Privacy Policy

In compliance with the General Data Protection Regulation (GDPR), we provide users of this website with this Privacy Policy to inform them about how we handle their personal data and protect their privacy and information.

Legal Regulations Applicable to the Website:

GRUPO TOP GESTIÓN has adapted this website to the requirements of Organic Law 3/2018, of December 5, on Personal Data Protection and the guarantee of digital rights (LOPD-gdd). It also complies with Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR), as well as Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSICE).

1. Joint Data Controllers:

1.1. Who are the Joint Data Controllers?

The companies belonging to the group of companies participated by TOP GESTIÓN or whose sole partner is TOP GESTIÓN and that independently develop each of the real estate promotions carried out by the TOP GESTIÓN group as part of its main activity.

1.2. Joint Trade Name of All Companies in the TOP GESTIÓN Group:

GRUPO TOP GESTIÓN

1.3. Common Contact Point:

Company Name: TOP GESTIÓN MADRID, S.L. | B86831476
Address: C/ Príncipe de Vergara, 120, staircase 3, 1st left, 28002 Madrid
Contact: Tel. 912 90 44 94 – Email: topgestionmadrid@grupotopgestion.com

1.4. Legal Regulation of the Joint Responsibility Situation:

In order to comply with the provisions of the applicable European Union Data Protection Regulation (Art. 26 of the GDPR), a Convention has been drafted to enable and globally regulate the joint responsibility regime for the processing of personal data among the various companies that make up the GRUPO TOP GESTIÓN. New entities created that are part of GRUPO TOP GESTIÓN have progressively adhered to this Convention by completing the Membership Document attached as Annex Two to the Convention itself. In compliance with the applicable regulations and upon request by the interested party at the email address topgestionmadrid@grupotopgestion.com, the Convention can be made available to them.

1.5. Origin and Communication of Intra-group Data:

For the purposes established in the GDPR and LOPD-gdd, the referral or sending by the User of personal data (data relating to identified or identifiable persons) through any website of GRUPO TOP GESTIÓN and the subsequent processing by us will be considered as data processing activity. The personal data processed by GRUPO TOP GESTIÓN comes from the various forms available on the group’s websites.

GRUPO TOP GESTIÓN guarantees the User that it will implement the appropriate technical and organizational security measures for the processing of such data to safeguard 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 joint data controllers for the purpose of carrying out joint and/or individualized processing, as applicable.

2. Purpose of Processing and Legitimacy

2.1. What Purpose Do We Process Your Data For?

At GRUPO TOP GESTIÓN, we process the data collected through the various forms on the websites for the following purposes:

Management, study, and resolution of inquiries regarding: the information included on the website and/or about our services; data processing, legal texts, claims, as well as any other issues.
Management and processing of User registration.
Management and processing of the GRUPO TOP GESTIÓN subscription list and sending newsletters, promotions, and offers.
Preparation of budgets, at the request of the interested party.
Management of reservations, at the request of the interested party.
Management, study, and resolution of communications regarding: alleged regulatory breaches, alleged violations of the Code of Ethics, alleged negligent acts or omissions; communication to the competent authorities or courts, where applicable.

The data provided will be located on the servers managed by the hosting service provider of the website on which the user has entered the relevant data, which will be considered the data processor. All servers of the various hosting providers of GRUPO TOP GESTIÓN are located within 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. Typically, GRUPO TOP GESTIÓN hosts its websites on the servers of OVH HISPANO, S.L. or RAIOLA NETWORKS, S.L. However, due to the large number of websites owned by GRUPO TOP GESTIÓN, among other factors, it is quite complex to provide a comprehensive list of: website – hosting service provider. If the interested party wishes to know which hosting provider has or had access to their personal data, they may contact our team at the following email address: topgestionmadrid@grupotopgestion.com. The interested party will be solely responsible for completing the forms with false, inaccurate, incomplete, or outdated data, and GRUPO TOP GESTIÓN is exempt from any responsibility in this regard. Users guarantee and are responsible, in any case, for the accuracy, validity, and authenticity of the personal data provided and commit to keeping them duly updated.

2.2. What is the Basis That Legitimizes 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 grant by providing the requested data through the website forms and marking the acceptance box for this privacy policy.

2.3. Will It Be Necessary for You to Provide All Your Data? What Will Happen If You Don’t Provide Us with Your Data?

Yes, it will be necessary for you to provide all the requested personal data. If you do not provide the requested data, we will not be able to properly attend to your request.

2.4. Will We Make Automated Individualized Decisions and/or Profile Creation that 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 retain your personal data for as long as necessary to achieve the purpose or purposes of processing pursued. Subsequently, as long as the user has not exercised their right to deletion, their data will be retained for the legal periods that apply in each case, taking into account the type of data and the purpose of the processing. In any case, the user may request detailed information about the data retention periods applied by contacting our Data Protection Officer at: topgestionmadrid@grupotopgestion.com.

