Privacy Policy - Dils

LEGAL NOTICE

In compliance with Law 34/2002 of 11 July on Information Society Services and Electronic Commerce, we hereby inform you that DILS REAL ESTATE SPAIN, S.L., with registered address at C/ Serrano 8, 28001 Madrid, Spain, and Tax Identification Number (CIF) B75303313, registered with the Madrid Commercial Registry, is the owner of this website.

DATA CONTROLLER

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD), users are hereby informed that any personal data we may collect directly from them will be processed confidentially by DILS REAL ESTATE SPAIN, S.L. and will be incorporated into the corresponding processing activities.

SCOPE AND PURPOSE OF PROCESSING

This Privacy Policy governs the processing of personal data carried out by DILS REAL ESTATE SPAIN, S.L. in the context of its activity as an international real estate firm specializing in advisory, brokerage, and real estate asset management services. This includes the provision of services in the office sector—such as services for investors—as well as participation in real estate investment transactions across the logistics and industrial, retail, hospitality, and residential sectors:

The management of clients, prospective clients, and website users
The provision of real estate brokerage services
The promotion of national and international real estate assets
Coordination with other companies within the corporate group to which it belongs

For these purposes, the processing may be carried out either directly by DILS REAL ESTATE SPAIN, S.L. or by other companies within its corporate group, depending on the specific operation of the requested service.

Furthermore, as part of its membership in the international DILS group, DILS REAL ESTATE SPAIN, S.L. may offer its clients, prospective clients, and other interested parties real estate opportunities, assets, or developments located in other countries, where such opportunities may be of interest based on their profile, preferences, or requests.

For this purpose, it may be necessary to coordinate the provision of services with other entities within the group, both within and outside the European Economic Area, in accordance with the provisions of this Privacy Policy.

PURPOSE OF THE PROCESSING OF PERSONAL DATA

Personal data will be processed for the following purposes, separately and in accordance with the applicable legal basis in each case:

Management of inquiries, requests, and contacts

To handle, process, and manage any request, inquiry, incident, or communication submitted by the user, including those made through web forms, email, telephone, or other available contact channels. This processing is necessary in order to respond to the data subject’s request, maintain contact with them, and provide the requested information.

Management of the pre-contractual and contractual relationship

To carry out all actions necessary for the provision of real estate services and for the management of the pre-contractual or contractual relationship with the data subject, including, among others, brokerage in sale, lease, or real estate investment transactions, commercial advisory services, organisation of property viewings, document management, coordination with third parties involved in the transaction, monitoring of opportunities and transactions, as well as any actions related to the preparation, execution, and performance of the requested services. This includes advisory services to tenants, owners, and investors, market analysis, structuring of real estate transactions, and the identification of investment opportunities. Additionally, personal data may be processed to offer our services as an international real estate firm through the corporate group to which we belong, including compliance with legal obligations relating to the prevention of money laundering and terrorist financing, identity verification, and analysis of the source of funds, where applicable.

Sending commercial communications and marketing

To send the data subject, by any means, including electronic means, commercial, promotional, or informational communications relating to products, services, investment opportunities, real estate market updates, events, publications, or related content concerning both DILS REAL ESTATE SPAIN, S.L. and other companies within the Group, including communications originating from such entities, even when they act as independent controllers. These communications may be tailored to the data subject’s profile and interests based on the information provided, their previous requests, and their interaction with the company, with the aim of offering more relevant content. In particular, such communications may include real estate assets, developments, or investment opportunities located both in Spain and in other countries in which the DILS Group operates, where these are aligned with the data subject’s profile.

Such processing will be carried out on the basis of the data subject’s consent or, where applicable, on the basis of the Controller’s legitimate interest in promoting its own services, duly balanced in accordance with applicable regulations, particularly where there is a prior relationship with the data subject or where the data subject has shown interest in similar services.

The data subject may object at any time to the processing of their data for commercial purposes, as well as withdraw their consent, through the mechanisms provided for this purpose.

Furthermore, basic commercial profiling may be carried out based on the information provided by the data subject and their interaction with the company, with the aim of offering content, products, and services better tailored to their interests. Under no circumstances will such processing involve automated decision-making producing legal effects concerning the data subject.

