Privacy Policy

ACCUMIN HOME, S.L.U. is committed to maintaining a transparent relationship with its customers by informing them about how we collect and securely process any data they provide when using our services.

For this purpose we have prepared this Privacy Policy (hereinafter the "Policy") that will allow our customers and / or service users to consult the information they need or clear any doubts they may have about the treatment we make of personal data.

This "Policy" applies to all the environments through which we interact with our customers and request personal data from them, in particular websites, e-mail or postal mail and telephone.

Consequently, this “Policy” does not apply to third-party websites, including those that can be accessed via a web link from our sites.

1. Data Controller

ACCUMIN HOME, S.L.U. (hereinafter “ACCUMIN HOME”), with Tax ID No. B86689494 and registered office at Calle José Echegaray No. 9, Las Rozas de Madrid, 28232 Madrid, is the Data Controller for this User Registry and will use your information to manage registration and access to the services offered through the corporate website.

2. To whom does this Policy apply with respect to personal data?

This privacy policy, in accordance with the regulations on the protection of personal data, describes the processing, management and purpose for which personal data are processed:

1. Individuals who contact ACCUMIN HOME to request a quote and/or to sign up for a service.
2. Individuals who register as users of the corporate website www.tinsa.es to sign up for a service offered on the website or to request commercial communications.
3. Third parties whose personal data has been provided by our clients or obtained by ACCUMIN HOME on behalf of our clients, for the proper provision of the requested services.

3. From which sources do we collect personal data?

3.1. Directly from our customers or service users

ACCUMIN HOME will collect personal data provided directly by our users/customers through the following sources:

a) Through the website:

We collect the personal data you provide when you register, as well as information derived from your access to and use of the services we offer on this website and from your browsing activity, such as (i) the data provided during registration; (ii) the data provided while using the services; (iii) the data derived from your communications with us; (iv) data derived from your browsing activity, such as cookies (information about user preferences when visiting a website), links, and system information—for which you can find more details in our website’s Cookie Policy; (v) any other data that you authorize us to process.

b) By email, by phone, or in person:

We collect data provided by customers through our sales or customer service channels and/or through external partners authorized to collect data from our customers in their capacity as data processors.

3.2. Through other sources

In specific cases, we may collect personal data from other sources, such as property and/or commercial registries, municipal and regional government registries, compensation boards, etc., when applicable regulations require us to conduct verifications or provide data contained in these registries.

4. What personal data do we collect?

4.1. Customer and User Data

We collect those data necessary for the management of the requested service, in particular:

1. Identifying information: First and last name, Tax ID number, Address, phone number, email address.
2. Economic, financial, and insurance data, particularly regarding the properties to be covered in the report.
3. Business information, particularly that related to the operation of the Property or the business that is the subject of this report.
4. Transaction data for goods and services.

4.2. Third-Party Data

In some cases, in order to provide our services, our clients may need to provide us with personal data regarding third parties, such as a contact person for managing the visit, the owner of the Property, information on tenants and other holders of real property rights, etc. The data collected will be processed solely for the purpose of including it in the reports at Appraisal or other services we provide.

Data pertaining to third parties will be included in the ACCUMIN HOME databases only when necessary for the proper provision of the contracted services, and in particular, when necessary to verify the ownership and occupancy status of the properties, the existence of encumbrances on the Property that could affect their value, as well as to manage access to and visits to the properties.

5. Purpose and Legal Basis

5.1. Request Management and Service Delivery

In general terms, the purpose of the data processing will be to manage requests submitted through the website, whether via a contact form or any other type of online form, or via an email request. Such a request may include, but is not limited to, processing a request, responding to a request for commercial information, processing a request for a quote, requesting duplicate invoices, checking the status of a work in progress, requesting a real estate mercado study, requesting an energy efficiency certificate, requesting nota simple, filing an appeal against capital gains tax, reviewing previously prepared reports, occasionally, once the contracted service has been completed, you will be sent a survey to gauge your grado satisfaction with the service provided, job applications, responses to user inquiries and requests, as well as any other interaction between the website user and ACCUMIN HOME that is intended to meet the user’s needs. All requested data is necessary to process the request.

ACCUMIN HOME will process the personal data provided by its customers and users primarily to manage the preparation of quotes and/or the provision of the contracted service. The legal basis for this processing is the performance of the contractual relationship and the implementation of pre-contractual measures.