3. Recipients of Assignments:

3.1. Will We Assign Your Data to Other Companies?

If you consent, GRUPO TOP GESTIÓN may assign your data to third parties providing home-related services so that they can send you commercial information about their products or services. Likewise, regarding other treatments not related to third-party advertising, GRUPO TOP GESTIÓN informs you that data may be communicated to the following recipients:

National or international competent authorities, including judicial bodies, regulatory and supervisory agencies, and state security forces and bodies.

Additionally, please note that for the provision of services available through this Website, the involvement of third-party service providers (e.g., web hosting and infrastructure, customer management tools, etc.) is necessary, which 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 that regulates the relationship between both, in order to provide additional guarantees for the proper processing by the respective marketer. Such guarantees or guidelines for processing personal data, in conjunction with the pre-existing ones diligently implemented by each marketer, presume 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 assigned data.

If the interested party wishes to obtain more information regarding this or wishes to communicate any apparently unlawful/illegal processing of their assigned personal data to the respective marketer, they may contact the email address topgestionmadrid@grupotopgestion.com, so that our team can provide more information and/or assess the possible breach of the contract signed with the marketer, and where appropriate and at our sole discretion, we may adopt and implement appropriate measures in defense of the affected User’s rights and interests. Users are informed that, for the proper provision of services (e.g., web hosting, marketing, etc.), different service providers contracted by GRUPO TOP GESTIÓN (data processors) may have access to the personal information necessary to perform their functions. These services provided by third parties are necessary for the development of GRUPO TOP GESTIÓN’s activity, and at all times, the processing of the data they carry out will be governed by a contract binding the processor to GRUPO TOP GESTIÓN. In no case will they use the information for other purposes, and they will process it in accordance with the guidelines stipulated by GRUPO TOP GESTIÓN and the current regulations on data protection. GRUPO TOP GESTIÓN, in its commitment to User privacy and data protection, will only choose service providers that offer sufficient guarantees to apply appropriate technical and organizational measures, so that processing complies with the applicable data protection legislation and guarantees the protection of User rights.

4. Recipients of International Transfers:

4.1. Will Your Personal Data Be Transferred to Third Countries or International Organizations?

Currently, GRUPO TOP GESTIÓN does not transfer personal data to third countries or international organizations.

5. Rights of the Data Subject

5.1. What Rights Do You Have Over Your Data?

As a User, you have the following rights with respect to your personal data:

Right to access: You have the right to obtain confirmation about whether GRUPO TOP GESTIÓN is processing your personal data or not.
Right to rectification: You have the right to request the correction of inaccurate or incomplete data.
Right to erasure: You can request the deletion of your personal data when they are no longer necessary for the purposes for which they were collected.
Right to restriction of processing: You have the right to request the restriction of processing when:
- You contest the accuracy of your personal data, for a period that allows GRUPO TOP GESTIÓN to verify its accuracy.
- The processing is unlawful and you oppose the deletion of personal data.
- GRUPO TOP GESTIÓN no longer needs your personal data for the purposes of processing, but you require it for the formulation, exercise, or defense of claims.
- You have objected to processing pending the verification of whether the legitimate grounds of the data controller override those of the data subject.
Right to data portability: You have the right to receive the personal data concerning you, which you have provided to GRUPO TOP GESTIÓN, in a structured, commonly used, and machine-readable format, and to transmit it to another controller.
Right to object: You have the right to object to the processing of your personal data based on the legitimate interest pursued by GRUPO TOP GESTIÓN or by a third party, including profiling. If you object, GRUPO TOP GESTIÓN will no longer process your personal data, unless it demonstrates compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the formulation, exercise, or defense of claims.

5.2. How Can You Exercise Your Rights?

You can exercise your rights by sending a request to the email address topgestionmadrid@grupotopgestion.com, or by writing to the following postal address: TOP GESTIÓN MADRID, S.L.
C/ Príncipe de Vergara, 120, staircase 3, 1st left,
28002 Madrid

In both cases, you must include:

Your first and last name, photocopy of your ID card or any other identification document.
A clear request specifying the right you wish to exercise.

5.3. Right to Withdraw Consent:

You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on the consent prior to its withdrawal. You can exercise this right in the same way as indicated in the previous point.

5.4. Right to Complain to a Supervisory Authority:

If you believe that your rights have been violated in relation to the processing of your personal data, you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD), through its website www.aepd.es, or by contacting the AEPD at C/ Jorge Juan, 6, 28001 Madrid.

6. Security Measures

6.1. How Do We Protect Your Personal Data?

GRUPO TOP GESTIÓN has implemented the appropriate technical and organizational security measures to protect the personal data processed against unauthorized access, unlawful processing, loss, destruction, or damage.

7. Updates and Modifications

7.1. Will This Privacy Policy Be Updated?

This Privacy Policy may be updated to adapt it to new legal and regulatory requirements or due to changes in our activities. We will notify you of any significant changes to the processing of your personal data through the website or by any means of communication.

8. Contact Information

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us at:

TOP GESTIÓN MADRID, S.L.
C/ Príncipe de Vergara, 120, staircase 3, 1st left,
28002 Madrid
Email: topgestionmadrid@grupotopgestion.com