In compliance with the GDPR personal data protection regulations, it makes this Privacy Policy available to the users of this website, with the purpose of providing information on how we process their personal data and protect their privacy and information. Legal regulations to which the website adheres: GRUPO TOP GESTIÓN has adapted this website to the requirements of Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights (LOPD-gdd). It also complies with 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 (GDPR), as well as with Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSICE).
Joint Controllers:
Who are the Joint Controller entities? The companies belonging to the group of companies in which TOP GESTIÓN holds an interest, or whose sole shareholder is TOP GESTIÓN, and which each independently carry out the property developments undertaken by the TOP GESTIÓN group within their principal activity.
Joint commercial name of all the companies in the TOP GESTIÓN group: GRUPO TOP GESTIÓN
Common contact point: Company Name: TOP GESTION MADRID, S.L. | B86831476 Address: C/ Príncipe de Vergara, 120, staircase 3, 1st left, 28002 Madrid Contact: Tel. 912 90 44 94 – Email: topgestionmadrid@grupotopgestion.com
Legal regulation of the joint controllership situation: In order to comply with the provisions established in the current European Union Data Protection regulations (Art. 26 GDPR), an Agreement has been drafted with the purpose of enabling and regulating globally, and for all the companies of GRUPO TOP GESTIÓN, the joint controllership regime for the joint processing of personal data between the different companies that form part of GRUPO TOP GESTIÓN. All newly created entities forming part of GRUPO TOP GESTIÓN have progressively adhered to said Agreement by completing the Deed of Accession incorporated as Second Annex to the Agreement itself. In compliance with the applicable regulations and upon prior request by the data subject at the email address topgestionmadrid@grupotopgestion.com, the Agreement may be made available to them.
Origin and intragroup communication of data: For the purposes of the GDPR and the LOPD-gdd, the submission or sending by the User of personal data (data relating to identified or identifiable persons) through any GRUPO TOP GESTIÓN website and its subsequent processing by us shall be considered as data processing activity. The personal data processed by GRUPO TOP GESTIÓN comes from the different forms available on the group’s websites. GRUPO TOP GESTIÓN guarantees the User that it will implement the appropriate technical and organisational security measures for the processing of such data, in order to safeguard the privacy of the information. Users are informed that any personal data collected on any of the websites belonging to GRUPO TOP GESTIÓN shall be communicated to all joint controllers for the purposes of carrying out joint and/or individualised processing, as appropriate.
Purpose of the processing and legal basis
For what purpose will we process your data? At GRUPO TOP GESTIÓN, we process the data collected through the different forms on the websites for the purpose of:
- Management, review and resolution of enquiries relating to: the information included on the website and/or our services; data processing, legal texts, complaints, as well as any other matters.
- Management and processing of User registration.
- Management and processing of the GRUPO TOP GESTIÓN subscription list and sending of the newsletter, promotions and offers.
- Preparation of quotations, at the prior request of the data subject.
- Management of bookings, at the prior request of the data subject.
- Management, review and resolution of communications relating to: alleged regulatory breaches, alleged breaches of the Code of Ethics, alleged negligent acts or omissions; communication to the competent Administrations and/or Courts, where appropriate.
The data provided will be located on the servers managed by the hosting service provider of the website on which the user has entered the data in question, which shall be considered the data processor. All the servers of the different hosting providers of GRUPO TOP GESTIÓN are located within European territory and the company that manages them offers sufficient guarantees to apply the security measures required by data protection regulations for the processing of personal data. GRUPO TOP GESTIÓN usually hosts its websites on the servers of OVH HISPANO, S.L. or RAIOLA NETWORKS, S.L. However, due to the large number of websites owned by GRUPO TOP GESTIÓN, among other factors, it is highly complex to set out exhaustively the relationship between: website – hosting service provider. If the data subject wishes to know, on an individual basis, which hosting provider has or has had access to their personal data, they may contact our team at the following email address: topgestionmadrid@grupotopgestion.com The data subject shall be solely responsible for completing the forms with false, inaccurate, incomplete or outdated data, and GRUPO TOP GESTIÓN shall be exempt from any liability in this regard. Users guarantee and shall in all cases be responsible for the accuracy, validity and authenticity of the personal data provided, and undertake to keep it duly updated.
What is the legal basis that entitles us to process your data? The legal basis for processing your data is consent. The processing of your data is based on your express consent, which you give by providing the data requested through the website forms and ticking the box accepting this privacy policy.
Will it be necessary for you to provide us with all your data? What will happen if you do not provide it to us? Yes, it will be necessary for you to provide all the personal data requested. If you do not provide the requested data, we will not be able to deal properly with your request.
Will we carry out automated individual decision-making and/or profiling that produces legal effects or similarly significantly affects you? No.
