I. PRIVACY POLICY AND DATA PROTECTION

Respecting the provisions of current legislation, Quartier Luxury Villas and Residences (hereinafter, also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated in this privacy policy

This privacy policy is adapted to current European and International regulations regarding the protection of personal data on the Internet. Specifically, it respects the following rules:

• Regulation (UE) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (RGPD).
• Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The person responsible for the processing of personal data collected in Quartier Luxury Villas and Residences is: Quartier Luxury Villas and Residences, Inc.

His contact details are as follows:

Address: Quartier Marbella, Calle 47 and Calle 53 east Marbella, Panama

Contact Phone: +507 64728600

Contact email: [email protected]

Registration of Personal Data

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Quartier Luxury Villas and Residences, through the forms extended on its pages, will be incorporated and will be treated in our file in order to be able to facilitate, speed up and comply with the commitments established between Quartier Luxury Villas and Residences and the User or the maintenance of the relationship established in the forms that the User fills out, or to attend to a request or query from the User. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD is applicable, a record of treatment activities is maintained that specifies, according to its purposes, the treatment activities carried out and the other circumstances established in the RGPD.

Principles applicable to the processing of personal data

The processing of the User’s personal data will be subject to the following principles contained in article 5 of the RGPD and in article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of the digital rights:

• Principle of legality, loyalty and transparency: the User’s consent will be required at all times prior to completely transparent information on the purposes for which the personal data is collected.
• Purpose limitation principle: personal data will be collected for specific, explicit and legitimate purposes.
• Principle of data minimization: the personal data collected will only be strictly necessary in relation to the purposes for which they are processed.
• Accuracy principle: personal data must be exact and always updated.
• Principle of limitation of the term of conservation: the personal data will only be maintained in a way that allows the identification of the User for the time necessary for the purposes of its treatment.
• Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
• Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met.

Categories of personal data

The categories of data that are processed in Quartier Luxury Villas and Residences are only identifying data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Quartier Luxury Villas and Residences undertakes to obtain the express and verifiable consent of the User for the processing of his/her personal data for one or more specific purposes.

The User shall have the right to withdraw his/her consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On the occasions in which the User must or can provide his/her data through forms to make inquiries, request information or for reasons related to the content of the Website, he/she will be informed if the completion of any of them is mandatory, as being essential for the proper development of the operation performed.

Purposes of the treatment to which the personal data is destined

Personal data is collected and managed by Quartier Luxury Villas and Residences in order to be able to facilitate, expedite and fulfill the commitments established between the Website and the User or for the maintenance of the relationship established in the forms that the latter fills out or to attend to a request or consultation.

Likewise, the data may be used for a commercial personalization, operational and statistical purpose, and activities of the corporate purpose of Quartier Luxury Villas and Residences, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as improve the quality, operation and navigation of the Website.

At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the treatment to which the personal data will be used; that is, the use or uses that will be given to the information collected.

Personal data retention periods

Personal data will only be retained for the minimum necessary time for the purposes of its treatment and, in any case, only for the following period: 24 months, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when this is not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data will not be shared with third parties.

In any case, at the time the personal data is obtained, the User will be informed about the recipients or about the recipients of the personal data categories.

Minors’ personal data

Respecting the provisions in articles 8 of the RGPD and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may grant their consent for the lawfully treatment of their personal data by Quartier Luxury Villas and Residences. In the case of a minor under 14 years of age, the consent of the parents or legal guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

Quartier Luxury Villas and Residences undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in such a way as to guarantee the security of personal data and prevent accidental or unlawful destruction, loss or alteration of the personal data transmitted, stored or otherwise processed, or unauthorized communication or access to said data.

However, because Quartier Luxury Villas and Residences cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User, without undue delay, when a violation of the security of personal data is likely to pose a high risk to the rights and freedoms of natural persons. Following the provisions of article 4 of the RGPD, a breach of the security of personal data is understood to be any breach of security that causes the accidental or unlawful destruction, loss or alteration of the personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to report and guarantee through a legal or contractual obligation that said confidentiality is respected by his employees, associates, and any person to whom he makes the information accessible.

Rights derived from the processing of personal data

The User has over Quartier Luxury Villas and Residences and may, therefore exercise them, the following rights recognized in the RGPD and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Right of access: It is the right of the User to obtain confirmation of whether or not Quartier Luxury Villas and Residences is treating his/her personal data and, if so, to obtain information about the specific personal data and the treatment that Quartier Luxury Villas and Residences has carried out or carries out, as well as, among others, of the information available on the origin of said data and the recipients of the communications made or planned thereof.
• Right of rectification: It is the right of the User to modify his/her personal data that turns out to be inaccurate or, taking into account the purposes of the treatment, incomplete.
• Right of deletion (“the right to be forgotten”): It is the User’s right, provided that the current legislation does not establish otherwise, to obtain the deletion of his/her personal data when these are no longer necessary for the purposes for which they were collected. or treated; the User has withdrawn his consent to the treatment and this does not have another legal basis; the User opposes to the treatment and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; the personal data must be deleted in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable measures to inform those responsible for processing the personal data of the interested party’s request to delete any link to those personal data.
• Right to limitation of treatment: It is the User’s right to limit the treatment of his/her personal data. The User has the right to obtain the limitation of the treatment when he/she contests the accuracy of his/her personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed to the treatment.
• Right to data portability: In the event that the treatment is carried out by automated means, the User will have the right to receive his/her personal data from the Data Controller in a structured, commonly used and mechanical reading format, and to transmit them to another person in charge of the treatment. Whenever technically possible, the Data Controller will transmit the data directly to that other controller.
• Right of opposition: It is the right of the User not to carry out the processing of his/her personal data or to cease the processing thereof by Quartier Luxury Villas and Residences.
• Right not to be the subject of a decision based solely on automated processing, including profiling: It is the User’s right not to be the subject of an individualized decision based solely on the automated processing of his/her personal data, including profiling, unless current legislation establishes otherwise.

Thus, the User may exercise his/her rights by written communication addressed to the Data Controller with the reference “RGPD-www.quartierhomeresidences.com“, specifying:

• Name, surnames of the User and copy of the DNI. In cases where representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document accrediting the representation. The photocopy of the DNI may be replaced by any other legally valid means proving the identity.
• Application with the specific reasons for the request or information to which you want to access.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that accredits the request made.

This application and any other attached document may be sent to the following address and/or email:

Address: Quartier Marbella, Calle 47 and Calle 53 east Marbella, Panama

Contact phone: +507 64728600

Email: [email protected]

Links to third party websites

The Website may include hyperlinks or links that allow access to websites of third parties other than Quartier Luxury Villas and Residences, and therefore are not operated by Quartier Luxury Villas and Residences. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Claims before the control authority

In the event that the User considers that there is a problem or infringement of current regulations in the way in which his/her personal data is being processed, he/she will have the right to effective judicial protection and to file a claim with a control authority, in particular, in the State in which you have your habitual residence, place of work or place of the alleged infringement. In the case of Spain, the control authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and is in agreement with the conditions on the protection of personal data contained in this Privacy Policy, as well as that he/she accepts the processing of his personal data so that the Data Controller can proceed to the same in the form, during the periods, and for the indicated purposes. The use of the Website will imply the acceptance of its Privacy Policy.

Quartier Luxury Villas and Residences reserves the right to modify its Privacy Policy, according to its own criteria or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (UE) 2016/679 of the European Parliament and of the Council, of April 27, 2016, detailing the protection of natural persons with regard to the processing of personal data and the free circulation of these data (RGPD) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.