Data Protection Policy

TINSA TASACIONES INMOBILIARIAS, S.A.U. (hereinafter Tinsa Tasaciones) wishes to maintain a transparent relationship with its clients, informing them of how we collect and securely treat any data they provide us with in the use of 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.

Accordingly, this "Policy" does not apply to third party websites, including those that may be accessed through a web link from our environments.

1. Data Controller

TINSA TASACIONES INMOBILIARIAS, S.A.U. NIF 78029774 and registered office at calle José Echegaray nº 9 de las Rozas de Madrid. 28232 Madrid is the party responsible for the processing of this User Register and will use your information to control the registration and access to the services offered through the corporate website.

2. Whose personal data is covered by this Policy?

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:

a) Persons who contact TINSA TASACIONES to request a quotation and/or contract a service.

b) Persons who register as Users of the corporate website www.tinsa.es to contract a service offered on the WEBSITE or to request the receipt of commercial communications.

c) Third parties whose personal data have been provided by our clients or have been obtained by TINSA TASACIONES on behalf of our clients, for the correct rendering of the requested services.

3. From what sources we collect personal data

3.1. Directly from our Customers or service users

The "Companies" will collect personal data provided directly by our users/customers, through the following sources:

a) Through the Web Page: we collect the personal data that you provide us with your registration, as well as the information derived from the access and use of the services that we offer you in this Web, and from your own navigation, such as (i) the data provided when you register; (ii) the data provided in the use of the services; (iii) the data derived from the communications that you maintain with us; (iv) data derived from your browsing, such as cookies (information about user preferences when visiting a website), links and system information, and about which you can obtain more details in the Cookies Policy of our website; (v) any other data that you authorize us to process.

b) By e-mail, by telephone or in person: we collect the data provided by customers through our commercial or customer services and/or through external collaborators authorized to collect data from our customers as data processors, in particular our appraisers and energy certifiers,
. The data may also be collected through third parties who have been appointed by the Customers to act as their agents in the relations with our "Companies" (in particular Financial Institutions).

3.2. Through other sources

Occasionally, we may collect personal data from other sources, such as property and/or mercantile registries, city council and autonomous community registries, compensation boards, etc., when the applicable regulations require the performance of verifications or the provision of data included in these registries.

4. What personal data we collect

4.1 Customer and User Data

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

a) Identification data: Name and surname, NIF/CIF, address, telephone, e-mail.

b) Economic, financial and insurance data, in particular related to the properties to be reported on

c) Commercial information data, especially those related to the operation of the real estate or business being reported.

d) Data on transactions of goods and services.

4.2 Third Party Data

Eventually, for the performance of our services, it may be necessary that our clients provide us with personal data of third parties, such as contact person for the management of the visit, owner of the property, data of tenants and other holders of real rights, etc... The data collected will only be processed for the purpose of incorporation in the appraisal reports or other services provided.

The incorporation to Tinsa's databases of data corresponding to third parties will only proceed when necessary for the correct rendering of the contracted services, and especially those necessary for the verification of the ownership and occupancy situation of the properties, existence of charges that encumber the property and could affect its value, as well as to manage the access and visit to the properties.

5. Purpose and Legitimation.

5.1 In general terms, the purpose of the processing will be to manage the request made through the website, either through the contact form or any other type of on-line form, or through a request by e-mail.

Such a request may be, but is not limited to, the management of a request, the reply to a request for commercial information, the management of a request for an estimate, the request for duplicate invoices, the status of a work in progress, the request for an online appraisal, the request for a real estate market study, the request for an energy efficiency certificate, the request for a simple note, the request to contest capital gains, the review of reports already completed, the request for employment or, if applicable, the registration in TINSA TASACIONES newsletters, request for a simple note, request for a challenge of capital gains, review of reports already completed, application for employment or, as the case may be, registration in TINSA TASACIONES newsletters, attention to user queries and requests, as well as any other interaction between the web user and TINSA TASACIONES that tends to satisfy the user's need. All the requested data are necessary to be able to attend the request.

TINSA TASACIONES will process the personal data provided by its customers and users mainly to manage the preparation of estimates and/or the provision of the contracted service. The legitimacy is based on the execution of the contractual relationship and the application of pre-contractual measures.

If you have made a telephone call for security, integrity and quality of service reasons, the call will be recorded and the data will be kept by TINSA TASACIONES. The legitimate basis is the legitimate interest of Tinsa to guarantee and have proof of the truthfulness and integrity of the information provided by this means, as well as to guarantee the quality of the service.

