Information on the processing of customer personal data by Kronos
Party responsible for data processing
KRONOS INVESTMENT MANAGEMENT SPAIN, S.L. or any of the companies managed by Kronos depending on the Project (hereinafter referred to as "KRONOS").
Registered office: C/Serrano 8, 28001, Madrid
Data Protection Officer contact: email@example.com
What data processing is carried out by KRONOS?
The processing of personal data by KRONOS will depend on the status of the temporary relationship with the data subject. Below, we will detail purposes, legal bases associated with the processing, categories of data processed, as well as retention periods of the personal data processed.
1. Request for information phase:
KRONOS will process the personal data collected directly from the interested parties or through the information request forms in order to be able to attend the request about the indicated promotion. In this sense and according to the request received, KRONOS will send the interested party information about the development of the property they are interested in. If the interested party does not wish to continue receiving information about said promotion, they may request the cancellation of communications whenever they consider it appropriate through the following e-mail address: firstname.lastname@example.org.
Finally, the application form requests the interested party's consent to: (i) receive information about other developments marketed by KRONOS and (ii) communicate their data to other companies in the real estate sector managed by Kronos so that they can send information about their products. This treatment is explained in section 5 of this document "Commercial information".
Legitimacy in the processing of personal data: KRONOS processes the information provided on the basis of:
Categories of personal data: The personal data that KRONOS will process at the time of the information request are: name and surname, address, e-mail address, details of the property of interest, as well as the contact details of the sales representative assigned to your information request.
Data Retention: KRONOS will keep the personal data of the interested parties during the marketing period of such promotion. If the interested parties finally decide to proceed with the purchase of the property, KRONOS will process the information related to the down payment or purchase in accordance with the data processing foreseen for those phases. If, in the end, the interested parties do not proceed with the purchase of the property, KRONOS will not process such information, except in the case foreseen in point 5 on commercial information. See point 5. Commercial Information.
2. Choice of property phase:
KRONOS will process your personal data in order to manage the choice of the property by the interested party. This choice can be made by means of a deposit document.
Legality in the processing of personal data:
KRONOS will process all information provided by the data subject for the purpose of managing the choice of a property for future purchase (art.6.1.b) of the General Data Protection Regulation). In this regard:
Likewise, from the moment the deposit is made, KRONOS implements all the obligations arising from the regulations on the prevention of money laundering and terrorist financing with the processing of personal data derived from the identification obligations. (art.6.1.c) of the General Data Protection Regulation). In this case, the data subject is informed that KRONOS may share this information with the other companies it manages in the real estate sector for the sole purpose of streamlining and managing the obligations that fall on these companies in this area. You may view the details of these companies at https://kronoshomes.com/sociedades.
On the other hand, only in the event that the interested party has expressly consented to the option of financing the property (art.6.1.a) of the General Data Protection Regulation) the data of the interested party may be communicated to the financial institution with which KRONOS maintains relations to facilitate the financing of this promotion, for the purpose of contacting them for the study and management of the possible financial transaction for the purchase of the aforementioned property. This consent will imply that the entity chosen for the possible financing will communicate your data to KRONOS once the operation has been approved or denied in order to continue with the negotiations of the possible purchase of the property in the appropriate terms.
Categories of personal data: The personal data that KRONOS will process at the time of choosing the property will be your name and surname, address, e-mail address, details of the property of interest, the salesperson assigned to your request for information, guarantee deposit, account information from financial institutions, signed deposit documents, expected time of formalization of the purchase contract and identification documents required by KRONOS in order to comply with obligations for the prevention of money laundering. KRONOS may also obtain additional data, either from common information files for the prevention of money laundering, as well as from official public registries.
Data retention: KRONOS will keep your personal data during the period of choice of the property or it can be extended in the event that the purchase is formalized. In the event that the purchase of the property does not materialize, your data will be kept blocked for a period of ten years to comply with the obligations of conservation of documentation derived from the regulations on prevention of money laundering and terrorist financing.
3. Purchase and Sale Formalization Phase:
KRONOS will process the buyers' data in order to manage and formalize the purchase contract.