How long will we process your data for? GRUPO TOP GESTIÓN will retain your personal data for the time necessary to achieve the intended processing purpose or purposes. Subsequently, provided that the user has not exercised their right to erasure, their data will be retained for the legal periods applicable in each case, taking into account the type of data and the purpose of the processing. In any event, the user may request detailed information on the data retention periods applied by contacting our Data Protection Officer, who may be contacted at the following address: : topgestionmadrid@grupotopgestion.com
RECIPIENTS OF DISCLOSURES:
Will we disclose your data to other companies? If you consent, GRUPO TOP GESTION may disclose your data to third-party entities that provide home-related services so that they may send you commercial information about their products or services. Likewise, with regard to the remaining processing operations other than third-party advertising, GRUPO TOP GESTION informs you that the data may be disclosed to the following recipients:
- Competent national or international authorities, including judicial bodies, regulatory and supervisory bodies and the State Security Forces and Corps.
Additionally, please note that, for the provision of the services made available through this Website, the involvement of third-party service providers is necessary (for example, web hosting and infrastructure, customer management tools, etc.), and they will process your personal data under our responsibility, on our behalf and following our instructions. GRUPO TOP GESTIÓN, diligently and prior to collaborating with each marketing company, has entered into the appropriate contract governing the relationship between both parties, in order to provide additional guarantees regarding the proper processing by the marketing company in question. Such guarantees or guidelines to be followed in the processing of personal data, in conjunction with those pre-existing and diligently implemented by each marketing company, presuppose sufficient protection of the User’s rights. However, GRUPO TOP GESTIÓN is not responsible for the processing that third-party marketing companies may carry out on the disclosed data. If the data subject wishes to obtain further information in this regard and/or wishes to notify us of any apparently illegitimate/illegal processing of their personal data disclosed to the marketing company in question, they may contact us at the email address topgestionmadrid@grupotopgestion.com, so that our team may provide them with further information and/or assess the possible breach of the contract entered into with the marketing company and, where appropriate and at our sole discretion, adopt and implement the appropriate measures in defence of the rights and interests of the affected User. The User is informed that, for the correct provision of the services (see web hosting, marketing, etc.), different service providers contracted by GRUPO TOP GESTIÓN (data processors) may have access to the personal information necessary to perform their functions. These services provided by third parties are necessary for the development of GRUPO TOP GESTIÓN’s activity and, at all times, the processing of the data they carry out shall be governed by a contract binding the processor to GRUPO TOP GESTIÓN. Under no circumstances will they use the information for other purposes and they will process it in accordance with the guidelines stipulated by GRUPO TOP GESTIÓN and the regulations in force on data protection. GRUPO TOP GESTIÓN, in its commitment to the User’s privacy and data protection, will choose only service providers that offer sufficient guarantees to apply appropriate technical and organisational measures, so that the processing is compliant with the applicable data protection legislation and ensures the protection of the User’s rights.
RECIPIENTS OF INTERNATIONAL TRANSFERS:
Will your personal data be transferred to third countries or international organisations? No, as a general rule.
DATA SUBJECT’S RIGHTS:
What rights protect you in relation to the processing of your data? Any data subject has the right to obtain confirmation as to whether or not GRUPO TOP GESTIÓN is processing personal data concerning them. Likewise, as provided for by the GDPR (arts. 15-22) and the LOPD-gdd (arts. 12-18), we inform you that you have the following rights:
- To access your data: You have the right to access your data in order to know which personal data concerning you we are processing.
- To request the rectification or erasure of your data: In certain circumstances, you have the right to rectify any inaccurate personal data concerning you that is being processed by us or, even, to request its erasure when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
- To request the restriction of the processing of your data: In certain circumstances, you will have the right to request that we restrict the processing of your data, in which case we inform you that we will only retain it for the exercise or defence of claims as provided for by the GDPR and the LOPD-gdd.
- To the portability of your data: In certain circumstances, you will have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit it to another data controller.
- To object to the processing of your data: In certain circumstances and on grounds relating to your particular situation, you will have the right to object to the processing of your data, in which case we would cease processing it except for compelling legitimate grounds, or for the exercise or defence of possible claims.
- To request not to be subject to automated individual decisions, including profiling.
- To lodge a complaint regarding data protection with the supervisory authority (Spanish Data Protection Agency).
When will we respond to your request? We will respond to your requests as soon as possible and, in any event, within one month from receipt of your request. That period may be extended by a further two months where necessary, taking into account the complexity and number of requests. The controller shall inform the data subject of the extension within the first month from the request.
Do you have the right to withdraw your consent? The data subject has the right to withdraw consent at any time, without this affecting the lawfulness of processing based on consent prior to its withdrawal.
Where should you apply in order to exercise your rights? For the exercise of the recognised rights, the data subject may contact TOP GESTION MADRID, S.L. via the email address: topgestionmadrid@grupotopgestion.com or by sending a written communication to the postal address: C/ Príncipe de Vergara, 120, staircase 3, 1st left, 28002 Madrid
Do you have the right to lodge a complaint? Yes. You, particularly where you have not obtained full satisfaction in the exercise of your rights, have the right to lodge a complaint with the national supervisory authority. For these purposes, you must contact the Spanish Data Protection Agency, whose contact details are set out below: C/ Jorge Juan, 6 – 28001 Madrid | https://www.aepd.es | dpd@agpd.es; Tel. 901100099 – 912663517
ACCEPTANCE AND CONSENT
You, as User, declare that you have been informed of the conditions regarding the protection of personal data, accepting and consenting to the processing thereof by GRUPO TOP GESTIÓN, in the manner and for the purposes indicated in this privacy policy.
