In compliance with the regulations on personal data protection RGPD, makes available to users of this website, this Privacy Policy, in order to provide information on how we treat your personal data and protect your privacy and information.
Legal regulations to which the website is subject to: GRUPO TOP GESTIÓN has adapted this website to the requirements of Organic Law 3/2018, of 5 December, on the Protection of Personal Data 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 individuals with regard to the processing of personal data and on the free movement of such data (RGPD), as well as with Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSICE).
- Joint Controllers:
1.1. Who are the Joint Controllers?
The companies belonging to the group of companies in which TOP GESTIÓN has a shareholding or whose sole shareholder is TOP GESTIÓN and which independently carry out each of the property developments developed by the TOP GESTIÓN group within its core business.
1.2. Joint commercial name of all the companies in the TOP GESTIÓN group:
TOP GESTIÓN GROUP
1.3. Common point of contact:
Company name: TOP GESTION MADRID, S.L. | B86831476
Address: C/ Príncipe de Vergara, 120, escalera 3, 1º izquierda28002 Madrid
Contact: Tel. 912 90 44 94 – Email: topgestionmadrid@grupotopgestion.com
1.4. Legal regulation of the situation of co-responsibility:
In order to comply with the provisions of current European Union Data Protection regulations (Art. 26 of the GDPR), an Agreement has been drawn up which aims to enable and regulate globally and for all the companies of the TOP GESTIÓN GROUP the regime of co-responsibility for the joint processing of personal data between the different companies that make up the TOP GESTIÓN GROUP.
All the newly created entities that form part of the TOP GESTIÓN GROUP have progressively adhered to this Agreement by completing the Adhesion Document incorporated as Annex Two to the Agreement itself.
1.5. Origin and Communication of intra-group data:
For the purposes of the provisions of the RGPD and the LOPD-gdd, the submission or sending by the User of personal data (data relating to identified or identifiable persons) through any website of TOP MANAGEMENT GROUP and subsequent processing by us, will be considered as data processing activity. The personal data processed by TOP MANAGEMENT GROUP comes from the various forms 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 ensure the privacy of the information.
Users are informed that any personal data collected on any of the websites belonging to GRUPO TOP GESTIÓN will be communicated to all those jointly responsible for the processing; for the purposes of joint or/and individualised processing, as appropriate.
2. Purpose of processing and legitimacy
2.1. For what purpose will we process your data?
GRUPO TOP GESTIÓN processes the data collected through the various forms on the website for the following purposes:
- Management, study and resolution of queries relating to: the information included on the website and / or our services; data processing, legal texts, claims, as well as any other issues.
- Management and processing of the User’s registration.
- Management and processing of the subscription list of GRUPO TOP GESTIÓN and sending the newsletter, promotions and offers.
- Elaboration of estimates, upon request of the interested party.
- Management of reservations, at the request of the interested party.
- Management, study and resolution of communications relating to: alleged breaches of regulations, alleged violations of the Code of Ethics, alleged negligent acts or omissions; communication to the competent authorities and/or courts, where appropriate.
The data provided will be located on servers managed by the hosting service provider of the website in which the user has entered the data in question, which will be considered in charge of the treatment. All servers of the different hosting providers of GRUPO TOP GESTIÓN are located in 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.
Usually, GRUPO TOP GESTIÓN places its web pages on the servers of OVH HISPANO, S.L. or RAIOLA NETWORKS, S.L.
The interested party shall be solely responsible for the completion of the forms with false, inaccurate, incomplete or outdated data, exonerating GRUPO TOP GESTIÓN from any liability in this regard. Users guarantee and respond, in any case, the accuracy, validity and authenticity of the personal data provided and undertake to keep them updated.
2.2. What is the legal basis for 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 when you provide the data requested through the forms on the website and tick the box accepting this privacy policy.
2.3. Will it be necessary for you to provide us with all your data? What will happen if you do not provide them?
Yes, it will be necessary for you to provide us with all the personal data requested. If you do not provide us with the requested data, we will not be able to deal with your request properly.
2.4. Will we make automated individualised decisions and/or profiling, which produce legal effects or significantly affect you in a similar way?
No.
2.5. How long will we process your data?
GRUPO TOP GESTIÓN will keep your personal data for the time necessary to achieve the purpose or purposes of processing.
Subsequently, provided that the user has not exercised their right of deletion, your data will be retained for the legal periods in each case are applicable, taking into account the type of data and the purpose of processing.
