PRIVACY AND DATA PROTECTION POLICY
In accordance with current legislation, the company Comercializadora Mediterránea de Viviendas S.L. (also known as Comervi), operating under the trade name Marina d'Or Construcciones (hereinafter, "the Company"), responsible for this website, undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected on this website, www.marinadorconstrucciones.com.
1. IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER.
To manage any issue arising from the use of this website, you can contact the Company, with registered office at Calle Moyano 8, 12002, Castellón de la Plana, Castellón, with Tax Identification Number (CIF): B12045076, directly at that address, through the website itself, by sending an email to contacto_rgpd@inseryal.es
2. REGULATIONS.
The Company undertakes to protect the privacy of its customers and to process their personal data in accordance with current regulations, namely: General Data Protection Regulation, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights, approved on 5 December 2018 (LOPDGDD) and Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).
3. DATA COLLECTION.
COMERVI collects your personal data by various means, namely:
- Through the forms on its website(s)
- Through written forms in its offices
- Through campaigns on Meta (Facebook and Instagram)
- Through advertising campaigns on Google
- Through advertisements published on real estate websites
- By sending emails to the company's email addresses
- Through telephone communication and/or WhatsApp chat, Telegram or SMS, with you providing the data.
- Through objective transcription of telephone conversations using AI applications for the purpose of improving customer service.
- Through forms in both physical and digital formats, at trade fairs and commercial events.
- Through data collected automatically when browsing our website or submitting forms.
In accordance with the provisions of Articles 7 LOPDGDD and 8 of the GDPR, only persons over the age of 14 may give their consent for the lawful processing of their personal data by the Company.
In the case of minors under the age of 14, the consent of their parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorised it.
Likewise, the data subject is responsible for the accuracy of the data provided.
4. PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA.
The processing of the data subject's personal data shall be subject to the following principles set out in Articles 4 and 5 of the LOPDGDD and Article 5 of the GDPR:
Principle of lawfulness, fairness and transparency: the consent of the data subject shall be required at all times, following fully transparent information on the purposes for which the personal data are collected.
Principle of purpose limitation: personal data shall be collected for specific, explicit and legitimate purposes.
Principle of data minimisation: the personal data collected shall be only those strictly necessary in relation to the purposes for which they are processed.
Principle of accuracy: personal data must be accurate and kept up to date.
Principle of storage limitation: personal data shall only be kept in a form which permits identification of the data subject for no longer than is necessary for the purposes for which it is processed.
Principle of integrity and confidentiality: personal data shall be processed in a manner that ensures its security and confidentiality.
Principles of proactive responsibility: the data controller shall be responsible for ensuring that the above principles are complied with.
5. CATEGORIES OF PERSONAL DATA.
The personal data subject to processing is always provided by the data subject and includes the following: Name, surname, email address and telephone number.
The data collected automatically are: IP address, browser and operating system of the computer from which you write to us or fill in forms.
6. PURPOSE OF DATA PROCESSING.
The collection and processing of the personal data of the data subject is for the purpose of responding to requests for information about the service requested and the subsequent management of the contractual and/or commercial relationship.
Other purposes for which COMERVI may process your personal data are:
- Processing of data of interested parties for the preparation of contracts.
- Processing of data for billing and administration of the commercial and/or contractual relationship.
- Responding to your requests for information when you so request.
- Enabling you to register as an interested party for the services offered through the website when you fill in the relevant form.
- Enabling your participation in possible prize draws and promotions carried out through the website, when you register for them.
- To ascertain your level of satisfaction and obtain feedback on your experience with our company.
- To send you electronic and non-electronic commercial communications that allow you to stay informed of the offers and promotions of the Company and, where applicable, its affiliated companies, provided that you have given your consent to do so.
- The data collected automatically will be used for the purposes of "spam prevention", "website security" and "technical display optimisation".
We do not intend to use your data for profiling purposes.
7. LEGAL BASIS FOR PROCESSING.
The legal basis for the aforementioned data processing will be:
- Art. 6.1.a) GDPR: Consent of the data subject.
- Art. 6.1.b) GDPR: processing necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Processing necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.
- With regard to data collected automatically, Art. 6.1 f) GDPR: Processing is necessary for the purposes of the legitimate interests pursued by the controller, as it is necessary to ensure the security and proper functioning of the service.
If the data is not processed, the contract cannot be performed and the purposes listed cannot be achieved.
If the legal basis is the consent of the data subject, we inform you that you may withdraw this consent at any time by sending an email to contacto_rgpd@inseryal.es or by post to the following address: Carrer de Moyano, 8, 12002 Castelló de la Plana, Castelló.
On occasions when the data subject must or may provide their data through forms to make enquiries, request information or for reasons related to the content of the website, they will be informed if the completion of any of these forms is mandatory because they are essential for the proper performance of the operation carried out.