If you have made a phone call for reasons related to security, integrity, and service quality, the call will be recorded and the data will be retained by ACCUMIN HOME. The legal basis is ACCUMIN HOME’s legitimate interest in ensuring and verifying the accuracy and integrity of the information provided through this medium, as well as in ensuring service quality. Since the receipt, transmission, and execution of customer orders placed over the phone require the retention of such recordings to ensure the integrity of the information associated with a specific date, thereby preventing errors and misunderstandings that could harm the parties involved. Furthermore, the legitimate interest is based on the need to provide evidence of a conversation in legal proceedings, as evidence in court, in the event of a dispute between the parties. Personal data of third parties provided by our customers or collected by ACCUMIN HOME on their behalf will be processed solely and exclusively for the proper performance of the contracted services and will be processed on the legal basis of the legitimate interest of the data controller.

In addition, some interactions during calls may be analyzed using technological tools to improve our customer service, in accordance with European regulations on artificial intelligence.

Any customer who has provided third-party data or on whose behalf such data has been obtained assumes the responsibility to inform those individuals (third parties), if legally required, of the processing that ACCUMIN HOME will carry out on their personal data and of the rights to which they are entitled as described in this “Policy.”

5.2. Promotional Information for Customers

If you have contracted a service with our company and are therefore our customer, we may use your data to send you promotional information via email regarding services similar to the one you have contracted. The processing will be carried out in compliance with the provisions of Law 34/2002, of July 11, on Information Society Services and Electronic Commerce. The sending of information about the company’s activities is based on the legitimate interest of ACCUMIN HOME, the data controller. The customer may object to this type of data processing at any time, and under no circumstances will the exercise of this right affect the continuation or termination of the contractual relationship between the customer and the company.

5.3. Commercial Communications with Your Consent

If you have expressly consented to receiving commercial and advertising communications (promoting our products, sending you reports and studies prepared by our companies, inviting you to participate in real estate conferences and events, presenting reports, participating in sweepstakes organized by our organization, etc.), by checking the corresponding boxes, we will process your data for this purpose by creating a commercial profile based on the information provided and through automated processing; under no circumstances will the withdrawal of this consent affect the performance of the contract or the provision of any services you may have contracted. The legal basis for the processing will be your express consent, which you may, however, revoke at any time.

5.4. Registered users on the website

If you have registered as a user of the website, we will process your data to create and manage your user account on the website, provide you with the online services you request, and compile statistics on the usability of our online services. The applicable legal basis in this case is the express consent you provide for your registration as a user of the website and the performance of a contract, should you contract any of our services.

6. How long do we retain your data?

6.1. Customers to whom we have provided a service

If you are our client and we have provided you with a service, we hereby inform you that the data you have provided will be retained for the purpose of managing the services and for the period necessary to (i) verify, prior to accepting an assignment, whether a report has previously been issued regarding the same matter, thereby avoiding any potential conflicts of interest related to the service previously provided to you, (ii) to comply with the legal obligations to which we are subject, (iii) and to respond to any inquiries or complaints that you or a third party may submit to us.

Given that many of our reports are used as a reference for establishing business relationships with third parties and that, furthermore, these relationships may extend over a long period of time (for example, when an appraisal is conducted to determine the auction value in the event of a foreclosure), we hereby inform you that we will retain the data for a minimum period of 25 years, a period we consider necessary to ensure that both our clients and authorized third parties can access the data for as long as the active transactions based on it remain in effect.

6.2. Rejected Job Offers

In the event that you ultimately do not accept our job offer, please be advised that we will retain your data for a period of 24 months in order to verify any special circumstances involving conflicts of interest, as well as to use your data for future job offers or for any other purposes and processing activities to which you have consented.

6.3. Registered users on the website

If you are registered as a user of our website www.tinsa.es, owned by ACCUMIN HOME, we will retain your personal data for the purpose of facilitating new sign-ups for our services. However, if we detect that you have not used or interacted with your account or any of our online services for a period of two years, we will proceed to cancel your user account by blocking your data.

6.4. Commercial Communications

If you have expressly consented to receive marketing information, we will retain your data for this purpose until you unsubscribe from the service.

6.5. Deletion of Your Data

In any case, we would like to remind you that you have the right to have your personal data deleted at any time.