Data sharing within the Group

In order to provide you with a comprehensive, coordinated, and tailored service, both in Spain and internationally, personal data may be shared with other offices, branches, subsidiaries, and companies within the Group, as well as, where applicable, with collaborators associated with the network of DILS REAL ESTATE SPAIN, S.L. or the corporate group to which it belongs, including where such entities are located outside the European Economic Area. Such disclosures may be carried out in order to offer real estate products and services tailored to the data subject’s profile, facilitate international investment opportunities, coordinate cross-border transactions, direct requests to the most appropriate office or entity, and ensure consistent and efficient service delivery. In particular, these communications may aim to identify and manage international real estate opportunities, channel requests to the most suitable group entity based on the location of the asset or the client’s interest, and provide coordinated real estate services across different countries. In all cases, such disclosures will be carried out in compliance with applicable data protection regulations and, where appropriate, by implementing adequate safeguards for international data transfers.

Such disclosures will be based, as appropriate, on the performance of the contractual or pre-contractual relationship with the data subject, on the Controller’s legitimate interest in the coordinated management of its business activities, or, where legally required, on the data subject’s consent. The entities within the Group may act, as appropriate in each case, as independent controllers, joint controllers, or processors, depending on the nature of the relationship and the services provided, ensuring at all times an adequate level of protection of personal data in accordance with applicable regulations.

Service improvement, quality, and internal control

To carry out internal analyses, audits, quality control procedures, the preparation of aggregated statistics, satisfaction surveys, supervisory actions, and the continuous improvement of internal processes, as well as training activities and internal supervision and control.

Use of artificial intelligence technologies

DILS REAL ESTATE SPAIN, S.L. may use artificial intelligence technologies, automated tools, and algorithmic support systems in order to improve operational efficiency, optimize internal processes, and enhance customer service. In particular, such tools may be used to manage inquiries, assist in the preparation of automated or semi-automated responses, classify requests, prioritize communications, personalize content and commercial proposals, and improve the user experience and the services provided. In all cases, these systems will operate as support tools and will be subject to appropriate human oversight. Furthermore, the use of these technologies will at all times comply with the principles of lawfulness, fairness, transparency, data minimization, proportionality, security, and confidentiality.

Furthermore, DILS REAL ESTATE SPAIN, S.L. declares that it has implemented the technical and organisational measures necessary to ensure a level of security appropriate to the risk, in accordance with the requirements of the GDPR and the LOPDGDD, in order to prevent the loss, alteration, improper processing, unauthorised access to, or theft of the personal data provided by users.

Under no circumstances will decisions be made based solely on automated processing that produce legal effects concerning the data subject or similarly significantly affect them, unless this is expressly permitted by applicable law and appropriate safeguards are implemented, including the right to obtain human intervention, to express their point of view, and to contest the decision.

Under no circumstances will special categories of personal data be used for these processing activities, nor will artificial intelligence systems be implemented without a prior risk assessment and the adoption of appropriate governance measures.

Furthermore, the data subject may request additional information about the general functioning of these systems and their impact on the processing of their data.

Compliance with legal obligations relating to the prevention of money laundering and terrorist financing

DILS REAL ESTATE SPAIN, S.L., in its capacity as a reporting entity under the applicable regulations on the prevention of money laundering and terrorist financing, will process the data subject’s personal data for the purpose of complying with the legal obligations applicable to it. This includes, among others, formal customer identification, verification of identity, analysis of the source of funds, assessment of the risk associated with the transaction, and, where appropriate, the reporting of suspicious transactions to the competent authorities.

This processing is based on compliance with a legal obligation; therefore, the data may be disclosed to the competent public authorities, including the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences (SEPBLAC), as well as to other bodies where legally required.

Furthermore, in accordance with applicable regulations, the exercise of certain rights by the data subject may be restricted in cases where such limitation is necessary to ensure compliance with legal obligations in this area.

Likewise, personal data processed in this context may be retained for the periods required under the applicable regulations on the prevention of money laundering and terrorist financing.

Use of instant messaging channels

DILS REAL ESTATE SPAIN, S.L. may communicate with data subjects through instant messaging applications, such as WhatsApp, for the purpose of managing inquiries, coordinating property viewings, conducting commercial follow-up, and facilitating the provision of real estate services. The use of these channels by the data subject is voluntary, and they may choose to use other means of communication at any time.

Through these channels, the data subject may send information and documentation related to the transaction, which will be processed in accordance with the provisions of this Privacy Policy.