AMENDMENT OF THE CONDITIONS OF THE PRIVACY POLICY
GRUPO TOP GESTIÓN expressly reserves the right to amend this privacy policy in order to adapt it to any legislative, case law or any other kind of developments.
CONTACT
If the User has any questions about our privacy policy, please contact topgestionmadrid@grupotopgestion.com
PROTECTION OF PERSONAL DATA
GRUPO TOP GESTIÓN (TOP GESTIÓN MADRID, SL, hereinafter, the “controller”), with C.I.F. B86831476 and registered office at C/ Príncipe de Vergara 120 · Staircase 3, 1st Floor · 28002 · Madrid, carries out, as part of its marketing actions and with a view to promoting the entity’s activity, various public communications and publications on the controller’s pages, web portals and social media. The personal data requested for the provision of our services is included in processing operations subject to the provisions of Organic Law 3/2018, of 5 December, on Personal Data Protection and the guarantee of digital rights (LOPD-gdd) and 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 (GDPR). The collection and processing of such data are carried out by GRUPO TOP GESTIÓN, and are intended for the management, provision, expansion and improvement of the services requested at any given time by the user, the monitoring of enquiries, participation in staff recruitment processes, electronic communications and/or the preparation of statistics. The services provided by GRUPO TOP GESTIÓN are aimed at persons over the age of majority. In the exceptional event that any service specifically aimed at minors under that age were to be developed, GRUPO TOP GESTIÓN would request the consent of parents or guardians for the collection of personal data or, where appropriate, for its processing. GRUPO TOP GESTIÓN undertakes to comply with its duty of secrecy with regard to the personal data supplied and with the obligation to process it confidentially and with reserve, in accordance with current legislation. For these purposes, it shall adopt the necessary measures to prevent its alteration, loss, processing or unauthorised access.
RIGHTS OF DATA SUBJECTS
Current data protection regulations protect you by means of a series of rights in relation to the use we make of your data. Each and every one of your rights is personal and non-transferable, that is, they may only be exercised by the data subject, subject to verification of their identity. Below, we indicate the rights to which you are entitled:
- To request access to your personal data.
- To request the rectification of your data.
- To request the erasure or deletion of your data (right to be “forgotten”).
- To restrict or object to the use we make of your data.
- Right to the portability of your data in cases of telecommunications or internet services.
- Right to withdraw your consent at any time.
- Right not to be subject to automated individual decisions.
- Right to lodge a complaint regarding data protection with the supervisory authority (Spanish Data Protection Agency)
How can you exercise your rights in relation to your data? In order to exercise your rights of access, rectification, erasure, restriction or objection, portability and withdrawal of consent, you may do so as follows:
Company Name: TOP GESTION MADRID, S.L.
Address: C/ Príncipe de Vergara, 120, staircase 3, 1st left, 28002 Madrid
Telephone: 912 90 44 94 Email: topgestionmadrid@grupotopgestion.com
How can you lodge a complaint?: In addition to the rights to which you are entitled, if you believe that your data is not being collected or processed in accordance with the current Data Protection regulations, or if you consider that you have not obtained full satisfaction in the exercise of your rights, you may lodge a complaint with the national supervisory authority, by contacting for these purposes the Spanish Data Protection Agency, whose contact details are set out below: C/ Jorge Juan, 6 – 28001 Madrid | https://www.aepd.es
| dpd@agpd.es
;Tel. 901100099 – 912663517.
MISCELLANEOUS
The headings of the different clauses are for information purposes only, and shall not affect, qualify or extend the interpretation of the Legal Notice and Terms of Use. In the event of any discrepancy between the provisions of this Legal Notice and Terms of Use and the specific conditions, general conditions or agreements entered into by TOP GESTIÓN and any of its subsidiaries with their clients, the provisions of the specific and/or general conditions shall prevail. In the event that any provision or provisions of this Legal Notice and Terms of Use is/are considered null and void or unenforceable, in whole or in part, by any competent Court, Tribunal or administrative body, such nullity or unenforceability shall not affect the other provisions of the Legal Notice and Terms of Use. The failure by the companies of the GRUPO TOP GESTIÓN to exercise or enforce any right or provision contained in this Legal Notice and Terms of Use shall not constitute a waiver thereof, unless acknowledged and agreed in writing by them.
APPLICABLE LAW AND JURISDICTION
The law applicable in the event of any dispute or conflict of interpretation of the terms that make up this Legal Notice, as well as any matter related to the services of this Portal, shall be Spanish law. The relationship between TOP GESTIÓN and the User shall be governed by the current Spanish regulations and any dispute shall be submitted to the Courts and Tribunals of Madrid.