Who is responsible for processing your data?

TESTA HOMES, S.L. is the data processor on behalf of other entities responsible for the data processing.

The data controller is the entity that owns the property and has entrusted TESTA HOMES, S.L. with managing its sale and/or rental, with TESTA HOMES, S.L. acting as the agent who markets the property

Name: TESTA HOMES, S.L. (TESTA HOMES)
Tax ID number: B88544267
Postal address: Str. Santiago de Compostela 94, 3rd floor, 28035 Madrid.
E-mail address: lopd@testahomes.com
Registration data: Madrid Mercantile Registry, volume 16,114, folio 87, sheet n°M-272946, 1st registration

What data do we process?

The categories of data we will process and need to provide our services are classified as follows:

• Identification and professional contact data.
• Billing and payment data.

Within each of these categories of data, the following types of data will be requested from you or provided to us by you at some point in our relationship:

• Identification and professional contact data: Full name, postal address, delivery address, date of birth, telephone number and email address. If you make a booking with us, the booking code.
• Billing and payment data. Billing address, current account number and banking details. Data needed to issue and complete an invoice.

The data you provide must be current and accurate. If the data provided is false, incomplete, inaccurate or outdated, TESTA HOMES reserves the right to terminate the contracted services or any other agreement that you propose to enter into or may have entered into.

The required data are a legal or contractual requirement and necessary for the purposes outlined, meaning you must provide them for the service offered by TESTA HOMES to be provided (unless otherwise specified in the required field). If you refuse to provide the data, we will be unable to offer the service.

Therefore, if the data are not provided or are not provided correctly, we will be unable to process the requests presented.

Third-party data. If you provide data of third parties with whom you have a relationship, you guarantee that you are legally authorised to provide that information. In that case, we will process the third-party data, assuming you have informed them that their data will be provided to TESTA HOMES for the necessary procedures and verifications to be done by TESTA HOMES for the stated purposes. Nonetheless, when possible, we will inform those third parties about how we process personal data.

We also inform you that we process both your data and the data of third parties included in the booking and the rental agreement to communicate and send the necessary notifications for the booking and the rental agreement. These communications are therefore always addressed to all individuals identified in both the booking and the rental and/or purchase agreement.

What are the purposes of processing your data?

1.- Management and administration of the rental services we offer

We will use your data, directly or through real estate agents acting as processors, to manage, administer and provide our rental services, respond to your enquiries or requests and handle the registration for utilities and any other necessary procedures with suppliers.

We will use your data to manage, administer, present, expand and improve our services. We will also carry out quantitative and qualitative studies of the use of our services to enhance their quality.

In the context of rental agreements, data will be processed to carry out all necessary actions and checks needed to comply with current anti-money laundering and counter-terrorism financing regulations, to determine if you are listed in any national or international registers, databases or lists of individuals and entities subject to sanctions and financial countermeasures.

Additionally, in the course of providing rental services, before and during the rental agreement we will consult credit information systems (ASNEF-EQUIFAX), as well as the Risk Information Centre of the Bank of Spain (CIRBE), to assess your creditworthiness.

If the there is an amount net, due and payable by the tenant that has not been subject to administrative or judicial claims by the debtor or to a binding alternative dispute resolution procedure, TESTA HOMES may include the data in credit information systems (ASNEF-EQUIFAX), C/Santiago de Compostela 94, planta 3º, 28035 Madrid, while the default persists, in accordance with applicable regulations.

2.- Handling and managing any contact made with TESTA HOMES through any means

If you contact us, be it as tenant or buyer or otherwise, and provide your contact details for us to respond in writing (e.g., email) or a call, we will use those details to respond to your enquiry or request.

We may record customer service calls for quality and security purposes. Through our social media profiles, we may also process your data when you interact directly with us by sending a direct message to address a request.

3.- Management, execution and administration of a booking

We will use your data directly or through our data processors to manage and process the booking of a property.

In the context of property booking management, data will be processed to carry out any actions and checks needed to comply with anti-money laundering and counter-terrorism financing regulations, to determine if you are listed in any national or international registers, databases or lists of individuals and entities subject to sanctions and financial countermeasures.

Following the booking, before the execution of the rental and/or purchase agreement and during its term, we will consult credit information systems (ASNEF-EQUIFAX) and the Risk Information Centre of the Bank of Spain (CIRBE) to assess your creditworthiness.

4.- Registration and use of the tenant and booking portals

As a tenant, within the context of our tenant portal, we will use your data to complete your registration process, identify you, manage our services related to property bookings and rentals, respond to your enquiries or requests and handle the registration for utilities and other necessary procedures with suppliers. We will also contact you and inform you about processes and actions related to your property.

5.- Sending information and commercial offers via any means, including electronic media

We will use your data to send personalised commercial communications related to the real estate sector that we believe may be of interest to you, via any means, automated or not (mail, SMS, MMS, email, Internet, phone…).

If you provide your consent, we will use your data to send information and commercial offers, via any means, automated or not (mail, SMS, MMS, email, Internet, phone…), from companies with whom TESTA HOMES has agreements in sectors related to real estate, such as decoration, interior design, cleaning services, moving services, furniture, maintenance services, concierge services, transport and lifestyle products and services.

If you have given your consent, your data will be processed for sending commercial communications, even if you are not a tenant or buyer, or even after your contract with us has ended, until you revoke your consent.

6.- Video surveillance systems

To ensure the safety of individuals and facilities, we use security cameras.

7.- Competitions, sweepstakes, promotions and/or activities, events organised by TESTA HOMES

When you participate in any competition, sweepstakes, event or other promotional activity organised by TESTA HOMES.