The use of these channels may involve the involvement of technology providers located outside the European Economic Area, which may entail international data transfers. Such transfers will in all cases be carried out with appropriate safeguards in accordance with applicable regulations, including the use of standard contractual clauses or other legally valid mechanisms.

The data subject is advised not to send particularly sensitive information through these channels, unless it is necessary within the framework of the contractual or pre-contractual relationship.

In all cases, DILS REAL ESTATE SPAIN, S.L. will adopt the necessary organisational and internal control measures to ensure the proper and secure use of these channels by its team. In particular, DILS REAL ESTATE SPAIN, S.L. may establish limitations or internal protocols regarding the transmission of certain documentation through these channels where necessary to ensure information security.

The use of these channels will not be considered the primary means for the exchange of particularly sensitive documentation, and DILS REAL ESTATE SPAIN, S.L. may require the use of more secure alternative channels where necessary. Furthermore, the data subject acknowledges that the use of these channels may entail certain risks inherent to their technological nature.

PRINCIPLES APPLICABLE TO THE DATA YOU PROVIDE TO US

Principle of lawfulness, fairness, and transparency: Personal data will be processed in a lawful, fair, and transparent manner, with the data subject being clearly and previously informed of the purposes of the processing and, where necessary, their consent being obtained.
Purpose limitation: Personal data will be collected for specified, explicit, and legitimate purposes and will not be further processed in a manner incompatible with those purposes.
Data minimisation principle: Only data that are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed will be processed.
Accuracy principle: Personal data will be accurate and, where necessary, kept up to date, and reasonable steps will be taken to ensure that data which are inaccurate are erased or rectified without delay.
Storage limitation principle: Personal data will be retained for no longer than is necessary for the purposes of the processing, without prejudice to their retention for the periods required by applicable law.
Integrity and confidentiality principle: Personal data will be processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, through the implementation of appropriate technical and organisational measures.
Accountability principle: DILS REAL ESTATE SPAIN, S.L. shall be responsible for compliance with the above principles and will adopt the necessary measures to ensure and be able to demonstrate such compliance.

LEGAL BASIS AND LAWFUL GROUNDS FOR PROCESSING

The processing of personal data by DILS REAL ESTATE SPAIN, S.L. is based on the following legal grounds, depending on the purpose:

Performance of a contract or implementation of pre-contractual measures, where necessary for the provision of the requested services (including real estate brokerage, transaction management, customer service, and communications carried out through digital channels and instant messaging tools such as WhatsApp or other equivalent tools).
Legitimate interest, for the management and maintenance of the commercial relationship, including communications with the data subject through digital channels and instant messaging tools such as WhatsApp or other equivalent tools, handling inquiries, improving services, preventing fraud, and sending communications regarding similar services, including the promotion of real estate opportunities within the international corporate group to which DILS REAL ESTATE SPAIN, S.L. belongs. All of the above is carried out taking into account the reasonable expectations of the data subject, particularly where there is a prior relationship or an active request for services, and ensuring in all cases a simple and free-of-charge right to object in each communication.
Consent of the data subject, given through a clear affirmative action, for specific purposes such as sending commercial communications, the use of cookies, handling requests, carrying out basic commercial profiling, and sharing data with Group companies, including those located outside the European Economic Area.
Compliance with legal obligations, where processing is necessary to comply with obligations imposed by applicable regulations, including those relating to the prevention of money laundering and terrorist financing.

Furthermore, DILS REAL ESTATE SPAIN, S.L. may use technological tools, including artificial intelligence systems, to improve customer service and personalize services, without adopting automated decisions with legal effects without the safeguards required by applicable regulations.

In the event of international data transfers, these will be carried out with appropriate safeguards in accordance with applicable law.

Where the user has not contracted any services, the legal basis will primarily be consent; in the case of clients, it will also include the performance of a contract and legitimate interest.

The data subject may withdraw their consent at any time, without affecting the lawfulness of prior processing, and may request additional information regarding the applicable legal bases and processing activities.

PERSONAL DATA RETENTION PERIOD

Personal data will be retained for as long as necessary to fulfil the purpose for which it was collected, as well as, where applicable, for the limitation periods of any relevant legal liabilities and any other retention periods required by applicable law.

Additionally, data may be retained for as long as there is a legitimate interest in maintaining the purpose of the processing and until the data subject requests its erasure, provided that it does not need to be retained in order to comply with a legal obligation.

