We welcome you to GRUPO TOP GESTIÓN, inviting you to read this Privacy Policy in order to inform you of the procedures for processing your personal data and your rights.

GRUPO TOP GESTIÓN attaches great importance to respect for privacy and takes all necessary measures to ensure the confidentiality and security of Users’ personal data.

ADDITIONAL INFORMATION ON DATA PROTECTION (RGPD|LOPD-gdd)

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

1. Joint controllers of the processing:

1.1. Who are the entities jointly responsible for the processing?

HICKMAN INVEST, S.L. (CIF: B87684817)
HORMIGONES DE VALDEBRIZ, S.L. (CIF: B19187186)
INVERSIONES EL AVENTINO, S.L. (CIF: B88000955)
SAIZA OBRAS Y PROYECTOS, S.L. (CIF: B86831021)
TAZ INVERSIÓN Y GESTIÓN, S.L. (CIF: B87385514)
TOP GESTION MADRID, S.L. (CIF: B86831476)
TOP GESTION RIVAS, S.L. (CIF: B88106349)
TJ AGRICULTURA, S.L. (CIF: B16166274)
ALARSAIZ INVESTMENT, S.L. (CIF: B87272340)
INVERSIONES EL VIMINAL, S.L. (CIF: B88196811)
DULCINEA 2015 REAL ESTATE, S.L. (CIF: B16103889)
TAZ REAL ESTATE, S.L. (CIF: B87385506)
RETURN SOLUTIONS, S.L. (CIF: B88213525)
URBEDESA, S.L. (CIF: B53701710)
ALMELOPO REAL ESTATE, S.L. (CIF: B88568332)
JITESA INVEST, S.L. (CIF: B88601844)
MAHELO INVERSIONES, S.L. (CIF: B88601869)
MALVAMAR ASSET, S.L. (CIF: B88441100)
MEPOMAR INVERSIONES, S.L. (CIF: B88568340)
DOÑA ANA ISABEL ALARCÓN SAIZ (CIF: 47.071.884-S)
AGRICULTURA LA MAZA S.COOP. CLM (CIF: F16345217)
INVERSIONES SAIZ ALARCÓN, S.L. (CIF: B86324076)
DOÑA JUANA SAIZ ALARCÓN (CIF: 70.504.113-M)
DOÑA MARIA EMILIA ALARCÓN SAIZ (CIF: 47.082.586-E)
SALANGO SOLUTIONS, S.L. (CIF: B88441118)
EXTREME SILVER, S.L. (CIF: B88229497)
RILO REAL ESTATE, S.L.U. (CIF: B01729375)
DRUAL ASSET, S.L.U. (CIF: B01729300)
JOALMA REAL ESTATE, S.L. (CIF: B01729367)
STARDWOOD HOMES, S.L. (CIF: B88337969)
INVERSIONES QUINDA, S.L.U. (CIF: B16851180)
MELMARIS REAL ESTATE, S.L.U. (CIF: B88601828)
NEXPRI INVERSIONES, S.L.U. (CIF: B67633651)
MARLU ASSET, S.L.U. (CIF: B67633644)GUMA ASSET, S.L.U. (CIF: B67633578)
ISLO REAL ESTATE, S.L. (CIF: B09746041)
MARAN ASSET, S.L.U. (CIF: B09749318)
RUBRAL REAL ESTATE, S.L.U. (CIF: B09748930)
MAVILASA INVERSIONES, S.L. (CIF: B72395577)
CALA OLIVERA GOLF PROJECT 2023, S.L. (CIF: B72395775)
ALKA PROJECT 2023, S.L. (CIF: B72395767)
LAS BRISAS PROJECT 2023, S.L.U. (CIF: B72395759)

1.2. Joint trading name:

GRUPO TOP GESTIÓN

1.3. Common point of contact:

Company name: TOP GESTION MADRID, S.L. : B86831476
Address: C/ Velázquez, 25 2ºD 28001 Madrid
Contact: Tel. 912 90 44 94 – Email: topgestionmadrid@topgestionmadrid.com

1.4. Legal regulation of the situation of co-responsibility:

In order to comply with the provisions of current European Union Data Protection legislation (Art. 26 of the GDPR), an agreement has been drafted to enable and regulate globally and for all the companies of the TOP GESTIÓN GROUP the regime of joint responsibility for the processing of personal data between the different companies that make up the TOP GESTIÓN GROUP.