Legality in the processing of personal data: KRONOS processes the information provided on the basis of the processing necessary for the performance of a purchase contract between the data subject and KRONOS. (art.6.1.b) of the General Data Protection Regulation). In this regard, this relationship will involve the following processing of personal data:
Compliance with identification obligations derived from the applicable regulations (art.6.1.c) of the General Data Protection Regulation):
Only in the event that the interested party has consented to the financing of the property, their data may be communicated to the financial institution with which KRONOS maintains relations to carry out the economic operation of the purchase of the property. (art.6.1.a) of the General Data Protection Regulation).
Categories of personal data: The personal data that KRONOS will process when you choose a property will be your name and surname, address, e-mail address, details of the property you are interested in, the salesperson assigned to your request for information, guarantee deposit, financial institution account information, professional information, family information, financial situation information, tax information, signed deposit documents, expected completion dates of the purchase contract and identification documents required by KRONOS in order to comply with anti-money laundering obligations. Furthermore, KRONOS may obtain additional data, either in common information files for the prevention of money laundering, as well as from official public registries. Likewise, KRONOS may process personal data of third parties provided by the buyer, such as: legal representatives, collaborators, guarantors, relatives or other related persons in case of presenting personal and material guarantees.
With respect to the above-mentioned processing of third-party data, the purchaser confirms that such data are genuine and that the subjects concerned have been informed and have consented to the processing of their personal data by KRONOS.
Data retention: KRONOS will keep your personal data during the entire process of formalization of the purchase. Once the period of one year and a half has elapsed (the period provided for possible post-sale management) your data will be kept blocked for a period of ten years to comply with the obligations of conservation of documentation derived from the regulations on the prevention of money laundering and terrorist financing.
4. Quality surveys:
Also, KRONOS will send you, based on its legitimate interest (art.6.1.f) of the General Data Protection Regulation), quality surveys on the service offered, the properties offered in order to learn from customer feedback, improve the information and quality of the processes and therefore the experience of all stakeholders in KRONOS promotions. KRONOS has carried out a weighting test of the aforementioned legitimate interest in order to verify that the sending of these satisfaction surveys to those interested in KRONOS promotions does not undermine their data protection rights. After such analysis, KRONOS understands that these rights are not violated given the clear information contained in this information document, as well as the possibility of the interested party to oppose the sending of such surveys either (i) via email at the time of the request and (ii) in the unsubscribe procedure that exists in such communication. Likewise, KRONOS will not send such surveys to those who have not consented to receive information about other KRONOS Group promotions. If you would like to know more about the details of this weighting test, you can request this at the following email address: email@example.com.
5. Commercial information:
In the information request forms, KRONOS will enable a mechanism for those who are interested to expressly consent to the subsequent processing (art.6.1.a) of the General Data Protection Regulation):
Only if the interested party has consented to such processing, KRONOS will process such information in any of its phases in order to keep them informed of other promotions or that other companies may know their data to send associated information. The interested party may always revoke the consent given. KRONOS, in the rest of the documentation associated with the sale of the property, includes mechanisms for revocation of consent, but, in any event, you can always revoke such consent, through a written communication, together with a copy of your ID card, at the address Calle Serrano 3, 28001 Madrid or via email to: firstname.lastname@example.org.
6. Processing of Web data:
If the interested party wishes to know about the processing of personal data carried out by KRONOS through www.kronoshomes.com, they may refer to the following informative texts:
If the interested party wishes to know about the processing of personal data carried out by KRONOS, through https://www.kronosig.com they can refer to the following informative texts:
To whom are your personal data communicated?
International Data Transfers
The interested party is informed that KRONOS does not carry out international transfers of its data.
Possible Claims or Exercise of Data Protection Rights
The interested party may exercise the rights of access, rectification, deletion, limitation, opposition, and portability with respect to their personal data, as well as the right to withdraw the consent given, requesting this in writing by email to email@example.com or letter addressed to the registered office of KRONOS indicated above, attaching a copy of your ID card. You can also file any type of data protection claim to the address indicated above or the interested party can go to the Spanish Data Protection Agency, the supervisory authority on data protection: http://www.agpd.es.