This Privacy Policy is applicable to the website of Altamira Asset Management, made available to the public at the URL www.altamirainmuebles.com, as well as to the interactions that the user makes with Altamira Asset Management through the website. The aforementioned Policy has been designed in accordance with the provisions of current legislation on the protection of personal data and the terms used in it have the same meaning as those included in the Legal Notice.

Altamira Asset Management may modify this Privacy Policy when necessary. In case of introducing modifications, we will communicate it through the web page or through other means, in order to inform the new conditions of Privacy. The fact of continuing to make use of the features made available by Altamira Asset Management after having notified you of the aforementioned modifications will imply that you agree with them, except for the cases in which your express consent is necessary.

• Who is responsible for the processing of your personal data?

The entity responsible for the processing of personal data is ALTAMIRA ASSET MANAGEMENT, S.A. (hereinafter Altamira Asset Management) provided with CIF A86819596 and with address at C / José Echegaray, n ° 6, 28232, Las Rozas de Madrid (Madrid).

• What personal information is processed?

The data that Altamira Asset Management handles as a result of the interactions made by the user through our website come from the following sources:

• Data provided by the user when filling up the forms given by Altamira Asset Management, or that the user enables social networks to provide Altamira Asset Management to register on the website when using the social network connectors.
• Data generated as a result of browsing and use by the visitor of Altamira Asset Management websites.
• Data generated as a consequence of the development, processing and maintenance on the management of the requests made by the user.
• Data obtained from external sources (e.g. Social networks, etc.).

Altamira Asset Management may process personal data of the following types, depending on the relationship established with the user:

• Identification data (e.g., name and surname, email address, postal address, telephone number, IP address, image, etc.).
• Navigation and location data (e.g. use of web pages, visited sections, data provided by the user through social networks when indicating their location, etc.).
• Other types of data: Only in case the user registers through the connectors of social networks, the types of data provided and consented by the user over the social network will be accessed and treated by Altamira Asset Management.

• For what purpose do we treat your personal data?

The personal data that are provided by the users of this website will be treated by Altamira Asset Management for the following purposes, depending on the type of data provided by the user, as well as the interactions that the user engages with Altamira Asset Management through the website:

1. Website contact: The personal data of the users who contact Altamira Asset Management through any of the contact channels made available on the website, will be treated in order to manage this contact, meet the requests received through them and provide the required services.
2. Management of the proposals presented by the user: Personal data will be processed to offer the appropriate response to proposals for the acquisition or lease of real estate, as well as to resolve any query raised by the user in this regard.
3. Web browsing guarantee: The personal data will be used only to allow navigation through our website and, if you accept the cookies policy, to analyze the navigation made and perform behavioral advertising.
4. Referral of information about the properties of your interest: In order to contact you through various means, including electronic means and provide or send you information in relation to the property for which the user has been interested, as well as in relation to other properties that Altamira Asset Management has in its portfolio.
5. Send commercial communications: The personal data provided will be treated in order to contact you through various means, including electronic means, in order to provide or send information in relation to the property for which the user has been interested, as well as in relation to other properties that Altamira Asset Management has in its portfolio. In relation to this purpose, prior to the use of the different web forms made available on the Web, you will be informed about the treatment that will be made of your data and, where appropriate, your consent will be sought for the aforementioned purpose. To which, you can revoke your consent at any time and free of charge by sending a message to the email address: cumplimiento.normativo@altamiraam.com
6. Help to obtain financing: In order to contact you through various means, including electronic means with the purpose of being able to help and advise you in obtaining property financing.

• What is the legal legitimacy for the treatment of your personal data?

Altamira Asset Management treats the personal data provided by the user, in accordance with the following legitimizing bases, based on the type of data provided by the user, as well as the interactions that the user engages with Altamira Asset Management:

1. The processing of your data for the purpose of «Contact», «Management of proposals» and «Web browsing», is based on the management and processing of the legal relationship between the user and Altamira Asset Management, that is, in the management of the request itself, in the maintenance of contact between the parties and, where appropriate, in the provision of the service that the user had requested.
2. The processing of your data for the «Referral of commercial communications» and «Assistance to obtain financing», is based on the consent given by the user in each case.