All newly created entities forming part of the TOP GESTIÓN GROUP have progressively adhered to this Agreement by completing the Adhesion Document incorporated as Annex Two to the Agreement itself.

In compliance with the applicable regulations and upon request by the interested party at the e-mail address topgestionmadrid@topgestionmadrid.com the Agreement may be made available to them.

1.5. Origin and communication of intra-group data:

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

GRUPO TOP GESTIÓN guarantees the User that it will implement the appropriate technical and organisational security measures for the processing of such data, in order to ensure 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 co-responsible for the treatment; for the purposes of joint or/and individualized treatment, as appropriate.

2. Purpose of processing and legitimacy

2.1. For what purpose will we process your data?

GRUPO TOP GESTIÓN processes the data collected through the various forms on its web pages for the following purposes:

– Management, study and resolution of queries relating to: the information included on the website and/or our services; data processing, legal texts, claims, as well as any other issues.

– Management and processing of user registration.

– Management and processing of the subscription list of GRUPO TOP GESTIÓN and sending the newsletter, promotions and offers.

– Preparation of quotations, upon request by the interested party.

– Management of reservations, at the request of the interested party.

– Management, study and resolution of communications relating to: alleged breaches of regulations, alleged violations of the Code of Ethics, alleged negligent acts or omissions; communication to the competent authorities and/or courts, where appropriate.

The data provided will be located on the servers managed by the hosting service provider of the website where the user has entered the data in question, which will be considered as the data processor. All servers of the different hosting providers of GRUPO TOP GESTIÓN are located in 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.

GRUPO TOP GESTIÓN usually locates its web pages in 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 very complex to expose exhaustively the relationship of: website – hosting service provider. If the data subject wishes to know in particular which hosting provider has or has had access to his personal data, he can contact our team at the following e-mail address: topgestionmadrid@topgestionmadrid.com.

The interested party shall be solely responsible for the completion of the forms with false, inaccurate, incomplete or outdated data, exonerating GRUPO TOP GESTIÓN of any responsibility in this regard. Users guarantee and respond, in any case, the accuracy, validity and authenticity of the personal data provided and undertake to keep them updated.

2.2. What is the legal basis for the processing of your data?

The legal basis for processing your data is consent.

The processing of your data is based on your express consent, which you give when you provide the data requested through the forms on the website and tick the box accepting this privacy policy.

2.3. Will it be necessary for you to provide us with all your data? What will happen if you do not provide them?

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

2.4. Will we make automated individualised decisions and/or profiling, which produce legal effects or significantly affect you in a similar way?

No.

2.5. How long will we process your data?

The personal data provided will be retained for as long as the User does not request its deletion.

3. RECIPIENTS OF TRANSFERS:

3.1. Will we transfer your data to other companies?

GRUPO TOP GESTIÓN will transfer your data to a group of real estate marketers, in order to contact those Users interested in purchasing a property.

GRUPO TOP GESTIÓN, diligently and prior to collaborating with each marketing company, has signed the appropriate contract that regulates the relationship between the two, in order to provide additional guarantees to the treatment due by the marketing company in question. These guarantees or guidelines to be followed in the processing of personal data, in conjunction with the pre-existing and diligently implemented in each marketer, presuppose sufficient protection of the User’s rights.

However, GRUPO TOP GESTIÓN is not responsible for the processing that marketers such as ALMAR PROYECT MANAGER, S.L., among others, may carry out with the data provided.

In the event that the interested party wishes to obtain further information in this regard and/or wishes to inform us of any apparently illegitimate/illegal processing of their personal data transferred to the marketing company in question, they may contact us at the e-mail address topgestionmadrid@topgestionmadrid.com , so that our team can provide them with further information and/or assess the possible breach of the contract signed with the marketing company and, where appropriate and at our sole discretion, we can adopt and implement the appropriate measures in defence of the rights and interests of the User affected.