Due to the fact that the reception, transmission and execution of customer orders that are made over the telephone entails the need to keep such recordings to guarantee the integrity of the information linked to a specific date, avoiding errors and misunderstandings that could be detrimental to the parties.

Likewise, the legitimate interest is based on the need to prove a conversation in a legal proceeding, as a means of proof before a trial, in the case of litigation between the parties. The personal data of third parties provided by our clients or collected by TINSA TASACIONES 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.

The client who has provided the data of third parties or on whose behalf they have been obtained, assumes the duty to inform, if legally required, such persons (third parties) of the processing that TINSA TASACIONES will carry out on their personal data and of their rights as described in the present "Policy".

5.2. If you have contracted a service with our company and therefore were our client, we may use your data in order to send you by email promotional information from the company in relation to similar services to the one you had contracted. The treatment will be carried out in compliance with the provisions of Law 34/2002, of July 11, 2002, of services of the information society and electronic commerce. The sending of information on the activity of the company finds its legitimacy in the legitimate interest of the "Companies", responsible for the treatment, the customer may at any time express their opposition to this type of treatment without in any case the exercise of this right conditions the maintenance or termination of the contractual relationship that binds you to the company.

5.3 If you had expressly accepted the reception of commercial and advertising communications (promoting our products, sending reports and studies prepared by our companies, inviting you to participate in real estate conferences and meetings, presentation of reports, participation in sweepstakes organized by our entity ...), through the marking of the corresponding boxes, we will treat your data with this purpose, by means of the elaboration of a commercial profile based on the information provided and by means of automated treatments, without in any case the withdrawal of this consent conditions the execution of the contract or the provision of the services that you could have contracted. The legitimacy of the treatment will be made on the basis of your express consent, however you may revoke it at any time.

5.4 If you have registered as a user of the website, we will process your data to create and manage your user account of the website, facilitate the provision of online services you request, and perform statistics on the usability of our online services. The applicable legal basis in this case is the express consent you give for the management of your registration as a user of the web and the execution of a contract, in case you hire any of our services.

6. How long we keep your data

6.1 If you are our client and we have provided you with a service, we inform you that the data provided will be kept for the management of the services and for the period of time necessary to (i) verify prior to accepting an assignment whether a report has been previously issued on the same subject and thus avoid possible situations of conflicts of interest that are related to the service that would have been provided, (ii) for compliance with the legal obligations to which we are subject, (iii) as well as to respond to queries or complaints that you or a third party may make to us.

In attention to the fact that many of our reports are adopted as reference for the establishment of business relationships with third parties and that additionally these relationships may have a long term validity in time (for example when they are valued to establish the auction value in a foreclosure), we inform you that we will keep the data for a minimum period of 25 years, period that we understand necessary to ensure that both our clients and third parties can access them during the period in which the active operations carried out based on them are in force. Likewise, and in view of the fact that the professional liability of our "Companies" is subject to long claim periods, the maintenance of the data is necessary to guarantee the defense of our interests until the expiration of the statute of limitations period of the actions that could be derived from the services.

6.2 In the event that our contracting proposal is not finally accepted by you, we inform you that we will keep your data for a period of 24 months for the purpose of verifying special situations of conflict of interest, as well as to have your data available for future offers or for the fulfillment of any other purposes and processing that you have consented to.

6.3. If you were registered as a user of our website www.tinsa.es owned by Tinsa Tasaciones Inmobiliarias, S.A.U. we will keep your personal data for the purpose of facilitating new hires of our services. However, if we detect that during a period of two years you have not used or interacted in your account or with any of our online services, we will proceed to the cancellation of your user account by blocking your data.

6.5. If you have expressly consented to receive commercial information, we will keep your data for this purpose until such time as you unsubscribe from the service.

6.6 In any case, we remind you that you have the right to cancel your personal data at any time.

7. With whom we share your information.

TINSA TASACIONES may share the data in the cases necessary for the strict and exclusive fulfillment or satisfaction of the aforementioned purposes, or for any other purpose necessary for the correct development of the relationship with you or cause that is justified in the legitimate interest of TINSA TASACIONES, as well as in the cases legally foreseen. In particular, we may give access to or communicate your personal data without the consent of the owner, in the following cases:

a) With the Courts and Tribunals, State Security Forces and Corps and with other Administrative Authorities, especially the Bank of Spain, CNMV, Public Treasury, or any other authority, when we understand that we may be legally required to do so.

b) With third party processors of Tinsa that perform functions on our behalf (including appraisers, external consultants and professional advisors, accountants, auditors, IT providers that develop our technological systems or guarantee their security and other processors) when the correct provision of the service requires access to the personal data of our Clients, with whom in any case and to guarantee the security of their data, the "Companies" will sign the corresponding contract regulating the obligations of each of said processors.

c) We may also share your data with group companies for internal administrative purposes.

d) If you so consent, we may share your personal data (name, email and telephone number) with Tinsa Digital S.L.U. for the purpose of communicating it to trusted real estate agents or mortgage brokers to help you find the mortgage that best suits your needs free of charge.