8.- Management of property bookings and sales

Management of the booking document and if the interest of both parties in the sale is confirmed, making the necessary arrangements for the sale to be successfully completed, whether directly through a commercial agent, or through sub-processors such as property managers, agencies and lawyers.

This includes any actions and checks needed to comply with anti-money laundering and counter-terrorism financing regulations, as specified by the applicable laws and regulations, to determine if you are listed in any national or international registers, databases or lists of individuals and entities subject to sanctions and financial countermeasures.

If requested by the data subject, we may also inform financial institutions of the data subject’s possible interest in being contacted to receive financing options.

The implementation of occasional internal and quality control campaigns.

9.- Registration and use of the sales portal

As someone interested in purchasing a property, and within the context of our sales portal, we will use your data to complete your registration process, identify you and manage and administer our property booking and sale-purchase services, responding to your enquiries or requests and carrying out all necessary procedures. We will also contact you with information on procedures and actions related to the property.

What is the legal basis for processing your data?

The consents obtained for the aforementioned purposes are independent, so users may revoke any one of them without affecting the others. You can revoke your consent for any or all of the purposes described by writing to TESTA HOMES S.L., providing your full name and address, either by post to C/Santiago de Compostela 94, planta 3º, 28035 Madrid, or via email to lopd@testahomes.com.

Management of property bookings and sales: The legal basis for processing data derives from the booking document and the purchase agreement, compliance with legal obligations, the express consent of the interested party and legitimate interest.

Registration and use of the sales portal: The legal basis for processing is the pre-contractual measures, the execution of the purchase agreement and the terms of access to each portal, as well as compliance with legal obligations.

Who may receive your data?

Service providers acting as data processors.

Where necessary, and for the purposes outlined, the following types of third parties may have access to your data:

• Real estate agents
• Entities providing utility services for our properties
• Entities responsible for property management services, such as key delivery
• The Owners’ Association and the Property Administrator to identify you and enable contact regarding decisions and regulations affecting the community
• Credit information services (ASNEF-EQUIFAX)
• Compliance with legal obligations (courts, law enforcement, etc.) and any relevant actions with competent public authorities or organisations (e.g., SEPBLAC).
• Insurance brokers and insurers
• Financial institutions
• Companies that assist us with customer service and payment claim management
• Auditors, consultants and other firms providing consultancy and auditing services
• Public authorities with powers for bookings or sales, such as the Executive Service for the Prevention of Money Laundering and Monetary Offences (SEPBLAC), property administrators and real estate agents involved in managing the sale

The owners of the assets managed by TESTA HOMES have agreements in place with entities within and outside the European Economic Area that include the relevant standard contractual clauses. You can consult the list of the entities that own the assets managed by TESTA HOMES on our website.

How long will we keep your data?

The data provided will be retained for the duration of the rental agreement and for the statute of limitations of any actions arising from it, which is generally a minimum of five (5) years from the termination of the rental agreement. However, this may vary depending on the type of action to be exercised and the legal obligations we must comply with.

For property sales, the data provided will be retained until the lapse of the actions derived from processing and for as long as necessary for the fulfilment of legal actions and obligations.

Data provided for managing bookings that do not result in a rental agreement will be retained for a period of eighteen (18) months, as this is considered a reasonable timeframe during which the client may decide to enter into the rental agreement or during which legal or other consequences may arise for the parties.

Data provided to comply with anti-money laundering and counter-terrorism financing regulations will be retained for ten (10) years from the termination of the rental agreement, as required by law.

If you have provided your consent, your data will be processed for sending commercial communications, even if you are not a tenant or after your contract has ended, until you revoke your consent.

What are your rights when you provide us with your data and how can you exercise them?

• Rights of data subjects regarding their personal data.
• Every person has the right to obtain confirmation as to whether TESTA HOMES is processing their personal data.
• Access, rectification and deletion: Data subjects have the right to access their personal data and request rectification of inaccurate data or request deletion when, among other reasons, the data is no longer necessary for the purposes for which they were collected.
• Limitation: In certain situations, data subjects may request the limitation of data processing, in which case we will retain the data only for exercising or defending claims and other cases covered by law.
• Objection: In certain circumstances and for reasons relating to their particular situation, data subjects may object to the processing of their data. The owners will stop processing the data, except for compelling legitimate reasons, or to exercise or defend possible claims.
• Objection to advertising: If you exercise the right to object to advertising, your data will be included in an advertising exclusion list.
• Objection to profiling.
• Portability: Data subjects have the right to data portability.

Power to withdraw consent

You also have the right to withdraw your consent for data processing at any time if consent was the legal basis for processing.

How to exercise rights or withdraw consent

You can exercise your rights or withdraw your consent at any time, free of charge, by writing to TESTA HOMES S.L., indicating the right you wish to exercise or your intention to withdraw your consent, along with your full name, and sending it by post to Str. Santiago de Compostela 94, 3rd floor, 28035 Madrid, or via email to lopd@testahomes.com

We inform you of your right to file a complaint with the Spanish Data Protection Agency (AEPD), as the supervisory authority, via their website www.aepd.es.

Additional information

Minors

Minors under the age of 18 should refrain from providing us with their personal data. Our services are intended for adults only.

Updating your data

You agree to immediately notify us of any changes to your data, ensuring that the information TESTA HOMES holds is always up to date and free from errors.

Links

The website may contain links to other websites. Please note that we are not responsible for the privacy or data processing practices of other websites. This Privacy Policy applies exclusively to information collected on our website. We recommend that you review the privacy and data processing policies of other websites you may link to from our website or visit by other means.

Last revision: June 2024

Entities owning assets managed by TESTA HOMES, S.L.