PRIVACY POLICY
1. Data controller
Controller: Pedruscos, S.L.
NIF: B72525447
Registered address: C/ Willy Manchot 2, apartamento 210, 29639 Benalmádena
Contact and rights-exercise email: pedruscossistemas@gmail.com
No Data Protection Officer is identified because no appointment has been communicated.
2. Personal data we may process
Depending on the channel used, Pedruscos, S.L. may process the following categories of data:
identification and contact data, such as name, email address and telephone number;
country and language where needed to manage the request;
information voluntarily included in messages or forms relating to the property or request;
commercial context data, such as project, property of interest, lead source, campaign, channel, capture date and follow-up status;
technical data strictly necessary for security, operation and traceability of the submission;
marketing preferences only where the person has expressed them through a separate option.
The standard form does not request identity documents, KYC/AML documentation, bank details, special-category data or other information that is not necessary to deal with the property enquiry.
3. Purposes and legal bases
A. Handling property enquiries and the requested contact.
Purpose: to answer enquiries, provide requested information, arrange video calls or viewings and carry out follow-up directly connected with the interest expressed.
Legal basis: steps taken at the request of the data subject before entering into a contract, Article 6(1)(b) GDPR, where applicable.
B. Managing the lead and the active commercial relationship.
Purpose: to maintain the commercial history required to organise actions, viewings, offers and communications relating to the current enquiry or negotiation.
Legal basis: Article 6(1)(b) GDPR where processing is necessary for pre-contractual or contractual steps; for other ancillary internal processing that is not necessary for that purpose, another legal basis will be used only where it is documented and applicable.
C. Optional marketing communications.
Purpose: to send commercial information about Pedruscos, S.L. properties and developments through the channels specifically consented to.
Legal basis: consent, Article 6(1)(a) GDPR and applicable electronic communications rules.
Marketing consent is separate from the property enquiry, optional and may be withdrawn at any time. Refusing marketing consent does not prevent a person from requesting information about a property.
D. Analytics, advertising measurement, personalisation and remarketing.
Purpose: to measure use of the website and campaign performance and, where specifically authorised, to carry out personalised advertising or remarketing.
Legal basis: consent where non-essential cookies, identifiers or technologies subject to consent are used.
These purposes will not be activated before the user has made the relevant choice under the applicable CMP policy.
E. Security, abuse prevention and defence of rights.
Purpose: to protect the website, systems and data, prevent abusive use and manage or defend claims.
Legal basis: legitimate interests in protecting systems and rights, Article 6(1)(f) GDPR, where applicable and after limiting processing to what is necessary; or compliance with a legal obligation, Article 6(1)(c) GDPR, where appropriate.
4. Source of the data
Data may be obtained:
directly from the person concerned through forms, email, telephone or WhatsApp;
from property portals or advertising platforms where the person submits an enquiry or form through those services;
from other authorised acquisition channels that forward a request initiated by the person concerned.
Where data is not obtained directly from the person concerned, Pedruscos, S.L. will provide the required privacy information no later than the first communication where that communication takes place before the generally applicable deadline. The information must also identify the source and the categories of data received.
5. Recipients, processors and international transfers
Authorised staff at Pedruscos, S.L. may access the data where they need it for commercial management.
Technology providers may also be involved as processors or under the legal role that applies, for example hosting, email and productivity services, CRM/AppSheet, automation and integration, analytics and advertising platforms where those functions are active and legally enabled.
Where a provider processes data from countries outside the European Economic Area or the applicable territorial framework, Pedruscos, S.L. will use the relevant international transfer mechanism, such as an adequacy decision or appropriate safeguards, depending on the service and provider actually used.
Personal data is not sold. Data may be disclosed to public authorities, courts or other third parties where required by law.
6. Retention
Data relating to a property enquiry and its associated lead will be retained for as long as necessary to handle the enquiry and while there is active commercial follow-up reasonably connected with the interest expressed.
When the data is no longer necessary for the active purpose, it will be deleted or, where appropriate, restricted and retained only for periods during which legal liabilities may arise. Once those periods end, it will be securely deleted.
Data processed for marketing will be used while consent remains valid and until the person withdraws it or objects. After withdrawal or objection, only the minimum information necessary to evidence the choice, address liabilities and prevent further communications contrary to that preference may be retained.
Evidence of information or consent and technical logs will be retained only for as long as necessary to demonstrate compliance, resolve incidents, protect systems or address liabilities; afterwards they will be deleted or restricted as appropriate.
This public policy uses retention criteria. Pedruscos must also approve an internal operational schedule for automated deletion of inactive leads and logs; that internal decision remains pending.
7. Rights
The data subject may request access, rectification, erasure, restriction of processing, objection and data portability where applicable, and may withdraw any consent given at any time.
To exercise these rights, write to pedruscossistemas@gmail.com, identifying the request and providing only the information necessary to verify identity where this is essential.
Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
The data subject may also lodge a complaint with the Spanish Data Protection Agency, without prejudice to any other avenue that may apply.
8. Required and optional data
Fields marked as required in a form are used only where they are essential to manage the request. Accepting marketing is not required in order to request information about a property.
9. Automated decision-making
P01 acquisition does not use solely automated decisions that produce legal effects concerning the data subject or similarly significantly affect them. Analytics or advertising platforms may apply their own segmentation processes only where the relevant use is legally enabled and, where required, consented to.
10. Security
Pedruscos, S.L. will apply reasonable and proportionate technical and organisational measures to protect data against loss, unauthorised access, alteration or improper disclosure.
11. Changes to this policy
The Privacy Policy may be updated when processing activities, providers or legal requirements change. The current version must remain easily accessible from the website.