Privacy Policy

HISPANIA ACTIVOS INMOBILIARIOS SOCIMI, S.A. (HISPANIA or the Entity) makes this Privacy Policy available to the users of the website located in the URL www.hispania.es (the Website), in order to provide information about how we process your personal data and protect your privacy and information.

HISPANIA requests that users spend a few minutes carefully reading this Privacy Policy.

Introduction

This Privacy Policy applies to the HISPANIA Website, made available to the public in the URL www.hispania.es, as well as to the user's interactions with HISPANIA through that Website.

HISPANIA may change whole or part of this Privacy Policy when necessary. If any changes are made, we will notify you through the Website or by other means, in order to find about the new Privacy terms and conditions. By continuing to make use of the functionalities made available by HISPANIA after having been notified of these changes you will state your agreement with them, except for those cases in which your express consent is required.

Who is the Controller for your personal data?

The controller for the personal data, in relation to the Website, is the company HISPANIA ACTIVOS INMOBILIARIOS SOCIMI, S.A., holder of tax identification number A-86919271 with address for these purposes at Edificio Sarrià Forum. Avda. Sarrià 102-106, Planta 11. 08017. Barcelona.

To guarantee adequate management of the processing of your data, HISPANIA has appointed a Data Protection Officer, whom you may address for any matter that might arise and who can be contacted at the email address dpo@hipartners.es.

What is the purpose of processing your personal data?

The personal data provided by users of this Website may be processed by HISPANIA for the following purposes, depending on the type of data provided by the user, as well as on the interactions between the user and HISPANIA through the Website.

  1. Contact and management and processing of website users' queries and requests: The personal data of users who contact HISPANIA through any of the contact channels made available through the Website in order to receive queries and/or requests from users will be processed to maintain contact between the parties, manage Website users, provide customer or user service, and manage and process user requests or queries sent via the channels provided for this purpose on our Website.
  2. Commercial communications pertaining to HISPANIA: Users' personal data may be processed by HISPANIA to send advertising, promotional, or relevant information about HISPANIA, as well as corporate information about HISPANIA and information about industry events of interest, by electronic communication means (email, SMS, and other equivalent electronic communication means) exclusively if the user had consented to this purpose if processing.In this regard, the Website does not keep a registration form or a form to request the delivery of commercial communications. HISPANIA obtains users' informed consent, in all cases, by external means unrelated to this Website. Users may object at any time to the purpose of the processing of their data for advertising or promotional purposes by HISPANIA by using the channels provided for this purpose by HISPANIA, as described in the section: What are your rights regarding your personal data? Likewise, the user will have the option of opposing said processing in each of the commercial communications sent to him/her.
  3. Whistleblower's channel management: Any data obtained by HISPANIA as a result of the communication or reporting of any kind of incident through the whistleblower's channel provided by HISPANIA for this purpose and made available by computer means will be processed for the exclusive purpose of managing and processing any claims, incidents, and irregularities reported, as established in its Code of Conduct.

HISPANIA expressly states that, in these cases, the data provided may be processed both by HISPANIA and by the company belonging to its business Group with which the claimant has the work, commercial, or professional relationship.

Finally, we inform that the personal data obtained by HISPANIA through the Whistleblower's Channel are strictly confidential and will be processed exclusively by staff authorized to manage and process that potential claim, incident, or irregularity.

What data are processed by HISPANIA and what are their sources?

The data processed by HISPANIA as a result of the user's interactions through our Website come from the following sources:

  • Data provided by the user by filling in the forms made available by HISPANIA or by any other means by which the user communicates with HISPANIA.
  • Data generated as a result of the development, processing, and maintenance of the relationship established between the user and HISPANIA.

HISPANIA may process personal data of the following types, depending on the relationship established with the user:

  • Identification and contact data (e.g. name and surname, email, postal address, telephone, IP address, etc.)
  • Other data types. If the Website user provides other types of data in their interactions with HISPANIA, mainly through the reports issued through the Whistleblower's Channel made available online by the Company, will these data be processed by HISPANIA, only if their processing is required for the purpose sought. Otherwise, the data will be erased without having been previously stored by HISPANIA.

What is the legal basis for the processing of your data by HISPANIA?

HISPANIA processes the personal data provided by the users of its Website on the following legal bases, depending on the type of data provided by the user, as well as on the user's interactions with HISPANIA:

  • The processing of your data for the purpose of "Contact and management and processing of Website users' queries and requests" is based on the management and processing of the legal relationship established between the user and HISPANIA, that is, on the management of the request, on the maintenance of the contact between the parties, and, if applicable, on the provision of the service requested by the user, as well as, in the legitimate interest of HISPANIA to respond to queries and requests from users.
  • The processing of your data for the purposes "Commercial communications pertaining to HISPANIA" is based on the consent requested in each case of the user. HISPANIA informs that it will only carry out this processing in the cases in which the user has expressly consented, through the means of obtaining consent made available by HISPANIA.
  • The processing of your data for the purpose "Whistleblower's Channel" is based on the existence of a public interest in the terms set out in Article 6.1(e) of Regulation (EU) 2016/679.

