In compliance with the provisions of current legislation, Building institutional-grade real assets (hereinafter also Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy is adapted to the current Spanish and European regulations on the protection of personal data on the internet. Specifically, it complies with the following rules:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
• Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of 21 December, approving the Regulation implementing Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the controller of personal data processing

The controller of the personal data collected on Building institutional-grade real assets is: AETHERION, SL, holder of Tax ID/CIF: B75889360 and registered in: with the following registration details: , whose representative is: (hereinafter, Controller). Their contact details are as follows:

Address: Calle de Antonio Maura, 7 6 Izq, 28014, Madrid

Contact email: info@aetherion.es

Registration of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Building institutional-grade real assets, through the forms available on its pages, will be incorporated and processed in our file in order to facilitate, streamline and fulfil the commitments established between Building institutional-grade real assets and the User or the maintenance of the relationship established in the forms completed by the latter, or to respond to a request or enquiry from the same. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained specifying, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights:

• Principle of lawfulness, fairness and transparency: the User’s consent shall be required at all times after fully transparent information has been provided regarding the purposes for which the personal data are collected.
• Principle of purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes.
• Principle of data minimisation: the personal data collected shall be only those strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and always kept up to date.
• Principle of storage limitation: personal data shall only be kept in a form which permits identification of the User for as long as necessary for the purposes of their processing.
• Principle of integrity and confidentiality: personal data shall be processed in such a way as to ensure their security and confidentiality.
• Principle of proactive accountability: the Controller shall be responsible for ensuring compliance with the above principles.

Categories of personal data

The categories of data processed by Building institutional-grade real assets are only identification data. Under no circumstances are special categories of personal data within the meaning of Article 9 of the GDPR processed.

The categories of data processed by Building institutional-grade real assets include both identification data and special categories of personal data within the meaning of Article 9 of the GDPR.

Special categories of personal data are understood to be those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data aimed at uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

For the processing of special categories of personal data, the User’s explicit consent for one or more specific purposes shall in all cases be required.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Building institutional-grade real assets undertakes to obtain the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw their consent at any time. It shall be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent shall not affect the use of the Website.

On occasions when the User must or may provide their data through forms in order to make enquiries, request information or for reasons related to the content of the Website, they shall be informed in the event that completion of any of them is mandatory because they are essential for the proper execution of the operation carried out.

Purposes of the processing for which personal data are intended

Personal data are collected and managed by Building institutional-grade real assets for the purpose of facilitating, streamlining and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms completed by the latter or responding to a request or enquiry.

Likewise, the data may be used for a commercial purpose of personalisation, operational and statistical purposes, and activities inherent to the corporate purpose of Building institutional-grade real assets, as well as for data extraction, storage and marketing studies to adapt the Content offered to the User, as well as improve the quality, operation and browsing of the Website.

At the time the personal data are obtained, the User shall be informed of the specific purpose or purposes of the processing for which the personal data are intended; that is, of the use or uses to be made of the information collected.

Retention periods of personal data

Personal data shall only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: , or until the User requests their deletion.

At the time the personal data are obtained, the User shall be informed of the period during which the personal data will be stored or, when this is not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data will not be shared with third parties.

In any case, at the time the personal data are obtained, the User shall be informed about the recipients or categories of recipients of the personal data.

The User’s personal data will be shared with the following recipients or categories of recipients:

If the Controller intends to transfer personal data to a third country or international organisation, at the time the personal data are obtained, the User shall be informed about the third country or international organisation to which the data are intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In compliance with the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights, only persons over 14 years of age may lawfully give their consent for the processing of their personal data by Building institutional-grade real assets. If the person is under 14 years of age, the consent of parents or guardians shall be necessary for the processing, and it shall only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

Building institutional-grade real assets undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in such a way as to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication of or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, since the transmission of data between the server and the User, and in feedback, is fully encrypted or encoded.

However, because Building institutional-grade real assets cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Controller undertakes to notify the User without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data security breach means any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

Personal data shall be treated as confidential by the Controller, who undertakes to inform of and guarantee by means of a legal or contractual obligation that such confidentiality is respected by their employees, associates, and any person to whom they make the information accessible.

Rights arising from the processing of personal data

The User has rights over Building institutional-grade real assets and may therefore exercise against the Controller the following rights recognised in the GDPR and Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights:

• Right of access: This is the User’s right to obtain confirmation of whether or not Building institutional-grade real assets is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Building institutional-grade real assets has carried out or is carrying out, as well as, among other things, the available information on the origin of such data and the recipients of the communications made or planned in relation to them.
• Right to rectification: This is the User’s right to have their personal data modified when they prove to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure (“the right to be forgotten”): This is the User’s right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data have been unlawfully processed; the personal data must be erased in compliance with a legal obligation; or the personal data were obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to erasing the data, the Controller, taking into account the available technology and the cost of its implementation, shall adopt reasonable measures to inform the controllers processing the personal data of the data subject’s request for the erasure of any links to such personal data.
• Right to restriction of processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs them to make claims; and when the User has objected to the processing.
• Right to data portability: In the event that the processing is carried out by automated means, the User shall have the right to receive from the Controller their personal data in a structured, commonly used and machine-readable format, and to transmit them to another controller. Whenever technically possible, the Controller shall transmit the data directly to that other controller.
• Right to object: This is the User’s right not to have their personal data processed or to have the processing of the same stopped by Building institutional-grade real assets.
• Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless current legislation provides otherwise.

Accordingly, the User may exercise their rights by means of a written communication addressed to the Controller with the reference “GDPR-https://aetherion.es/“, specifying:

• Name, surname(s) of the User and copy of ID document. In cases where representation is admitted, identification by the same means of the person representing the User shall also be necessary, as well as the document proving the representation. The photocopy of the ID document may be replaced by any other legally valid means that proves identity.
• Request stating the specific reasons for the application or the information to which access is sought.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document proving the request made.

This request and any other attached document may be sent to the following address and/or email address:

Postal address: Calle de Antonio Maura, 7 6 Izq, 28014, Madrid

Email address: info@aetherion.es

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Building institutional-grade real assets, and which are therefore not operated by Building institutional-grade real assets. The owners of such websites shall have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints before the supervisory authority

If the User considers that there is a problem or a breach of the current regulations in the way their personal data are being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, in the State in which they have their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as that they accept the processing of their personal data so that the Controller may proceed with it in the manner, for the periods and for the purposes indicated. Use of the Website shall imply acceptance of its Privacy Policy.

Building institutional-grade real assets reserves the right to modify its Privacy Policy, according to its own discretion, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy shall not be explicitly notified to the User. The User is recommended to consult this page periodically in order to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and to Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights..