1. INTRODUCTION
ZITTA PROPERTIES, S.L., of registered office at Calle Claudio Coello 106-4º Dcha 28006 Madrid, España and Tax ID Number B-80925019(hereinafter, ‘ ZITTA PROPERTIES’) takes the privacy of the personal data that it processes as a data controller very seriously, as its primary goal is to maintain the full trust of its customers and potential customers.

Therefore and in order to fully comply with General Data Protection Regulation 2016/679 (‘ GDPR’), ZITTA PROPERTIES has launched this Privacy Policy detailing its practices for the processing of personal data relating to the provision of its real estate development services, covering the entire process up to the delivery of housing or other property (the ‘ Services’).

Please read this Privacy Policy carefully and contact the ZITTA PROPERTIES Data Protection Officer if you have any questions regarding any of the practices described below. Any reference to ‘we’, ‘us’, ‘our’ or ‘ZITTA PROPERTIES’ in this Privacy Policy is a reference to ZITTA PROPERTIES.

2. PERSONAL DETAILS: CONCEPT, ORIGIN, LEGITIMACY AND PROCESSING
2.1. WHAT IS PERSONAL DATA?
Personal data is any data or information about an identified or identifiable individual, such as name, date of birth, postal address, e-mail address, gender, consumer status of a product or a company’s customer or employee, creditworthiness, consumer habits, bank accounts and professional experience. On the other hand, it is also necessary to take into account personal data considered to be particularly sensitive personal data, which, due to its very personal nature, requires the subject or entity involved to apply more restrictive security measures to ensure not only its confidentiality but also its integrity and limited and restricted use. In addition, to collect and process these data, prior and explicit consent must always be requested, and, where applicable, compliance with the additional requirements established in the applicable regulations. Particularly sensitive personal data includes data such as ethnic or racial background, political opinions, trade union membership, religion or health, among others. Given the nature of the Services provided by ZITTA PROPERTIES, we understand that we do not need to collect or process particularly sensitive data from our customers or potential customers. If, due to exceptional circumstances, ZITTA PROPERTIES needed to collect particularly sensitive data, we would first obtain the informed, free and explicit consent of those affected.

2.2. WHAT PERSONAL DATA DOES ZITTA PROPERTIES PROCESS?
Pursuant to the provision of the Services, ZITTA PROPERTIES processes the personal data of its customers or prospective customers (hereinafter: ‘ Data Subject’ or ‘ Data Subjects’), in order to fulfil its legal, contractual obligations and to fulfil its legitimate interests.

The personal data that ZITTA PROPERTIES may process from Data Subjects (hereinafter: ‘ Personal Data’) is as follows:

• name and surname, age, gender, date of birth, address, nationality, marital status, ID card or passport, e-mail, telephone, voice data, calls, professional activity, family information, bank data, navigation data on the ZITTA PROPERTIES website, complementary information communicated by the Data Subject in messages with ZITTA PROPERTIES, and any other data necessary for the provision of the Services.

2.3. SOURCE OF PERSONAL DATA
The source of the Personal Data accessed by ZITTA PROPERTIES may be the Data Subject or third parties. In particular, ZITTA PROPERTIES collects the Personal Data previously described in the following ways:

1. Through third parties, such as real estate marketing companies.
2. Directly through the Parties themselves, as a result of the formalisation of a contractual relationship and the provision of the corresponding Services.
3. Directly, via the ZITTA PROPERTIES website or telephone calls and messages between Data Subjects and ZITTA PROPERTIES. In this regard, the Data Subjects are informed that ZITTA PROPERTIES could record telephone calls and electronic messages that ZITTA PROPERTIES sends them (via e-mail, instant messaging applications, social networks or any other equivalent means that could be used), in order to serve as a means of proof of the instructions received and transactions carried out.

It is important that Data Subjects ensure that all Personal Data that they provide or have provided to ZITTA PROPERTIES is up to date. Therefore, in the event of any modification to the data previously sent by the Data Subjects to ZITTA PROPERTIES (namely those that could affect their postal address, e-mail address, contact numbers and bank details), the Data Subjects undertake to contact the ZITTA PROPERTIES Data Protection Officer for its updating.