8. RECIPIENTS OF PERSONAL DATA.
Your personal data will not be disclosed except in cases provided for by law. However, third parties who provide services to the Company and with whom a data processing agreement has been signed may have access to this data.
No international transfer of your data is envisaged.
9. DATA RETENTION.
The data processed by the company as the data controller will be retained for the time necessary to maintain the relationship between the company and you. Once this relationship has ended, your data will be retained for the time necessary to be able to exercise any actions that may arise from the contractual relationship established.
If there is no contractual relationship, a period of 12 months is established for the deletion or review of personal data with the data subject.
If you send us your curriculum vitae or register for the various job offers we may publish, we will process your data in order to assess and manage your job application and, where appropriate, carry out the necessary actions for the selection and recruitment of personnel, in order to offer you positions that match your profile.
Unless otherwise indicated, the provision of the required data is necessary, and failure to provide it will prevent the selection process from continuing.
In the case of data you provide us in relation to your job search or job offers you wish to subscribe to, it will be kept for one year from the date of the last update of your data or delivery thereof.
After this period, if the data has not been updated, it will be deleted, unless you indicate otherwise.
10. CONFIDENTIALITY AND SECURITY OF PERSONAL DATA.
COMERVI has adopted the necessary technical and organisational measures, in accordance with the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised communication or access to such data.
However, as the Company 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 data subject without undue delay when a personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.
In accordance with Article 4 of the GDPR, a personal data breach is understood to be any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised communication or access to such data.
Personal data will be treated as confidential by the data controller, who undertakes to inform and ensure, by means of a legal or contractual obligation, that such confidentiality is respected by its employees, collaborators, affiliated companies and any person to whom it makes the information accessible.
11. EXERCISE OF RIGHTS.
You may exercise your rights of access, rectification, erasure, objection, revocation, portability and restriction of processing, as set out in the GDPR and the LOPDGDD, by sending a letter together with a copy of your ID card or equivalent identification document to: Comervi, Calle Moyano 8, 12002, Castellón de la Plana, Castellón, Spain, or by email to contacto_rgpd@inseryal.es with the subject line "Data Protection".
The request must specify which of these rights you wish to exercise and be accompanied by a photocopy of your ID card or equivalent identification document.
If you consider that your rights have not been duly respected, you may lodge a complaint with the Spanish Data Protection Agency (AEPD), about which you can find more information at www.aepd.es
Below is a description of each of the rights that you may exercise against the data controller, as recognised in Articles 12 to 18 of the LOPDGDD and Articles 15 to 22 of the GDPR:
Right of access: this is the right of the data subject to obtain confirmation as to whether or not the Company is processing their personal data and, if so, to obtain information about their specific personal data and the processing that COMERVI has carried out or is carrying out, as well as the information available about the origin of such data and the recipients of the communications made or planned.
Right of rectification: this is the right of the data subject to have their personal data modified if it is inaccurate or, taking into account the purposes of the processing, incomplete.
Right of erasure ("the right to be forgotten"): this is the right of the data subject, unless otherwise provided by current legislation, to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the data subject has withdrawn their consent to the processing and there is no other legal basis for it; the data subject objects to the processing and there is no other legitimate reason to continue with it; the personal data has been processed unlawfully; the personal data must be erased 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 implementation, shall take reasonable steps to inform those responsible for processing the personal data of the data subject's request to delete any links to that personal data.
Right to restriction of processing: this is the right of the data subject to restrict the processing of their personal data.
The data subject has the right to obtain the restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the controller no longer needs the personal data, but the data subject needs it to make claims; and when the data subject has objected to the processing.
Right to data portability: where processing is carried out by automated means, the data subject shall have the right to receive their personal data from the controller in a structured, commonly used and machine-readable format and to transmit those data to another controller. Where technically feasible, the controller shall transmit the data directly to that other controller.
Right to object: this is the right of the data subject to prevent the processing of their personal data or to have the Company cease processing it.
Right not to be subject to a decision based solely on automated processing, including profiling: this is the right of the data subject not to be subject to an individualised decision based solely on the automated processing of their personal data, including profiling, unless otherwise provided for by applicable law.
12. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY.
The data subject must have read and agreed to the conditions on the protection of personal data contained in this Privacy Policy, as well as accept the processing of their personal data so that the data controller can proceed with the processing in the manner, for the period and for the purposes indicated.
Use of the website does not in itself imply acceptance of the privacy policy, and it is necessary for the user to expressly accept it through the mechanisms provided for this purpose.
The Company reserves the right to modify its Privacy Policy, at its own discretion, or due to a legislative, jurisprudential or doctrinal change by the Spanish Data Protection Agency (AEPD).