Without prejudice to the foregoing, and unless a different retention period applies as a result of a legal obligation or the need to address potential liabilities, the following indicative periods shall apply:

Management of inquiries, requests, and contacts: data will be retained for as long as necessary to handle the request and, in any event, for a maximum period of twelve (12) months from the last interaction, unless a contractual or pre-contractual relationship arises from it.
Pre-contractual and contractual relationship: data will be retained for the duration of the relationship and, thereafter, for the periods required by law for compliance with legal obligations and for the establishment, exercise, or defence of legal claims.
Commercial communications: data will be retained until the data subject withdraws their consent or objects to the processing.
Data sharing within the Group: data will be retained for as long as necessary to achieve the purpose of service coordination and until its erasure is requested.
Use of artificial intelligence technologies: data processed in the context of interactions with automated systems will be retained for a maximum period of twelve (12) months.
Recruitment processes: if the candidate is not selected, the data will be retained for a maximum period of twenty-four (24) months, unless the data subject authorizes its retention for a longer period. In the event of hiring, the data will be retained for the duration of the employment relationship and thereafter for the periods required by applicable law.
Security and internal control: data will be retained for as long as necessary to ensure system security and in accordance with the periods established by applicable law.

In all cases, once the above periods have elapsed, the data will be duly restricted and subsequently erased or anonymised.

In the event of withdrawal of consent or the exercise of the rights of erasure or cancellation, the data will be restricted and retained solely at the disposal of the competent authorities for the legally established periods in order to address any potential liabilities arising from the processing.

DATA RECIPIENTS AND DISCLOSURES

All disclosures set out below are necessary for the fulfillment of the purposes described above or are carried out in compliance with a legal obligation. Personal data may be disclosed to:

Companies within the DILS Group (https://dils.com/) for the purpose of identifying and channeling real estate opportunities within the Group
Other companies within the DILS Group or collaborators associated with its network, solely for the purpose of offering you the products best suited to your needs or requests
Public Administrations and the Courts
IT service providers, including cloud computing service providers

INTERNATIONAL DATA TRANSFERS TO THIRD COUNTRIES

As a general rule, the processing of personal data is carried out by service providers located within the European Union or in countries that have been recognized as providing an adequate level of data protection in accordance with applicable regulations.

However, in certain cases, for the purposes described above, DILS REAL ESTATE SPAIN, S.L. may engage service providers that access personal data from outside the European Economic Area, which may entail international data transfers. This includes transfers arising from international operations and coordination among different entities within the DILS Group, as well as from the use of technology providers for the management of communications, digital platforms, and messaging tools such as WhatsApp or other equivalent tools.

Such transfers will in all cases be carried out with appropriate safeguards, in accordance with applicable regulations, including, where applicable, adequacy decisions of the European Commission or the execution of standard contractual clauses approved by the European Commission, as well as other valid mechanisms that ensure a level of protection equivalent to that of the European Union. The data subject may request additional information regarding such safeguards by submitting a request to the Controller.

Furthermore, where necessary, specific assessments of the impact of international data transfers will be carried out in order to ensure that the level of protection of personal data is not undermined, adopting, where appropriate, additional measures complementary to the standard contractual clauses.

DATA SUBJECT RIGHTS

Users or clients may exercise their rights of access, rectification, erasure, and portability of their data, as well as restriction of and objection to processing, and the right not to be subject to decisions based solely on automated processing of their data, with DILS REAL ESTATE SPAIN, S.L. They may also withdraw, at any time, the consent given for specific purposes, without affecting the lawfulness of processing based on consent prior to its withdrawal, and may modify their preferences. In particular, where processing is based on legitimate interest or carried out for commercial purposes, the data subject shall have the right to object at any time.

A brief description of these rights is provided below:

Right of access: enables the data subject to know what personal data are being processed, for what purpose, their origin, and, where applicable, any disclosures made or envisaged.
Right to rectification: allows the data subject to request the correction of inaccurate or incomplete personal data.
Right to erasure: allows the data subject to request the deletion of personal data where, among other reasons, they are no longer necessary for the purposes for which they were collected, without prejudice to any legal obligations to retain such data.
Right to object: allows the data subject to object to the processing of their data in relation to any of the purposes for which they are processed, in particular where the processing is based on legitimate interest.
Right to restriction of processing: allows the data subject to request the restriction of the processing of their data in the following cases:
where the accuracy of the data is contested
where the processing is unlawful and the data subject opposes its erasure
where the data are no longer necessary for the purposes of the processing, but the data subject requires them for the establishment, exercise, or defence of legal claims
where the right to object has been exercised and verification is pending
Right to data portability: allows the data subject to receive the personal data they have provided in a structured, commonly used, and machine-readable format, and to transmit those data to another controller where technically feasible.