3. PURPOSE
ZITTA PROPERTIES processes Personal Data in accordance with the purposes described below:

1. To carry out contractual obligations with regard to the Services contracted by the Data Subjects and to comply with any other purpose connected with the provision of the Services, such as handling queries, suggestions and orders received by ZITTA PROPERTIES from the Data Subjects.
2. Profiling the Data Subjects, based on the information available to ZITTA PROPERTIES, so that ZITTA PROPERTIES can offer more personalised and appropriate processing to the interests and characteristics of the Data Subjects. It is important to mention that at no time is profiling carried out exclusively on an automated basis nor does it have legal effects on Data Subjects.
3. With regard to the navigation data obtained through the ZITTA PROPERTIES website, ‘Cookies’, ZITTA PROPERTIES proceeds to process it in order to improve the user experience of its website; for example, the latest search criteria from users are analysed in order to present the offers of the Services that ZITTA PROPERTIES believes may be of interest to them.To learn more about ZITTA PROPERTIES’s Cookie Policy, please visit the following link https://zittaproperties.com/cookie-policy/?lang=en.
4. To carry out analysis, study, evaluation, marketing, promotion, information and sending of commercial messages, with regard to the products and Services of ZITTA PROPERTIES or companies directly or indirectly owned by ZITTA PROPERTIES, not only by post, telephone or fax, but also by SMS, instant messaging applications, social networks, e-mail, or any other electronic or telematic means available from time to time, under the terms set out in Article 21 of Law 34/2002, Information on Information Society Services and other applicable regulations.

   ZITTA PROPERTIES reminds you that at all times the Data Subject has the right not to receive information and advertising, particularly by electronic or telematic means, or by post. Therefore, if the Data Subject wishes to opt out and stop receiving commercial messages and advertising by electronic, telematic means or by any other available means, they may notify ZITTA PROPERTIES by sending an email to the ZITTA PROPERTIES Data Protection Officer.

5. To comply with their legal and regulatory obligations.
6. Performing such processing as are necessary to satisfy the legitimate interests of ZITTA PROPERTIES, but ensuring that the rights and freedoms of Data Subjects are not affected.
7. Facilitate the access of Data Subjects to commercially competitive financing conditions.

4. DISCLOSURE OF PERSONAL DATA
Furthermore, and in order to pursue compliance with the purposes set out above, ZITTA PROPERTIES may share the personal information of Data Subjects with third parties. In any event, ZITTA PROPERTIES undertakes to ensure that third party recipients of Personal Data comply with the privacy standards applied and offered by ZITTA PROPERTIES. ZITTA PROPERTIES may share your Personal Information with:

1. Companies directly or indirectly owned by ZITTA PROPERTIES for the purposes described above.
2. Third party contributors and service providers contracted by ZITTA PROPERTIES to carry out duties related to their business. This category may include construction companies, real estate trading companies, financial services companies, banks, companies organising promotional events in the real estate sector, companies in the legal sector such as law firms or notary’s offices, technology service companies, communications companies and any others that may be involved in the real estate marketing process.
3. Relevant judicial and governmental authorities to comply with applicable laws and regulatory monitoring and reporting obligations, to respond to requests from public authorities or for other legal reasons.

5. SECURITY OF PERSONAL DATA
ZITTA PROPERTIES is very committed to the security, privacy and integrity of the Personal Data it processes belonging to its Data Subjects. For this reason, ZITTA PROPERTIES has in place and applies the highest security standards to ensure that Personal Data is handled in a fully secure manner within ZITTA PROPERTIES. In particular, ZITTA PROPERTIES employs the organisational, technical and administrative measures which, in accordance with the state of the art and nature of the Personal Data applicable, guarantee full protection, integrity and confidentiality of Personal Data belonging to its Data Subjects. These also include measures to address any suspected breach of Personal Data.

6. RIGHTS OF DATA SUBJECTS
In line with the provisions of the GDPR, ZITTA PROPERTIES informs the Data Subjects that they have the following rights under it:

• Right to access: Any Data Subject may request ZITTA PROPERTIES to confirm whether it is processing their Personal Data, to provide them with a copy of such Personal Data and to provide them with any other information about their Personal Data (what data do they have, for what they use it for, to whom they send it to, whether they transfer it to third parties, its location, how they protect it, how long they keep it for, what rights do Data Subjects have, how you may file a complaint, where your data has been obtained from), to the extent that this information has not already been provided to you in this Privacy Policy.
• Right to rectification: Data Subjects may request that ZITTA PROPERTIES correct and update their inaccurate Personal Information.
• Right to erasure of Personal Data: Data Subjects may require erasure of their Personal Data by ZITTA PROPERTIES when: (i) The Personal Data is no longer necessary in relation to the purposes for which it was collected, (ii) the Data Subject withdraws their consent (if the data processing is based on consent), (iii) the Data Subject exercises their right to opposition (as defined below), (iv) the Personal Data has been unlawfully processed, and (v) ZITTA PROPERTIES has to comply with a legal obligation.
• Right to restriction: Any Data Subject may request that ZITTA PROPERTIES limit the processing of their Personal Data (i.e., retaining it but not using it) only if (i) its accuracy is disputed (see below the right to rectification), to enable us to verify its accuracy; (ii) the processing is unlawful, but the Data Subject does not want the Personal Data removed; (iii) it is no longer necessary for the purposes for which it was collected, but ZITTA PROPERTIES still needs them for the preparing, exercising or defending of legal claims; (iv) the Data Subject has exercised the right of opposition and the verification of the grounds for its opposition is pending.ZITTA PROPERTIES may continue to use your Personal Information after a request for restriction (i) if it has your consent; (ii) for the preparing, exercising or defending of legal claims; or (iii) to protect the rights of another individual or legal entity.
• Right to data portability: Under certain circumstances, Data Subjects are entitled to receive their Personal Data from ZITTA PROPERTIES that is being processed in a structured, commonly used and machine-readable format. They also have the right to request the transfer of their Personal Data to another entity by ZITTA PROPERTIES.
• Right to opposition: Data Subjects may object to any processing of their Personal Data that is legally based on the ‘legitimate interests’ of ZITTA PROPERTIES, if they believe that there are specific circumstances which could unreasonably affect their fundamental rights and freedoms.It is important to be aware that in those cases where Data Subjects exercise their right to object to the processing of such Personal Data as may be necessary to satisfy the legitimate interests of ZITTA PROPERTIES (and to comply with their legal and contractual obligations), ZITTA PROPERTIES may be unable to provide the Services to said Data Subjects.
• Right to the opposition of sending commercial messages: Data Subjects have the right to object to the use of their Personal Data for the sending of commercial messages, including by electronic and telematic means.
• Withdrawal of consent: Any Data Subject may withdraw their consent in connection with any processing of their Personal Data based on prior consent. Consent can be withdrawn by contacting the ZITTA PROPERTIES Data Protection Officer.
• Right to file a complaint with the Spanish Data Protection Agency: While we prefer that Data Subjects first approach ZITTA PROPERTIES to resolve any complaints or queries, it is important that Data Subjects know that they have the right to file a complaint with the Spanish Data Protection Agency, through the contact details provided in Section 10 below.

Data Subjects may exercise their rights by contacting the ZITTA PROPERTIES Data Protection Officer, by written request duly justifying the scope of their request and attaching a photocopy of their ID or passport.

7. PERSONAL DATA STORAGE PERIOD
ZITTA PROPERTIES does not retain Personal Data on Data Subjects for longer than is necessary to meet the purposes for which it is processed.

In this regard, ZITTA PROPERTIES has a personal data retention policy in place that determines how long certain types of personal information are retained. For more information on the criteria ZITTA PROPERTIES uses to determine storage periods for personal information, please contact the ZITTA PROPERTIES Data Protection Officer.

8. CHANGES TO THIS PRIVACY POLICY
Any future privacy changes ZITTA PROPERTIES makes will be posted on its website. Please check the ZITTA PROPERTIES website often for updates or changes to our Privacy Policy.

9. ZITTA PROPERTIES CONTACT DATA – DATA PROTECTION OFFICER
If you have any questions about the practices described in this Privacy Policy, you may contact the ZITTA PROPERTIES Data Protection Officer at the following addresses and telephone number:

• rgpd@zittaproperties.com/ 91 999 24 60
• Claudio Coello 106-4º Dcha 28006 Madrid

The Data Subject is advised that in order for ZITTA PROPERTIES to be able to provide them with information or exercise their rights, they may need to verify their identity, request a copy of their ID card or passport, or ask for other details that will duly explain the scope of their request. We will contact you as soon as possible.

10. CONTACT DETAILS OF THE SPANISH DATA PROTECTION AGENCY
If you wish to contact the Spanish Data Protection Agency regarding any of the practices described in this Privacy Policy, you may do so via the following address and telephone numbers:

• Agencia Española de Protección de Datos – Calle Jorge Juan 6, 28001 Madrid.

• 901 100 099 / 912 663 517.