1. Contact Information

http://www.haya.es (here in after, the "Web"):

Social Name: HAYA REAL ESTATE S.A.U.

C.I.F: A86744349

Registered Office: Vía de los Poblados, 3. Cristalia Building 9 - 28033 Madrid

Phone: 901 11 77 88

Registered in the Mercantile Registry of Madrid in Volume 31.153, Section 8 of the Companies Book, Folio 10, Sheet number M-560.663.

2. Who is responsible for the processing of your personal data?

Your personal data will be processed by the company "Haya Real Estate, SLU" (hereinafter, "HAYA"), with NIF B86744349 and registered office at Vía de los Poblados No. 3, Parque Empresarial Cristalia, Edificio nº 9, CP 28033 , Madrid Spain).

HAYA has appointed a Delegate for Data Protection, with whom you can contact through the email address oficinadpo@haya.es.

3. What is the purpose of the processing of your data and our legitimacy for it?

When HAYA carries out the processing of your personal data, it pursues the following purposes:

Purpose 1: provision of the services offered by HAYA in the commercialization of real estate assets

HAYA provides an exclusive marketing service for real estate assets directly or through a network of Real Estate Agents (APIs) with whom we have agreements. Through our sales network you can find out all the properties we have available, their description, characteristics and price, as well as visit them or make an offer for them and enjoy other added services that we carry out in order to carry out the commercialization activity of the buildings. Through your request and interest in any of the properties that we commercialize, your personal data will be processed to: (i) process your registration as an interested client and potential buyer; (ii) process your application visit the property in which you are interested; (iii) process the presentation of your offer for the property in which you are interested; (iv) process and respond to your questions, queries or claims made through the API or our contact phone. Also, in our web portal, www.haya.es, you can find the properties that we commercialize published, know their description, characteristics, price, photos, as well as other added services to carry out the real estate commercialization activity. By using the services offered on our website and, in accordance with the Terms of Use of the web portal, your personal data may be processed to: (v) process your registration as a web user; (vi) process your contact request to know more details about the property in which you are interested or arrange a visit; (vii) process the presentation of your offer for the property in which you are interested; (viii) process your recommendation to third parties of a property published on the web portal; (ix) process and answer your questions, queries or claims made through the contact web form.

Purpose 2: communication of data to the company that owns the property and to the rest of the companies in its Group

Based on the execution of the contractual relationship, HAYA may communicate your data to the company that owns the real estate asset in which you have shown interest (for example, when requesting more information, requesting a visit or making an offer on it), as well as the rest of the company belonging to its Economic Group, with the objective of managing the commercialization of said property made by HAYA (for example, to specify a visit with the owner, to send the owner his offer for real estate for him to value it, valuing the available financing options, closing the purchase and sale operation of the property, etc.).

Purpose 3: statistical information and satisfaction surveys

HAYA has a legitimate interest in knowing both the opinion of its users regarding the properties it sells and the services it offers, as well as its interests in the search of real estate, its browsing habits, etc. (For example, knowing which areas are the most demanded by users in the search for real estate, what kind of properties are the most demanded, the most demanded price range, the days and hours in which more real estate searches are carried out, among others) with the aim of being able to offer products and services more adjusted to the needs of its customers and users, as well as to improve both current and future products and services as well as their process of provision and commercialization.

To achieve the objective stated in the previous paragraph, HAYA will be able to process your data and:

- Conduct satisfaction surveys both telephone and electronic, even once you stop being a user of the web portal or stop showing interest in a property and, in these latter cases, to know the reasons for its progress.

- Proceed with anonymization, so that the information of your interests, searches and browsing habits can not be linked with your person and, after that, carry out statistical and econometric studies (for example, knowing the life cycle of the client or user and / or identify patterns of abandonment propensity).

Purpose 4: communication of data to Public Organizations and Public Administrations in compliance with legal obligations

HAYA has to comply with certain obligations established by the regulations on the Prevention of Money Laundering and Terrorist Financing, which could involve the request of data on your business or professional activity before Public Organizations in order to verify the information provided, or communication and / or consultation of data to the Risk Information Center of the Bank of Spain, in the cases legally established.

Purpose 5: sending commercial communications on similar properties and offers and promotions of HAYA

In the event that you give your consent, HAYA may send you by any channel, electronic or otherwise, segmented commercial information about the properties in which you have previously shown interest (for example, a decrease in the price of a property that you visited or saved as a favorite in your personal user account of our web portal) or on properties with similar characteristics (for example, properties located in the same area or similar to the ones you visited or saved as a favorite in your personal user account of our web portal) as well as HAYA offers and promotions that may interest you, directly or because they are related to the provision, improvement and updating of our services.

This commercial information may be generic or personalized. In the latter case, it will involve the previous processing of your data in order to be able to proceed with profiling and carterization, determine tastes, preferences and needs and, based on these, identify the information that may be most interesting to you.

At any time and for free, you can object to this purpose to not receive new commercial information, offers and promotions, indicating it by mail to the address above or by email to the address protecciondedatos@haya.es. Likewise, in all electronic commercial communications you will be informed, again, of your right to oppose the sending of commercial communications.

Purpose 6: communication of data to other companies of the HAYA Group, to third companies that provide services related to the real estate sector and to collaborating companies

In case you give your consent, HAYA may communicate your information to:

Other companies of the HAYA Economic Group that provide services related to the sectors related to the commercialization of real estate assets, including their financing, promotion, titling and others with added value to them.