These rights may be exercised by submitting a request to privacy.spain@dils.com or by post to C/ Serrano 8 (entrance via C/ Conde de Aranda 2), 28001 Madrid, Spain.

The data subject also has the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es), in particular where they consider that the processing of their data does not comply with applicable regulations.

DATA RELATING TO MINORS

DILS REAL ESTATE SPAIN, S.L. will not collect or process personal data of minors under 14 years of age without the prior consent of their parents, guardians, or legal representatives, in accordance with applicable data protection regulations.

Accordingly, where the data subject is under 14 years of age, the processing of their personal data will only be considered lawful if such consent has been given or authorized by the person exercising parental authority or guardianship, and to the extent that such consent has been provided.

DILS REAL ESTATE SPAIN, S.L. reserves the right to request the necessary documentation to verify the user’s age or the authenticity of the consent provided by their legal representatives.

PERSONAL DATA OF THIRD PARTIES

If the user provides DILS REAL ESTATE SPAIN, S.L. with personal data relating to third parties, the user must ensure that such individuals have been previously informed of the content of this Privacy Policy and that their consent has been obtained where required for the disclosure of their data.

The user also guarantees that the data provided are accurate, truthful, and up to date, and assumes responsibility for any direct or indirect damage or harm that may arise from a breach of this obligation.

PROCESSING OF CURRICULUM VITAE

Personal data provided by candidates will be processed by DILS REAL ESTATE SPAIN, S.L. for the purpose of managing their application and participation in current or future recruitment processes.

The legal basis for this processing is the implementation of pre-contractual measures at the request of the data subject and, where applicable, the data subject’s consent for the retention of their application for future recruitment processes.

The data may be disclosed to other companies within the Group or to recruitment service providers acting as processors, solely for the purpose of managing recruitment processes.

The data will be retained for a maximum period of 24 months, unless the candidate requests its erasure earlier or a different retention period applies in accordance with applicable regulations.

The candidate may exercise their data protection rights at any time, in accordance with the provisions set out in this Privacy Policy.

DILS REAL ESTATE SPAIN, S.L. reserves the right to amend this Privacy Policy in order to adapt it to legislative or case law developments, as well as to industry practices.

USERS WHO DO NOT AGREE WITH THIS POLICY MUST NOT SUBMIT ANY DATA THROUGH THIS WEBSITE OR ACCESS ITS CONTENT.

TERMS OF USE AND WEBSITE CONTENT

All content included on the website, including, by way of example and without limitation, texts, photographs, graphics, images, icons, technology, software, graphic design, and source code, is owned by DILS REAL ESTATE SPAIN, S.L. or, where applicable, by third parties. Access to the website shall not be construed as granting the user any rights of exploitation over such content. Accordingly, any reproduction, distribution, public communication, transformation, or any other form of exploitation, in whole or in part, is expressly prohibited without the prior written authorization of the rights holder.

DILS REAL ESTATE SPAIN, S.L. shall not be liable for any third-party content that may be published on the website, provided that it has no actual knowledge that such content is unlawful or infringes the rights of third parties, or, if it does have such knowledge, it acts diligently to remove it or prevent access to it.

The user undertakes to make appropriate use of the website’s content and services in accordance with the law, good faith, and public order, and in particular agrees not to use them for unlawful purposes or in a manner that infringes the rights or interests of third parties, not to reproduce or exploit the content without authorization, and not to cause damage to the physical or logical systems of DILS REAL ESTATE SPAIN, S.L. or of third parties.

The relationship between the user and DILS REAL ESTATE SPAIN, S.L. shall be governed by the applicable laws of Spain. For the resolution of any disputes arising from access to or use of the website, the parties submit to the Courts and Tribunals of Madrid, unless applicable consumer protection laws establish a different mandatory jurisdiction.

COOKIE POLICY

The website uses its own and third-party cookies in order to ensure its proper functioning, analyse users’ browsing behaviour, and, where applicable, personalize content and advertising. Users may obtain detailed information about the use of cookies, as well as configure or reject their use, through the Cookie Policy available on the website.