Privacy policy

https://rbkprime.com/ is an Internet domain owned by:

RBK PRIME INVEST, S.L.
B19449412
Located at Puerto Portals Local 74, 07181 Calviá, Palma de Mallorca.

In accordance 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), and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights (LOPDGDD), we set out this Privacy Policy.

This policy is not limited to the website, but governs all the processing of personal data carried out by the company in the course of its activity, regardless of the channel through which the data are collected (in person, by telephone, by email, paper forms, the website or other means).

We reserve the right to amend this Privacy Policy to adapt it to legislative and case-law developments or to the interpretation of the Spanish Data Protection Agency. In that case, such changes will be announced, clearly indicating the modifications made with due advance notice, and requesting acceptance of those changes where necessary.

The User undertakes that all the data they provide are true and correct.

WHAT TYPES OF DATA WILL WE USE?

Identifying data (Tax ID / national ID number, Address, Image/voice, Social Security / mutual insurance number, Telephone, Physical marks, First name and surname, Signature, Electronic signature, Health card)
Personal characteristics (Marital status data, Family data, Date of birth, Age, Sex, Nationality, Mother tongue, Physical or anthropometric characteristics)
Economic, financial and insurance data (Income, earnings, Investments, assets, Credits, loans, guarantees, Bank details, Pension and retirement plans, Payroll economic data, Tax deduction data / taxes, Insurance, Mortgages, Subsidies, benefits, Credit history, Credit cards)
Transactions in goods and services (Goods and services supplied by the data subject, Goods and services received by the data subject, Financial transactions, Compensation / Indemnities)
Social circumstances (Accommodation/housing characteristics, Military status, Properties/possessions, Hobbies and lifestyle, Membership of clubs/associations, Licences/permits/authorisations)
Academic and professional data (Training, qualifications, Student record, Professional experience, Membership of professional bodies or associations)
Employment details (Profession, Jobs held, Non-economic payroll data, Employee history)
Commercial information (Activities and businesses, Commercial licences, Subscriptions to publications/media, Artistic, literary, scientific or technical creations)
Pseudonymised data (Data that do not allow the direct identification of Users but do allow behaviour to be individualised)

FOR WHAT PURPOSES WILL WE USE THE USER'S DATA?

Handling information requests: Attend to and handle the enquiries, information requests or petitions made by Users through the contact forms, email and means enabled on the website, such as WhatsApp with Artificial Intelligence activated.
- Voice transcription using Artificial Intelligence systems. In compliance with Article 50 of the Artificial Intelligence Regulation and the guidelines of the AEPD, you are informed that:
  - Voice communication will be transcribed by an AI system that will be hosted on our server. The system does not store or retain the audio.
  - The purpose of the processing is to record the instructions, enquiries and communications made by the client, to guarantee the quality of the service and the accuracy of the information processed, and to ensure the proper provision of professional services.
Provision of real estate brokerage services: Manage the relationship with potential buyers, sellers and other persons interested in the real estate services offered, including brokerage, advice and management of property sale and purchase transactions.
Handling requests relating to properties: Handle requests for information, viewings, reservations or any other request relating to the properties published on the website, as well as providing the interested party with information on their characteristics, availability, price, location and the other conditions of the transaction.
Contact with potential buyers or sellers: Contact persons interested in buying, selling or marketing a property in order to provide them with information on real estate opportunities that match the request made or the characteristics indicated by the interested party themselves.
Personalisation of real estate service: Analyse the information voluntarily provided by the interested party, such as preferences on location, property features, indicative budget or type of transaction, in order to offer them personalised attention and show them properties that may match their interests.
Management of the contractual relationship: When the User engages any of the entity's services, process their data to manage, perform and monitor the contractual relationship, including the preparation and formalisation of the necessary documentation, the administrative management of the transaction and the handling of the obligations arising from it.
Compliance with legal obligations: Comply with the legal obligations applicable to the activity and to sale and purchase or brokerage transactions, as well as respond to requests from authorities, public bodies, courts and tribunals when legally required.
Management of the whistleblowing or reporting channel: Manage the communications, complaints or reports received through the whistleblowing channel enabled on the website, including their receipt, recording, analysis, investigation and, where appropriate, the adoption of the corresponding measures, as well as monitoring and closing the proceedings. This processing will be carried out in accordance with the applicable regulations on data protection and on the protection of persons who report breaches of the law and combat corruption. Likewise, the necessary measures will be adopted to guarantee the confidentiality of the identity of the persons reporting and of the persons concerned, under the terms established by the applicable regulations.
Sending commercial communications: Where the interested party has given their consent when it is required, use their contact details to send them commercial communications relating to properties, real estate investment opportunities, new services, news and other opportunities that may be of interest to them.
Commercial profiling: Where appropriate and there is a valid legal basis for doing so, we may use certain data provided by the interested party and their interaction with our services to build profiles intended exclusively to improve the selection and recommendation of properties and real estate opportunities that may match their preferences. In cases where profiling constitutes processing subject to specific information, the interested party will be informed and the rights legally due to them will be respected.
Website security and fraud prevention: Guarantee the security of the website, detect and prevent unauthorised access, fraudulent use, cyber attacks and other actions that may compromise the security of the systems or of the Users.
Exercise and defence of rights: Handle requests to exercise data protection rights and, where necessary, retain and process the relevant information for the formulation, exercise or defence of claims and legal actions.