Third companies provide services related to the sectors related to the commercialization of real estate assets, including their financing, promotion, titling and others of added value to them

Other companies with which HAYA has signed different collaboration agreements and that may belong to sectors such as telecommunications, finance, consumer goods, health and NGO's.

The communication of your data will be made with the aim that these companies can send you, directly and without the intermediation of HAYA, offers and promotions related to your products and services, or manage with you, upon request, the commercialization or benefit of any of your products or services.

Purpose 7: communication of data to service providers

If you give your consent, HAYA may communicate your data to companies that provide services that allow a better commercialization of the real estate asset in which you have shown interest and whose sectors of activity are the financial, the insurer or the provision of household supplies ( for example, water supply, electricity, gas, etc.), with the aim of offering a personalized service according to your needs in those areas with respect to the property in which you have shown interest.

4. What kind of data do we deal with?

For the purposes set out in the previous section, we deal with a set of personal data that can be divided into the following sources and categories:

a) Data provided directly by you: at the time of registration as a web user and / or in the application itself, through the completion of the forms for this purpose enabled.

The client guarantees that, the data provided to HAYA for the provision of the services requested respond truthfully to the real situation and that it will communicate any modification that affects them. Consequently, the customer will be liable to HAYA and third parties for any damages or losses caused as a result of breach of the obligations assumed in this clause.

b) Data derived from the provision of the service: all data that we already know from any previous interaction with you (for example, searches and interests made on real estate or properties with common characteristics, visits made to real estate, offers made by real estate , previous purchases of real estate commercialized by HAYA, claims or requests for information, etc.).

5. How long will we keep your personal information?

HAYA will keep your personal data as long as they are necessary for the development of the requested service or as long as they are necessary for the development and conclusion of the commercialization of the property in which you are interested. After this period, the data will be deleted in accordance with the provisions of the data protection regulations and the other applicable regulations, which implies their blocking, being available only at the request of Judges and Tribunals, the Public Prosecutor or the Public Administrations competent during the limitation period of the actions that could derive to be subsequently eliminated.

For the purposes of the foregoing paragraph, HAYA will proceed to block those users who are inactive, that is, those who do not access their personal web portal account or interact with HAYA requesting any of their services for a period of 5 days. years. Likewise, HAYA informs you that, in the event that the Money Laundering Prevention and Financing of Terrorism regulations apply to the processing of your data (for example, when you finally acquire a specific property marketed by HAYA), you have the obligation to keep your personal data for a minimum period of ten years.

6. To which recipients do we communicate your personal data?

HAYA may communicate its data to all those entities and organizations with respect to which it has an obligation or has obtained its consent. Among others, following:

Authorities or official bodies of other countries, located both inside and outside the European Union, within the framework of the fight against fraud, the financing of terrorism and serious forms of organized crime and the prevention of money laundering. Among others, your data may be communicated to the Executive Service of the Money Laundering and Monetary Offenses Commission - SEPBLAC when required.

Courts and Tribunals, and State Security Forces and Corps, in the event that HAYA may be required to communicate personal data in the framework of a judicial investigation.

To the companies that own the property and the companies of its Economic Group.

To companies and Collaborators for which you have given consent.

To our parent company, Cerberus Capital Management L.P., resident in the United States. HAYA informs you that said International Data Transfer is done with your consent, within the framework of the contractual relationship you have with HAYA for the commercialization of the property and with the objective of preventing money laundering and financing of terrorism.

7. Are there International Data Transfers?

In certain cases, HAYA carries out International Data Transfers in compliance with the requirements of the European Data Protection Regulation. In this sense, when the owners or managers of the assets, or its parent company, are located in the US, their data may be transferred to that territory for the prevention of money laundering and financing of terrorism, for which we will request your free, express and unequivocal consent.

8. What are your rights and how can you exercise them?

Our data protection regulations confers a series of rights in relation to the processing of data that our services imply and that we can summarize in the following:

Right of access: you have the right to know what kind of data we are dealing with and the characteristics of the treatment we are carrying out.

Right of rectification: you can request the modification of your data because they are inaccurate or not true.

Portability right: you can obtain a copy in an interoperable format of the data that is being processed.

Right to limitation of treatment in the cases included in the Law.

Right of withdrawal: you can request the deletion of your data when the treatment is no longer necessary.

Right of opposition: you can request the cessation of commercial communications in the terms indicated above.

Right to revoke the consent given.

You can exercise your rights by email to the address protecciondedatos@haya.es or by postal communication to the address Vía de los Poblados No. 3, Parque Empresarial Cristalia, Building No. 9, CP 28033, Madrid (Spain) indicating the right to exercise and attaching your ID or similar identification documentation. Likewise, you have the right to file a claim with the control authority (in Spain, the Spanish Data Protection Agency).

9. Do we access data from third parties?

For the provision of certain services, you may need to provide us with personal and contact information of third parties (for example, name, surname, email address or contact telephone number) that you think may be of interest to you. the properties commercialized by HAYA.

HAYA will exclusively treat this information to inform you of its suggestion about the property. In this sense, you guarantee the veracity and updating of the personal data of these third parties and, where appropriate, ensure that you have complied with all those obligations that, in terms of data protection, are attributable to you, having previously obtained your consent in if necessary.

Last update on June 14, 2018.