The User is informed that, for the proper provision of services (see, web hosting, marketing, etc.), different service providers contracted by GRUPO TOP GESTIÓN (data processors) may have access to personal information necessary to perform their functions.

These services provided by third parties are necessary for the development of the activity of TOP MANAGEMENT GROUP and, at all times, the processing of data carried out by them will be governed by contract that binds the manager with respect to TOP MANAGEMENT GROUP. In no case will they use the information for other purposes and will treat it in accordance with the guidelines stipulated by TOP MANAGEMENT GROUP and the current legislation on data protection.

GRUPO TOP GESTIÓN, in its commitment to privacy and data protection of the User, will only choose service providers that offer sufficient guarantees to implement appropriate technical and organizational measures, so that the treatment is in accordance with applicable legislation on data protection and ensure the protection of the rights of the User.

4. RECIPIENTS OF INTERNATIONAL TRANSFERS:

4.1. Will your personal data be transferred to third countries or international organisations?

No, as a general rule.

5. RIGHTS OF THE DATA SUBJECT:

5.1. What rights do you have in relation to the processing of your data?

Any interested party has the right to obtain confirmation as to whether or not GRUPO TOP GESTIÓN is processing personal data concerning them.

Also, as provided for in the RGPD (arts. 15-22) and the LOPD-gdd (arts. 12-18), we inform you that you have the following rights:

– Access to your data: You have the right to access your data to find out what personal data we are processing concerning you.

– Request rectification or deletion of your data: In certain circumstances, you have the right to rectify any inaccurate personal data concerning you that is processed by us or even to ask us to delete it when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

– Request the restriction of the processing of your data: In certain circumstances, you have the right to ask us to limit the processing of your data, in which case we inform you that we will only keep them for the exercise or defence of claims as provided for in the RGPD and the LOPD-gdd.

– To the portability of your data: In certain circumstances, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit it to another data controller.

– Object to the processing of your data: In certain circumstances and for reasons relating to your particular situation, you have the right to object to the processing of your data in which case, we will stop processing it except for compelling legitimate reasons, or the exercise or defence of possible claims.

– Ask not to be subject to automated individual decisions, including profiling.

– File a data protection complaint with the supervisory authority (Spanish Data Protection Agency).

5.2. When will we respond to your request?

We will respond to your requests as soon as possible and, in any case, within one month of receiving your request. This period may be extended by a further two months if necessary, taking into account the complexity and number of requests. The person responsible shall inform the person concerned of the extension within one month of the request.

5.3. Do you have the right to withdraw your consent?

The data subject has the right to withdraw consent at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

5.4. Where should you go to exercise your rights?

To exercise the recognised rights, the interested party may contact TOP GESTION MADRID, S.L. by e-mail at: topgestionmadrid@topgestionmadrid.com or by writing to the following postal address: C/ Velázquez, 25 2ºD 28001 Madrid.

5.5. Do you have the right to complain?

Yes, especially when you have not obtained full satisfaction in the exercise of your rights, you have the right to lodge a complaint with the national supervisory authority. For this purpose, you should contact the Spanish Data Protection Agency, whose contact details are given below:

C/ Jorge Juan, 6 – 28001 Madrid | https://www.aepd.es | dpd@agpd.es
Tel. 901100099 – 912663517

 

6. ACCEPTANCE AND CONSENT

You, as User, declare that you have been informed of the conditions on the protection of personal data, accepting and consenting to the processing of such data by GRUPO TOP GESTIÓN, in the manner and for the purposes stated in this privacy policy.

7. MODIFICATION OF THE CONDITIONS OF THE PRIVACY POLICY

GRUPO TOP GESTIÓN expressly reserves the right to modify this privacy policy to adapt it to any new legislative, jurisprudential or other developments.

8. CONTACT

Should the User have any questions about our privacy policy, please contact topgestionmadrid@topgestionmadrid.com.

The privacy policy was last updated on 01 November 2022.