• To whom is your information communicated?

The data collected by Altamira Asset Management through the forms of the website, may be communicated to the owner of the property or asset for which the user has been interested in order to ensure the proper management and processing of the legal relationship entered into between the user and Altamira Asset Management.

In relation to the remaining data processing purposes detailed in this Privacy Policy, Altamira Asset Management informs users that such treatment purposes do not imply communications of their data by Altamira Asset Management to third parties.

• How long do we keep your data for?

Altamira Asset Management will keep your personal data for the time necessary to provide the requested service and / or to achieve the purpose of the treatment sought.

Subsequently, provided that the user has not exercised their right to data deletion, their data will be kept during the legal deadlines that in each case result from application, taking into account the type of data, as well as the purpose of the treatment and, where appropriate, the time in which some type of responsibility derived from the relationship maintained between the User and Altamira Asset Management may be demanded.

• What personal information should you provide in each case?

Altamira Asset Management informs the user that, when personal data are collected through a form made available through the website, it will be necessary for the user to provide, at least, those data marked with an asterisk (*). In case of not providing at least such data, considered as necessary, Altamira Asset Management will not be able to manage the provision of the service requested by the user.

Likewise, the user guarantees that the personal information provided through the website is true, accurate, complete and up-to-date, and is responsible for any direct or indirect loss or damage that may be caused as a result of the breach of such obligation.

• What measures are taken to protect your personal data?

In compliance with current regulations, Altamira Asset Management has made a risk assessment of the data it deals with and has adopted the necessary technical and organizational measures to maintain the level of security required in response to the personal data processed. Likewise, it is endowed with the precise mechanisms at its disposal to avoid as far as possible unauthorized access, theft and illicit modifications and the loss of data and tries to install those other means and additional technical measures within its reach to avoid loss, misuse, alteration and unauthorized access to personal data provided.

For all the above, it is recommended the utmost diligence in this matter and the use of all the security tools available to it, not putting the responsibility onto Altamira Asset Management for theft, modification or loss of illicit data.

• What are your rights about your personal data?

Altamira Asset Management informs you that it has the following rights regarding your personal data:

• Right of Access: You have the right of access your data to know what personal information concerning you we are dealing with.
• Right to rectification or erasure (“right to be forgotten”): in certain circumstances, you have the right to rectify personal data that you consider inaccurate and that concerns you, and that are subject to handling by Altamira Asset Management, as well as the right to request the deletion of your data when, among other reasons, the data was no longer necessary for the purposes they were initially collected.
• Request the limitation of the processing of your data: In certain circumstances, you have the right to request the limitation of the handling of your files, in which case we inform you that we will only keep this data which you have requested limitation for the exercise of defense of claims.
• Right to data portability: In certain circumstances, you will have the right to receive the personal data that concerns you, and that you have given us, in a structured format of common use and mechanical reading, as well as to be transmitted by Altamira Asset Management to another party responsible for the handling.
• Right to object to the processing of their personal data in certain circumstances: In certain circumstances and for reasons related to your particular situation, you will have the right to object to the processing of your data in which case, we could stop dealing with unless we must continue doing so for compelling legitimate reasons or for the exercise or defense of possible claims.

Altamira Asset Management informs you that you can exercise your rights over your personal data through any of the following channels:

• By writing a letter to Altamira Asset Management, S.A, en C/ José Echegaray, n° 6, 28232, Las Rozas de Madrid, to the attention of Cumplimiento Normativo.
• By sending an e-mail to: cumplimiento.normativo@altamiraam.com

In both cases, it is required to prove the identity of the person exercising their rights by sending a copy of their DNI, NIE, Passport or any other equivalent document, two sides.

Altamira Asset Management will provide the information requested within a maximum period of one month from receipt of the request. This period may be extended for another two months if necessary, taking into account the complexity and the number of applications.

Finally, Altamira Asset Management informs you that you may file a claim with the competent Control Authority regarding data protection. However, in the first instance, you may submit a claim to the Data Protection Officer, who will resolve the claim within a maximum period of two months.