about you is correct, relevant and up to date.
You may use the relevant links on our websites and social media to contact us or if you have any concerns at email@example.com to request that we remove your information from our database, if for any reason you are unable to do this directly.
Why does HPS collect, use and share personal information?
We may use your personal information for the following purposes:
· Registration and account administration. We use personal information to allow you access to our Wi-Fi and to register you as a customer and to allow you to administer and manage your reservation. If you haven’t finalised the online registration, we may send a reminder to continue with the registration. If you have made property enquiries, we may send you notifications about the enquiries and any further properties we deem suitable. We believe that this additional service is useful to you and allows you to make changes and get access to information relevant to your initial enquiry. Processing of your personal information is necessary for the performance of your agreement with HPS. If you do not provide the requested information HPS cannot assist with your enquiry.
· Processing of your orders (orders, deliveries, invoices, after sales service, etc.). This processing is necessary for the performance of any contract to which you are party.
· Customer Service. We use personal information to help us get to know you better and to provide you with personalised offers about our products and services (by email, by SMS, on social networks or any other medium and by displaying targeted ads on websites and on social networks), also to respond to your requests, questions and concerns. We also use information to manage your viewings / sales and to analyse and anticipate market trends to best meet your needs. For these purposes, we may perform segmentation operations based on your preferences, interests and purchases behaviour, analyse your browsing and requests on our website or perform any other actions to better qualify our database. Creating an account allows us to personalise your customer experience. This processing is made with your consent or necessary for the purposes of the legitimate interest referred to above.
· Social interaction. This processing is made with your consent.
· Marketing/Communications: We use personal information to provide you with requested information, to send our newsletter and marketing communications, and updates about the Services. You may opt-out at any time from our newsletter and other marketing communications by following the unsubscribe instructions included in these emails, accessing the email preferences in the Backoffice, or by contacting us at firstname.lastname@example.org In view of purpose, HPS relies on your consent to use your personal information for certain marketing purposes. For this purpose, you will be requested to provide consent if data is collected via your use of Wi-Fi unless you have already provided your consent for receiving marketing / communications at another point of service contact.
· Fraud detection and prevention. We use personal information to prevent fraud and other illegal or violating activities. We also use this information to investigate and detect fraud and to facilitate prosecution where necessary. For this purpose, personal information may be shared with third parties, such as law enforcement authorities and external advisors. This processing is necessary for legal purposes and the purposes of the legitimate interest referred to above.
· As otherwise permitted by law and/or if we need to notify to you from time to time.
Does HPS disclose or share your personal information?
We never sell nor rent your personal information with other companies for marketing purposes.
We authorise service providers to use your personal information only to the extent necessary to perform services on our behalf or to comply with legal requirements and we strive to ensure that your personal information is always protected.
· Sharing with Third Parties / Affiliates.
We share your personal information with suppliers who help us facilitate running our business such as software providers, marketing platforms and other technology providers (“Affiliates”) as permitted by law. We may use service providers to act on our behalf and at our direction for order processing and fulfilment, secure payment, customer service management, maintenance and technical development operations, rate and reviews, analytics, management of digital campaigns, etc. If required by law, we shall first ask your consent before our Affiliates may use your personal information for other purposes such as marketing. In the majority these third parties are not located outside of the European Economic Area (EEA). Where we do transfer data to be processed outside of the EEA, we will obtain your express consent to do so prior. We will ensure for any companies located out of the EEA, who may not provide the same level of data protection as in your country of residence, that we enter into appropriate data transfer agreements. Mail Chimp based in the US, may store and send communications on our behalf and we ensure such third parties comply with the EU-U.S. Privacy Shield Framework and the Privacy Shield Principles regarding the collection, use, and retention of personal information transferred from the European Union to the U.S.
· Compelled Disclosure. When legally required, strictly necessary for the performance of the services or to protect our rights, or the rights of our Affiliates or users, we may disclose your personal information to law enforcement authorities, investigative organisations or in legal proceedings.
· Our Group Companies. Personal information will only be shared across the HPS Group in certain circumstances and where lawful to do so, i.e., it may be necessary to share your personal information with other members of the Group, which includes our ultimate parent company, its subsidiaries and other group members for the purposes of our business management, including workforce management and administration, management information, forecasting and other related functions. Access rights between members of the HPIS are limited and granted only on a need-to-know basis, depending on job functions and roles. In addition, your business contact details, images and other information that you make available on our internal systems will be available to colleagues across the HPIS Group.
· Sale or Merger. We may share your personal data in the event of a merger, acquisition, or sale of all or a portion of our assets. Of course, we shall notify you via email and/or a prominent notice on our Site and inform you of your rights.
Sharing and Disclosure of Aggregate Data. We may share data in aggregate form and/or in a form which does not enable the recipient of such data to identify you, with third parties, for example for industry analysis and demographic profiling.
How does HPS retain your personal information?
We will retain your personal information for as long as we deem it necessary to provide services to you, comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business.
How does HPS protect the information held by you?
We understand the importance of your data security and take appropriate steps to protect it.
We monitor our systems and take appropriate technical and organisational measures, in relation to the nature of data and risks, to preserve the security and confidentiality of your personal information.
We secure access to all transactional areas of our websites and apps using appropriate technology and security measures such as an authentication process, backup, antivirus, firewall, etc. and ensure data is password protected or encrypted wherever necessary. We include practices such as limited access by members of staff who, by virtue of their duties, are authorised to access data, contractual guarantees in case of third-party provider, privacy risk assessments, and internal reviews of our practices and policies.
Updating or Accessing Your Personal Information
Please make sure that your personal information is accurate and up to date, and please inform HPS of changes in a timely manner. You may inquire about the personal information we maintain about you and enforce your rights of access, to rectify and correct, limit restriction of processing, oppose / object to processing, erasure or to enforce your right to data portability. You can also withdraw your consent at any time. To exercise these rights, you must send us a request contacting email@example.com
There are several ways you can stop direct marketing communications from us, through the unsubscribe link, managing preferences and opt out in the links provided as part of the communications. Alternatively, you may contact us on the details above. Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
We will deal with requests to delete, rectify or block inaccurate personal information or to cease processing personal information in accordance with applicable policies and procedures. We may not disclose data that you are not entitled to receive under applicable laws (e.g., data revealing information about another individual) or delete, rectify or block personal data which our internal policies or applicable mandatory law oblige us to keep. If you have any difficulties in updating your personal information, please use the contact details above.
How does HPS handle personal and sensitive data?
We do not knowingly collect nor process personal information from minors under the age of 16. Assuming we would have knowledge of the collection of personal information from minors without prior authorisation from the holder of the parental responsibility, we will take appropriate measures to contact the person and, if necessary, to delete this personal data from our servers and/or those of our service providers.
Questions or Complaints
HPS will be receptive to any queries or requests made in connection with our processing of your personal information. You may contact us via firstname.lastname@example.org All questions and complaints reported to HPS will be investigated. HPS will attempt to resolve complaints and questions in line with internal policies.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
Changes to Notice
Just as our business changes constantly, this privacy statement may also change.