Annex I - Additional information about data privacy

The entity responsible for processing your personal data is “JOSEL S.L.U” (hereinafter, “Núñez i Navarro”), with its registered office at Calle Urgell, number 230 - 08036, in Barcelona. If you have any questions regarding data protection, you can send an email to the email address gdpr@nyn.es .

For what purpose, and on what legal basis, do we collect and use your personal data?

We request your personal information primarily to provide you with the best possible service and to manage the leasing or sale of one of our properties, whether it be homes, commercial spaces, offices, industrial units, or office buildings.
In any case, depending on how we use the personal information you provide us, the legal basis that will allow us to process it will differ. Below, we detail the purposes and legal bases for processing your personal data:

1. Fulfillment of the contractual relationship

Primarily, we will need to process your personal data to manage the leasing or sale of one of our residential properties, commercial spaces, offices, industrial units, or offices.
In this regard, we will need to process your data to carry out any management or procedure related to the property. That is, to analyze your profile and solvency as a potential tenant or buyer, formalize the corresponding key handover document, and send you any other type of information you need to know about your contract.
In the case of a lease agreement, we will process your data to proceed with the monthly billing and payment of the corresponding rents and manage the change of the account holder's name in the contracts formalized with the water supply or electricity and gas distribution or supply companies.
On the other hand, in the case of a purchase agreement, we will process them for the formalization of the corresponding deposit contract, as a preliminary measure to the formalization of the purchase agreement, and for the billing and payment of the corresponding price and taxes, as well as to manage the registration of the property sale in the Property Registry.
If we did not process your identification data, contact information, data related to your solvency and the origin of your funds, as well as your banking data, we could not formalize or maintain the lease or purchase agreement of one of our residential properties, commercial spaces, offices, industrial units, or offices.

2. Legitimate interest

On the other hand, we will need you to provide us with your personal data and process it to attend to and respond to your requests for information and to organize the corresponding visits to our properties. Also to address your suggestions, complaints or possible claims you may have.
Once you are a tenant or buyer of one of our homes, premises, offices, warehouses, or offices, we will process your personal data to:
(i) Send you communications with information, offers, and promotions about properties similar to the one you have already purchased or rented.

(ii) Send you a survey so you can give us your opinion about the experience you have had with Núñez i Navarro, about how we have treated you.

(iii) For administrative, statistical, accounting, reporting, and internal control purposes, all companies of the Núñez i Navarro Group may also process your personal data internally.

You can find information about the companies that make up the Group at the following link.

(iv) Likewise, actions of anonymization, pseudonymization, and encryption of your personal data may also be carried out on the information contained in the systems.
In these cases, we understand that at Núñez i Navarro we have a legitimate interest in using your personal data and, above all, that using this information does not harm your privacy or intimacy.

3. Compliance with a legal obligation

There will also be occasions when we need to process your personal data to comply with certain legal obligations that apply to us. By way of example, and without limitation, we will need to process your personal data to comply with the provisions of the following regulations:
(i) The Urban Leasing Law 29/1994, of November 24, mainly regarding the requirement and corresponding deposit of the security deposit.

(ii) The Money Laundering Prevention Law 10/2017, of April 28, mainly regarding the examination and verification of the origin of the funds of our buyers.
The foregoing is especially important when the State Security Forces and Corps, the Courts and Tribunals, or the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offenses (hereinafter, 'SEPBLAC') require us to provide them with your data.

4. Consent

There may be some matters that are not necessary for processing and maintaining the contract formalized with us, that are not legally required, or for which we do not have a legitimate interest. In these cases, we will not do anything without your authorization first; when this is the case, we will inform you in detail of the purposes and how we want to use your data so that you are aware and can decide how we can handle it.
This may happen, for example, when we are going to send you commercial information about the companies of the Núñez i Navarro Group, dedicated to the hotel, real estate, and parking management sectors, as well as their news and promotions.
Of course, at any time you can withdraw your authorization without this affecting your status as a client of Núñez i Navarro. We inform you in more detail on how to do this in the section regarding your rights. All actions that we have taken before you withdraw your consent will remain lawful.