8. International Data Transfer

The "Companies" belong to a multinational group, so in order to comply with the purposes set forth in this "Policy", as well as for internal administrative purposes, there is the possibility of access to your personal data from any of the companies of the GROUP, by our employees, agents or contractors".

You can access the updated list of the companies that form a group with the "Companies" in the following link.

These companies are located in different countries, some of which are outside the European Economic Area (EEA),

(EEA), as in the case of a processing order provided by one of the companies of the group, located in Mexico, which could process your data in case you contact in a timetable outside the established in Spain, in order to provide you with a service on a continuous basis, in the position of data processor of the organization. The legal basis is the signature of the standard contractual clauses approved by the European Commission.

However, in the event that we transfer Personal Data to countries or territories that do not offer a level of protection equivalent to that of the EU, we will establish the necessary technical and legal measures to guarantee the security and legitimacy of the international transfer, as well as the adequate confidentiality and secrecy of the transferred data. In this regard, we inform you that TINSA TASACIONES uses the services of third party providers that involve international transfer to the United States, a country that guarantees a level of protection equivalent to that of the European Union for personal data transferred from Europe to third party providers in the United States that are adhered to the Data Privacy Framework, among which these providers are included.

Having clarified the above, if you wish, you may request additional information on the specific protection measures and guarantees applied by TINSA TASACIONES to the export of your Personal Data to countries without a comparable level of protection, as well as on the specific
locations of the companies that may have access to your personal data in compliance with the aforementioned purposes, by contacting us at the following address protecciondedatos@tinsa.com.

9. Security measures

We undertake to treat your data in accordance with the provisions of the applicable regulations and, in particular (i) to treat those data to which we have access, with sufficient guarantees of confidentiality; and (ii) to adopt those technical security measures
and organizational measures necessary to prevent alteration, loss and unauthorized access or processing of 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 intrusion when transmitting data over the Internet or from a website, we and our subcontractors and business partners make every effort to maintain the necessary physical, electronic and procedural safeguards to ensure that your information is protected in accordance with the applicable data protection requirements.

10. Your rights

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

(A) Access: You can ask us to provide you with more details about how we process your personal data and request a copy of the personal information we hold about you.

(B) Rectification: You may ask us to change any inaccuracies in the personal data we hold about you.

(C) Deletion: You can ask us to delete your personal data when we no longer have legal grounds to use it and the relationship between you and us has expired.

(D) Limitation of processing: you may restrict the processing of your data by TINSA for one or more specific purposes.

(E) Opposition: you can oppose the processing of your data by the company for a specific purpose, provided that such processing is not necessary for the performance, development and control of your relationship with us.

(F) Data Portability: You may ask us to transfer personal information you have provided to us to a third party.

You can exercise your rights of access, rectification, deletion, limitation in the treatment, opposition and portability of data before the company that has been identified as responsible for the data at the time of registration of the same, in the following way:

TINSA TASACIONES INMOBILIARIAS, S.A.U. NIF 78029774 and registered office at calle José Echegaray nº 9, Las Rozas de Madrid. 28232 Madrid.

By sending an e-mail to the address protecciondedatos@tinsa.com or by letter to the address indicated above addressed to our Legal Department together with proof of identity and stating the rights you specifically wish to exercise.

As a last resort, you may request information about your rights and file a complaint with the Spanish Data Protection Authority, located at Calle Jorge Juan, nº 6, 28001 Madrid.

LIST OF COMPANIES THAT FORM A BUSINESS GROUP WITH TINSA TASACIONES INMOBILIARIAS S.A.U. AND TINSA DIGITAL S.L.U.

(a) Asertia Real Estate, S.L.U.
(b) Tinsa Internacional de Inversiones, S.L.U.
(c) Tinsa Digital S.L.U.
(d) DEYDE, Calidad de Datos, S.L.U.