3. RECIPIENTS OF TRANSFERS:
3.1. Will we transfer your data to other companies?
If you give your consent, GRUPO TOP GESTION may transfer your data to third parties that provide services related to the home so that they can send you commercial information about their products or services. In the same way, with regard to other processing other than third party advertising, GRUPO TOP GESTION informs you that the data may be communicated to the following recipients:
- Competent national or international authorities, including judicial bodies, regulatory and supervisory bodies and State Security Forces and Corps.
Additionally, please note that the provision of the services made available through this Website requires the intervention of third party service providers (e.g. web hosting and infrastructure, customer management tools, etc.) who 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 marketer, has signed the appropriate contract regulating the relationship between the two, in order to provide additional guarantees to the treatment due by the marketer in question. These guarantees or guidelines to be followed in the processing of personal data, in conjunction with the pre-existing and diligently implemented in each marketer, presuppose sufficient protection of the User’s rights.
However, GRUPO TOP GESTIÓN is not responsible for the processing that third party marketers may carry out with the data provided.
The User is informed that, for the proper provision of services (see, web hosting, marketing, etc.), different service providers contracted by GRUPO TOP GESTIÓN (data processors) may have access to personal information necessary to perform their functions.
These services provided by third parties are necessary for the development of the activity of TOP MANAGEMENT GROUP and, at all times, the processing of data carried out by them will be governed by contract that binds the manager with respect to TOP MANAGEMENT GROUP. In no case will they use the information for other purposes and will treat it in accordance with the guidelines stipulated by TOP MANAGEMENT GROUP and the current legislation on data protection.
GRUPO TOP GESTIÓN, in its commitment to privacy and data protection of the User, will only choose service providers that offer sufficient guarantees to implement appropriate technical and organizational measures, so that the treatment is in accordance with applicable legislation on data protection and ensure the protection of the rights of the User.
4. RECIPIENTS OF INTERNATIONAL TRANSFERS:
4.1. Will your personal data be transferred to third countries or international organisations?
No, as a general rule.
5. RIGHTS OF THE DATA SUBJECT:
5.1. What rights do you have in relation to the processing of your data?
Any interested party has the right to obtain confirmation as to whether or not GRUPO TOP GESTIÓN is processing personal data concerning them.
- Also, as provided for in the RGPD (arts. 15-22) and the LOPD-gdd (arts. 12-18), we inform you that you have the following rights:
- Access to your data: You have the right to access your data to find out what personal data we are processing concerning you.
- Request rectification or deletion of your data: In certain circumstances, you have the right to rectify any inaccurate personal data concerning you that is processed by us or even to ask us to delete it when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
- Request the restriction of the processing of your data: In certain circumstances, you will have the right to ask us to limit the processing of your data, in which case we inform you that we will only keep them for the exercise or defence of claims as provided for in the RGPD and the LOPD-gdd.
- To portability of your data: In certain circumstances, you 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.
- Object to the processing of your data: In certain circumstances and for reasons related to your particular situation, you have the right to object to the processing of your data in which case, we will stop processing it except for compelling legitimate reasons, or the exercise or defence of possible claims.
- Ask not to be subject to automated individual decisions, including profiling.
- File a data protection complaint with the supervisory authority (Spanish Data Protection Agency).
5.2. When will we respond to your request?
We will respond to your requests as soon as possible and in any case within one month of receiving your request. This period may be extended by a further two months if necessary, taking into account the complexity and number of requests. The person responsible shall inform the person concerned of the extension within one month of the request.
5.3. Do you have the right to withdraw your consent?
The data subject has the right to withdraw consent at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.
5.4. Where should you go to exercise your rights?
In order to exercise the recognised rights, the interested party may contact TOP GESTION MADRID, S.L. by e-mail: topgestionmadrid@grupotopgestion.com or by writing to the following postal address: C/ Príncipe de Vergara, 120, escalera 3, 1º izquierda, 28002 Madrid.
5.5. Do you have the right to complain?
Yes, especially when you have not obtained full satisfaction in the exercise of your rights, you have the right to lodge a complaint with the national supervisory authority. For this purpose, you should contact the Spanish Data Protection Agency, whose contact details are given below:C/ Jorge Juan, 6 – 28001 Madrid | https://www.aepd.es | dpd@agpd.es; Tel. 901100099 – 912663517
6. ACCEPTANCE AND CONSENT
You, as User, declare that you have been informed of the conditions on the protection of personal data, accepting and consenting to the processing of these, by GRUPO TOP GESTIÓN, in the manner and for the purposes indicated in this privacy policy.
