Information on the processing of personal customer data by Kronos

Data controller

KRONOS INVESTMENT MANAGEMENT SPAIN, S.L. or any of the companies managed by Kronos depending on the Project (hereinafter "KRONOS")

Registered office: C/Serrano 8, 28001 Madrid, Spain

Data Protection Officer Contact: protecciondedatos@kronosre.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 interested party. 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. Information request stage:

KRONOS will process the personal data it collects directly from the interested parties or through information request forms in order to process the request for the promotion indicated. In this regard, in accordance with the request received, KRONOS will send the interested party information on the development of the property they are interested in. If the interested party does not wish to continue receiving information about this promotion, they may request the cancellation of communications at any time by sending an e-mail to the following address: protecciondedatos@kronosre.com. 

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 processing is described in section 5 of this document "Commercial information". 

Legality in the processing of personal data: KRONOS processes the information provided on the basis of:

• The processing necessary for the application at the request of the interested party requesting information on a property whose marketing and sale is by KRONOS. (art.6.1.b) of the General Data Protection Regulation).
• The express consent of the interested party through the boxes provided for this purpose in the information request form. (art.6.1.a) of the General Data Protection Regulation).

Categories of personal data: The personal data that KRONOS will process at the time of the information request are: first 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 request for information. 

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 this information, except in the case foreseen in point 5 on commercial information. See point 5. Commercial Information. 

 

2. Property selection 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 GDPR). In this regard: 

• KRONOS will inform the marketers designated in the said promotion in order to carry out the execution of the promotion.
• KRONOS may carry out the processing of data derived from the execution of this document or from any action derived from the guarantee deposit.

Also, from the moment the guarantee is sent, 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 interested party is informed that KRONOS may share this information with the other companies it manages in the real estate sector for the sole purpose of expediting and managing the obligations that apply to these companies in this area. You may consult the details of these companies at https://kronoshomes.com/sociedades.

On the other hand, only in the case that the interested party has expressly consented to the financing option of the property (art.6.1.a) of the General Data Protection Regulation) the data of the interested party may be communicated to the financial entity with which KRONOS maintains relations to facilitate the financing of the present promotion, with the purpose of contacting them for the study and management of the possible financial operation of 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 first name, surname, address, e-mail address, details of the property of interest, marketer assigned to your request for information, guarantee deposit, account information from financial institutions, documents signed as a deposit, expected time of completion of the contract of sale and identification documents required by KRONOS in compliance with the obligations of prevention of money laundering. In addition, KRONOS can obtain additional data, either in ordinary information files for the prevention of money laundering, as well as from official public registries. 

Data Retention: KRONOS will maintain your personal data for the duration of the property selection period or it can be extended in the event that the purchase is completed. In the event that the purchase of the property does not materialize, your data will be kept blocked for a period of ten years in order to comply with the obligations of conservation of the documentation derived from the regulations for the prevention of money laundering and financing of terrorism.

 

3. Purchase and Sale Formalization Phase:

KRONOS will process the buyers' data in order to manage and formalize the purchase and sale 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:

• Necessary management for the formalization of the purchase contract.
• Documentary/contractual, accounting, tax and administrative management.
• Management and, where appropriate, communication of data with public registries, insurance companies and notaries involved in the process.
• Pre and post-sale management. All activities that are carried out according to the needs that may arise from the provision of the housing.

Compliance with identification obligations derived from the applicable regulations (art.6.1.c) of the General Data Protection Regulation):

• Prevention of money laundering and terrorist financing. In this case, we inform you that KRONOS may share this information with the other companies that it manages and that have already been mentioned above for the sole purpose of streamlining and managing the obligations that fall on these companies in this area.
• Necessary communication of data with public bodies that may either require information or such communication of data deriving from their own regulations, such as tax regulations.

Only in the event that the data subject 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 financial transaction 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 first name and surname, address, e-mail address, details of the property you are interested in, the marketer 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. KRONOS may also obtain additional data, either from shared anti-money laundering information files or from official public registries. KRONOS may also process personal data of third parties provided by the buyer, such as: legal representatives, collaborators, guarantors, relatives or other persons of the surroundings in case of presenting personal and actual guarantees. 