5. Public Interest

In some of our properties, we will also need to process your image to control access to them, as well as their interiors, to ensure their security and the integrity of the facilities. For this reason, we have installed surveillance systems and/or cameras.
This data processing is necessary for reasons of public interest as established in the current data protection legislation.
We will inform you in each case and you can also request detailed information about the video surveillance data processing at any time by contacting gdpr@nyn.es.

Do we share your personal data with anyone?

As a general rule, we will not share them with any third party. However, it may be necessary to manage your lease or purchase agreement, always in accordance with the terms and conditions of this Annex. There may also be cases where we are legally required to do so or have a legitimate interest in doing so.
Thus, as we have explained to you, there may be occasions when we have a legal obligation to communicate your personal data, when you have given us your consent, or when we have a legitimate interest in doing so. In these cases, we will share your data with the following third parties for the purposes described in this Privacy Policy:

1. The State Security Forces and Corps, the Courts and Tribunals, the SEPBLAC, when they require it or when it is necessary to comply with the legal obligations applicable to us.

2. Notaries, management agencies or the Property Registry when it is necessary to properly formalize the contract signed with you, in accordance with legally established requirements.

3. Service providers necessary for carrying out our activity, such as telephone support services or email marketing services that help our marketing team to conduct customer satisfaction surveys. In these cases, we want to clarify that we will sign the corresponding contract with them to ensure that they apply all the appropriate measures to protect your personal data.

Specifically, Núñez i Navarro may contract the provision of services from third-party providers who carry out their activity, by way of example, in the following sectors: logistics services, legal advice, supplier accreditation, multidisciplinary professional services companies, companies related to maintenance, technology service providers, IT service companies, physical security companies, instant messaging service providers, infrastructure management and maintenance companies, and call center services companies.

4. Other companies of the Núñez i Navarro Group, for administrative, statistical, accounting, reporting, and internal control purposes or, when you have previously authorized us, to send commercial information.

How long will we retain your personal data?

At Núñez i Navarro, we will retain your personal data for as long as necessary to address any request or inquiry you may have, as long as the contract signed with you is in force, or as long as we have your authorization.
Once this period has passed, you should be aware that the Law imposes on us the obligation to keep your data for an additional period, especially to deal with possible claims. During this time, we will keep them blocked solely to make them available to the State Security Forces and Corps, Judges and Courts, or SEPBLAC or other competent Public Administrations.

What rights do you have to control the personal data you have provided to Núñez i Navarro and how can you exercise them?

The law recognizes a series of rights for you, which you should be aware of and can exercise to protect your privacy. We are mainly referring to your right to:
1. Confirm whether at Núñez i Navarro we are processing your personal data or not and, if so, (a) access them, (b) request their rectification if you believe they are inaccurate or, where appropriate, (c) request their deletion when, among other reasons, you consider that they are no longer necessary, taking into account the purpose for which you provided them to us.

2. Under certain circumstances, you may also request to limit the use we make of your data, or even object to us continuing to use it. In such a case, we will stop using them, except for compelling legitimate reasons or for the establishment, exercise, or defense of legal claims.

3. If we use your personal information to create behavioral profiles (for example, to better understand your interests and needs through the navigation you make on our Website), and we do so in a fully automated manner, you have the right to be informed about it, to request the personal intervention of any of our agents, to challenge any decision based on those profiles, or to simply express your point of view.


4. You will also have the right to request the portability of the data you have provided to us, so that if you are interested, we can send them directly to you or to a third party you indicate, in a commonly used and machine-readable format.

5. Of course, you have the right to withdraw at any time the specific authorizations you may have given us to use your personal data. As we have indicated, all actions carried out before you withdraw your consent will remain lawful.

6. Finally, you can submit any claim to Núñez i Navarro and/or to the Spanish Data Protection Agency through the website www.nyn.es, especially if you have exercised any right and we have not addressed it within the legally established terms.

To do so, you just have to send us an e-mail to the e-mail address gdpr@nyn.es or, if you prefer, send us your request by postal mail to Urgell Street, 230 – 08036, in Barcelona.

Who is the Data Protection Officer of the Núñez i Navarro Group?

At Núñez i Navarro, we have appointed a person, the Data Protection Officer, to ensure that we meet all the legal requirements of the regulations on the protection of personal data.
You can contact them at any time to provide you with all the information related to your personal data. To get in touch with them, you can do so through the following email address: gdpr@nyn.es