7. MODIFICATION OF THE CONDITIONS OF THE PRIVACY POLICY
GRUPO TOP GESTIÓN expressly reserves the right to modify this privacy policy to adapt it to any new legislative, jurisprudential or other developments.
- CONTACT
If you have any questions about our privacy policy, please contact us at topgestionmadrid@grupotopgestion.com.
- PROTECTION OF PERSONAL DATA
GRUPO TOP GESTIÓN (TOP GESTIÓN MADRID, SL, hereinafter, the “data controller”), with tax identification number B86831476 and registered office at C/ Príncipe de Vergara 120 – Escalera 3, 1º Planta – 28002 – Madrid, carries out, as part of its marketing actions and in order to promote the activity of the entity, various public communications and publications on the pages, web portals and social networks of the data controller.
The personal data requested for the provision of our services are included in processing subject to the provisions of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and 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 individuals with regard to the processing of personal data and on the free movement of such data (RGPD). The collection and processing of such data is carried out by GRUPO TOP GESTIÓN, and its purpose is the management, provision, expansion and improvement of the services requested at any given time by the user, the monitoring of queries, participation in personnel selection processes, electronic communications and/or the preparation of statistics.
The services provided by GRUPO TOP GESTIÓN are aimed at adults. In the exceptional event that a service specifically aimed at minors of that age will be developed, GRUPO TOP GESTIÓN will request the consent of parents or guardians for the collection of personal data or, where appropriate, for the treatment of these.
GRUPO TOP GESTIÓN is committed to fulfilling its obligation of secrecy with respect to personal data provided and the duty to treat them with confidentiality and reserve, in accordance with current legislation. To this end, it will adopt the necessary measures to prevent their alteration, loss, unauthorised processing or access.
DATA SUBJECTS’ RIGHTS
The data protection regulations in force protect you in a series of rights in relation to the use we make of your data. Each and every one of your rights are unipersonal and non-transferable, i.e. they can only be exercised by the owner of the data, subject to verification of their identity.
Below, we indicate which rights you are entitled to:
- Request access to your personal data.
- Request rectification of your data.
- Request the deletion or removal of your data (right to be “forgotten”).
- Limit or object to the use we make of your data.
- Right to the portability of your data in the case of telecommunications or internet services.
- The right to withdraw your consent at any time.
- The right not to be subject to automated individual decisions.
- The right to lodge a data protection complaint with the supervisory authority (Spanish Data Protection Agency).
How can you exercise your rights in relation to your data?
To exercise your rights of access, rectification, deletion, limitation or opposition, portability and withdrawal of consent, you can do so as follows:
Company Name: TOP GESTION MADRID, S.L.
Address: C/ Príncipe de Vergara, 120, staircase 3, 1º left, 28002 Madrid
Telephone: 912 90 44 94
E-mail: topgestionmadrid@grupotopgestion.com
How can you make a complaint: In addition to the rights you have, if you believe that your data is not being collected or processed in accordance with current Data Protection regulations or if you consider that you have not obtained full satisfaction in the exercise of your rights, you may make a complaint to the national supervisory authority, contacting the Spanish Data Protection Agency, whose contact details are given below: C/ Jorge Juan, 6 – 28001 Madrid | https://www.aepd.es | dpd@agpd.es;Tel. 901100099 – 912663517.
MISCELLANEOUS
The headings of the various 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 particular conditions, general conditions or agreements that TOP GESTIÓN and any of its subsidiaries reach with its clients, the provisions of the particular and/or general conditions shall prevail.
In the event that any provision or provisions of this Legal Notice and Terms of Use shall be deemed invalid or unenforceable, in whole or in part, by any Court, Tribunal or competent administrative body, such invalidity or unenforceability shall not affect the other provisions of the Legal Notice and Terms of Use.
The failure of TOP GESTIÓN GROUP companies 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 to in writing by TOP GESTIÓN GROUP companies.
APPLICABLE LAW AND JURISDICTION
The applicable law in case of 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, will be Spanish law.
The relationship between TOP GESTIÓN, and the User shall be governed by current Spanish law and any dispute shall be submitted to the Courts and Tribunals of Madrid.