7. Who We Share Your Data With

ACCUMIN HOME may share your data in cases where it is necessary for the strict and exclusive fulfillment of the aforementioned purposes, or for any other purpose necessary for the proper conduct of our relationship with you, or where such sharing is justified by ACCUMIN HOME’s legitimate interests, as well as in cases provided for by law. In particular, we may disclose your personal data without your consent in the following cases:

1. With the courts and tribunals, state law enforcement agencies, and other administrative authorities—in particular the Spanish Tax Agency ( Banco de España), the National Securities Market Commission (CNMV), the Public Treasury, or any other authority—when we believe that such authorities may legally request such information from us.
2. With third-party data processors engaged by Tinsa who perform functions on our behalf (including appraisers, external consultants and professional advisors, accountants, auditors, IT providers who develop our technology systems or ensure their security, and other data processors) when the proper provision of the service requires access to our Clients’ personal data; in all such cases, and to ensure the security of their data, ACCUMIN HOME will enter into the corresponding contract governing the obligations of each of these data processors.
3. We may also share your information with companies within our group for internal administrative fines .

8. International Data Transfer

ACCUMIN HOME is part of a multinational group; therefore, in order to fulfill the purposes set forth in this “Policy,” as well as for internal fines , your personal data may be accessed by our employees, agents, or contractors from any of the companies within the GROUP.

However, in the event that we transfer Personal Data to countries or territories that do not offer a level of protection comparable to that of the EU, we will implement the necessary technical and legal measures to ensure the security and legitimacy of the international transfer, as well as the adequate confidentiality and privacy of the transferred data. In this regard, we inform you that ACCUMIN HOME uses the services of third-party providers that involve international transfers to the United States, a country that guarantees a level of protection equivalent to that of the European la Unión for personal data transferred from Europe to third-party providers in the United States that adhere to the Data Privacy Framework (https://www.dataprivacyframework.gov/s/), among which these providers are included.

Having clarified the above, if you wish, you may request additional information regarding the specific safeguards and guarantees applied by ACCUMIN HOME to the transfer of your Personal Data to countries without an equivalent level of protection, as well as the specific locations of the companies that may have access to your personal data in accordance with the aforementioned purposes, by contacting us at the following address : gdpr@accumin.com.

9. Security Measures

We are committed to processing your data in accordance with applicable regulations and, in particular, to (i) processing the data to which we have access with sufficient safeguards to ensure confidentiality; and (ii) implementing the necessary technical and organizational security measures to prevent the alteration, loss, or unauthorized processing of or access to your data.

All your data is stored on secure servers (or secure physical copies) owned by us or our subcontractors or business partners, and our security criteria and policies (or equivalent policies of our subcontractors or business partners) apply to access and use of your data.

Although it is not possible to guarantee absolute protection against unauthorized access when transmitting data over the internet or from a website, we, along with our subcontractors and business partners, make every effort to maintain the necessary physical, electronic, and procedural safeguards to ensure the protection of your information in accordance with applicable data protection requirements.

10. Your Rights

Finally, we inform you that you have the following rights:

1. Access: You may ask us to provide you with more details about how we process your personal data and request a copy of the personal information we have about you.
2. Correction: You may ask us to correct any inaccuracies in the personal information we have about you.
3. Deletion: You may ask us to delete your personal data when we no longer have a legal basis for using it and the relationship between us has ended.
4. Restriction of Processing: You may restrict the processing of your data by ACCUMIN HOME for one or more specific purposes.
5. Right to Object: You may object to the company’s processing of your data for a specific purpose, provided that such processing is not necessary for the fulfillment, execution, and monitoring of your relationship.
6. Data portability: You may ask us to transfer the personal information you have provided to us to a third party.

You may exercise your rights of access, rectification, erasure, restriction of processing, objection, and data portability with the company identified as the data controller at the time your data was collected, as follows:

ACCUMIN HOME, S.L.U., with Tax ID No. B86689494 and registered office at Calle José Echegaray No. 9, Las Rozas de Madrid, 28232 Madrid.

By sending an email to gdpr@accumin.com or by mail to the address provided, addressed to our Legal Department, along with a copy of your identification document and specifying the rights you wish to exercise.

Ultimately, you may request information about your rights and file a complaint with the Spanish Data Protection Agency, located at Calle Jorge Juan, No. 6, 28001 Madrid.