WHAT ARE THE LEGITIMATE BASES FOR THE PROCESSING?

We may process the User's personal data on the basis of a legitimate interest, regarding the service and regarding the sending of commercial communications relating to our service.

When the basis for the processing is consent, we will request acceptance as the legitimate basis to use the data. In the case, for example, of communications through WhatsApp in which we use artificial intelligence tools to record and transcribe the conversation, the purpose is to keep a record of your request, handle it properly and improve the quality of the service provided.

Before starting the recording we will inform you of it. If you do not want the conversation to be recorded or transcribed, you may contact us by other means, such as telephone, email or in-person service, without this affecting the provision of the service.

The User may withdraw their consent at any time by sending us an email to data.protection@rbkprime.com

HOW LONG WILL WE KEEP THE USER'S DATA?

We will keep the User's personal data in our information systems for as long as it is necessary, the relationship as a client continues, and to comply with legal obligations, for a period of 5 years.

TO WHOM CAN WE DISCLOSE THE USER'S DATA?

The User's data will not be disclosed to third parties except where there is a legal obligation, you expressly authorise us to do so and/or when it is necessary to comply with the contract agreed to provide our services.

In order to manage the service, in some cases it will be necessary to disclose the data to companies of the same group and/or service providers, for administrative or storage purposes or to support communication, in which case the corresponding data processor agreement will have been signed with each of them, in accordance with Article 28 of the GDPR, which guarantees that they will only process the data following our instructions, for the purposes indicated and applying the appropriate security measures.

To provide our real estate services it may be necessary to transfer your data to countries located outside the European Economic Area (EEA), in the following cases:

a) Management of transactions on properties located outside the EEA. When the property you are interested in is located outside the EEA, we will disclose your data to the parties necessary for the transaction, such as owners, local agents, notaries, lawyers or financial institutions of the country where the property is located. This transfer is necessary to perform the contract or to apply the pre-contractual measures you have requested from us (Article 49.1.b of the GDPR). It will be limited to the data strictly necessary to manage the transaction.

b) Collaborators located outside the EEA. Some of our collaborators and service providers may be established outside the EEA. In these cases, the transfers are carried out with the appropriate safeguards of Article 46 of the GDPR. We have signed with them the standard contractual clauses approved by the European Commission, which oblige them to protect your data at a level equivalent to that required in the European Union. Where the country of destination has an adequacy decision of the European Commission, the transfer is covered by that decision (Article 45 of the GDPR).

HOW CAN THE USER EXERCISE THEIR RIGHTS?

The User may exercise their rights of access, rectification, objection and erasure of their data, request the restriction and portability thereof, as well as other rights, by writing to the following email: data.protection@rbkprime.com

In the following cases:

To rectify inaccurate data or, where applicable, request their erasure (right to be forgotten) when, for example, you have withdrawn your consent. In that case, we will only retain them for the exercise or defence of claims and/or for compliance with a legal obligation.
To request the restriction of the processing of the data when, for example, the data are no longer necessary for the purposes for which they were collected.
To request the portability of the User's data in an automated format that allows them to be copied, moved and transmitted, when the processing is carried out by automated means.
In addition, you may lodge a complaint with the Supervisory Authority (Spanish Data Protection Agency www.agpd.es)

WHAT TYPES OF DATA ARE DISPENSABLE?

The mandatory nature of certain data collected in the forms on the website will be indicated by an asterisk (*) and/or a warning. Failure to complete such data may prevent us from providing all the services linked to such data, releasing us from any liability for the non-provision or incomplete provision of those services.