With respect to the above-mentioned processing of third-party data, the purchaser confirms that such data are real and that the data 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 whole purchasing process. Once the period of one and a half years has elapsed (the period foreseen for possible post-sale procedures), your data will be kept blocked for a period of ten years in order to comply with the documentation retention obligations derived from the regulations for the prevention of money laundering and financing of terrorism. 

 

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 and the properties offered in order to learn from customer feedback, improve the information and quality of the processes and therefore the experience of all those interested 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 further information on this weighting test, you may request it at: protecciondedatos@kronosre.com. 

 

5. Commercial information:

In the information request forms, KRONOS will enable a mechanism for those who are interested to expressly consent to the following processing (art.6.1.a) of the General Data Protection Regulation):

• A specific consent so that KRONOS, either through calls from its managers or through e-mail, may send commercial information about events or other promotions marketed by KRONOS or other products in the real estate sector to which KRONOS is a party. For the preparation of such communications, KRONOS will personalize them based on profiles based on the preferences of promotions that have been expressed, or, in the case that they are customers, based on the personal data that KRONOS has regarding their preferences and history of operations.
• Another specific consent allows KRONOS to send the contact details of the interested parties to other companies managed by KRONOS so that they can send them commercial information about their products in the real estate sector.

Only if the data subject has consented to such processing, shall KRONOS process such information in any of its phases in order to keep you informed of other promotions or so that other companies may have access to your data in order to send you related information. The interested party may always revoke the consent given. In the rest of the documentation associated with the sale of the property, KRONOS includes mechanisms for revoking consent, but, in any case, you can always revoke such consent by sending a written communication, together with a copy of your ID card, to the following address: Calle Serrano 3, 28001 Madrid or by email to: protecciondedatos@kronosre.com. 

 

6. Web data processing:

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:

• Privacy Policy: https://kronoshomes.com/privacidad
• Cookies Policy: https://kronoshomes.com/cookies

If the interested party wishes to know about the processing of personal data carried out by KRONOS through https://www.kronosig.com, they may refer to the following informative texts: 

• Privacy Policy: https://www.kronosig.com/es/
• Cookies Policy:  https://www.kronosig.com/es                                                           

To whom are your personal data communicated? 

• Only if the interested party has given its express consent, through the mechanism provided for this purpose, KRONOS may send contact information to the other companies managed by KRONOS so that they can send the interested party marketing information.
• According to the time phase of the relationship with the interested party:
• During the information request phase, KRONOS will not communicate your data to any third party, other than KRONOS suppliers, as stated in the last paragraph of this section.
• During the property selection phase, KRONOS may communicate the data of the interested party to:
• Kronos Group companies for purposes related to the prevention of money laundering and terrorist financing.
• In the event that the interested party is interested in financing the property, their data may be communicated to financial institutions.
• At the purchase and sale stage:
• Financial entity for the management of the financing and possible subrogation of real rights.
• Underwriters of the contract.
• Public agencies and institutions of the General State Administration, Autonomous and Local Administrations.
• Law enforcement agencies in case KRONOS is required to provide certain information.
• Courts and Tribunals in the event of any proceeding or dispute arising from the purchase agreement.
• Entities that participate in the process of preparing the property, either supply or assembly companies, both in a phase prior to the delivery of the property, or in a later phase in case any repairs, modifications or additional materials are necessary.
• Finally, KRONOS has third party service providers that may have access to personal data of data subjects in the course of providing their services, such as suppliers, materials, maintenance, control and surveillance of works, architects, site technicians, auditors, experts, lawyers, managers, IT maintenance, financing services, potential investors, administrative services and destruction of documentation, among others. KRONOS pre-selects these suppliers on the basis of data protection compliance criteria, has data protection contracts with all of them, and monitors their compliance with their data protection obligations.

 

International Data Transfer

The data subject is informed that KRONOS does not carry out international transfers of their data.

Possible claims or exercise of data protection rights

The interested party may exercise the rights of access, rectification, deletion, limitation, opposition, portability with respect to their personal data, as well as the right to withdraw the consent given, requesting it in writing by e-mail at  protecciondedatos@kronosre.com or letter addressed to the registered office of KRONOS indicated above, enclosing a copy of their ID card. You can also file any type of data protection claim at the above address or you can go to the Spanish Data Protection Agency, the supervisory authority for data protection, http://www.agpd.es.