Who are the recipients of your data?

HISPANIA informs users that, regarding the purpose of data processing "Whistleblower's Channel", it may transfer data to the company of its business group with which the user maintains the work, commercial, or professional relationship to be in a position to manage them efficiently, as well as to the Courts in those cases in which it is necessary.

Regarding the other purposes of data processing established by means of this Privacy Policy, HISPANIA informs users that these purposes of processing do not entail the transfer of their data by HISPANIA to third-party entities, except for legal obligation. However, third parties providing internal management services may have access to them.

How long will we keep your personal data?

HISPANIA will keep your personal data for as long as required for the provision of the service requested and/or to achieve the purpose of the processing sought.

Later, provided that the user has not exercised its right of removal, their data will be duly kept during the applicable legal periods, taking into account the type of the data as well as the purpose of their processing.

In any case, the user may request detailed information about the data retention periods applied at HISPANIA by contacting our Data Protection Officer, who can be contacted at dpo@hipartners.es .

What personal data should be provided in each case?

HISPANIA informs users that, when personal data are obtained through a form made available on our Website, the user must provide at least the data specified as mandatory, with an asterisk (*), in the form in question. If at least those data, which are regarded as mandatory, are not provided, HISPANIA will be unable to manage the service or the query made by the user.

What should you warrant by providing your personal data?

The user warrants that the information provided is true, accurate, complete, and up-to-date, and is responsible for any harm or loss, direct or indirect, that may be caused as a result of a breach of this obligation.

If the user provided these third-party data, they warrant that they have informed that third party of all the aspects of this Privacy Policy and obtained their consent to provide their data for the purpose of their processing in question. All this prior to the supply of third-party data through our Website. This must be understood with the exception of the peculiarities of the supply of third-party data through the Whistleblower's Channel made available by HISPANIA online.

HISPANIA informs you that, you must be older than 18 to provide your personal data in any way through our Website. Users who provide data to HISPANIA through this Website represent and warrant that they are older than 18, and are entirely responsible for this statement.

What measures to we take to protect your personal data?

Given HISPANIA’s interest in ensuring the security and confidentiality of your data, the security measures required for personal data protection have been taken and the technical measures at its disposal have been implemented to prevent loss, misuse, alteration, unauthorised access, and theft of the personal data provided through the Website. In any case, it should be borne in mind that online security measures are not unassailable.

What are your rights over your personal data?

HISPANIA informs you that you have the right to receive the confirmation of whether we are processing personal data affecting you or not.

HISPANIA also informs you that you have the following rights over your personal data:

  • Accessing your data: You have the right to access your data to find which personal data concerning you we are processing.
  • Requesting the rectification or removal of your data: Under certain circumstances, you have the right to rectify those personal data that you regard as inaccurate and concern you, and are processed by HISPANIA, as well as the right to request the removal of your data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
  • Requesting the limitation of the processing of your data: Under certain circumstances, you will have the right to request that we limit the processing of your data, in which case we inform you that we will only keep the data, the limitation of processing of which has been requested for the exercise or defence of claims.
  • To the portability of your data: Under certain circumstances, you will have the right to receive the personal data that concern you and that you have provided to us, in a commonly used structured format that is automatically read, as well as to their transfer by HISPANIA to another controller.
  • Objecting to the processing of your data: Under certain circumstances and for reasons connected to your specific situation, you will have the right to object to the processing of your data, in which case we will cease to process them unless we must continue to do so for legitimate imperative reasons or for the exercise or defense of potential claims.

We also remind you that you have the right to withdraw any of the consents given for the processing of your data, without this affecting the lawfulness of the processing based on the consent prior to their withdrawal.

HISPANIA informs you that you may exercise your rights over personal data by means of a written message sent to HISPANIA ACTIVOS INMOBILIARIOS SOCIMI, S.A., with the subject line "Data Protection", together with photocopy of your national identification document or an equivalent document, on both sides, which may be sent to either of the following addresses:

  • Edificio Sarrià Forum. Avda. Sarrià 102-106, Planta 11, 08017, Barcelona
  • dpo@hipartners.es

HISPANIA will provide the information requested within one month from the reception of the request. This period may be extended by an additional two months if necessary, taking into account the complexity and volume of requests.

You may file a complaint with the Data Protection Officer, who will resolve the complaint within a maximum period of one month. Likewise, HISPANIA notifies you that you may file a claim with the competent Control Authority as regards data protection.