Privacy Policy

In accordance with Law 29/2021, of October 28, qualified for the protection of personal data ("LQPD") and the regulations that develop it, as well as taking into account the principles of Regulation (UE) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data ("GDPR"), persons who access or interact with the website https://adriyatik.ad (the "Web") and/or with the enabled contact channels (email, telephone or instant messaging applications, such as WhatsApp) are informed about the processing of their personal data ("Privacy Policy").

This Privacy Policy describes the way in which VENTALL 2020, SLU obtains, uses, preserves and protects personal data, as well as the rights that assist the interested persons.

For the purposes of this policy, "User" means any natural person who accesses the Web or who communicates with VENTALL 2020, SLU through any of the enabled channels.

The use of the Web implies that the User has read and understood this Privacy Policy.

1. DATA CONTROLLER

The person responsible for the processing of personal data ("Controller") is:

VENTALL 2020, SLU, with NRT L-715479-D and address for the purposes of this policy at Avinguda del Pont de la Tosca, 11, Edifici Paris Londres Bloc París, L1, AD700, Escaldes-Engordany (Principality of Andorra).

The company owns the trademark ADRIYATIK.

The contact email is: info@adriyatik.ad

2. DATA PROTECTION OFFICER

The Controller has appointed a Data Protection Officer ("DPO"), who can be contacted for any question related to the processing of personal data or the exercise of rights recognized by applicable regulations.

ELEVA DATA, SL with NRT L-716693-U and contact email: dpd@eleva.legal

3. SCOPE OF APPLICATION

This Privacy Policy is applicable to the processing of personal data carried out in relation to:

• People who access and browse the Web;
• People who communicate with VENTALL 2020, SLU through email, telephone or instant messaging applications (such as WhatsApp);
• People who fill out contact or information request forms available on the Web;
• People who contract products or services offered by VENTALL 2020, SLU through the Web;
• Customers, suppliers or other third parties who maintain a commercial or professional relationship with VENTALL 2020, SLU.

The personal data provided must be true, accurate, updated and relevant.

VENTALL 2020, SLU warns that, unless there is a duly accredited legal representation, no User can use the identity of another person or communicate their personal data. Therefore, the data provided by the User must correspond to their real identity and be current, accurate and true.

The User will be solely responsible for any damage, direct or indirect, that may be caused to third parties or to VENTALL 2020, SLU as a consequence of the communication of false, inaccurate, outdated or inadequate data.

In the event that the User provides personal data of third parties, they declare to have the necessary legitimacy for its communication and to have previously informed the interested persons about the content of this Privacy Policy.

This Privacy Policy is subsidiary to any informative clause or specific condition regarding data protection that may be established in forms, particular conditions or other documents. In these cases, the specific conditions will prevail when expressly provided for.

4. PERSONAL DATA AND CATEGORIES OF DATA WE COLLECT AND PROCESS

The personal data we collect and process is that provided directly by the User, as well as that which can be obtained as a result of their interaction with the Web or through the contact channels enabled by VENTALL 2020, SLU such as web forms, email or instant messaging applications (such as WhatsApp).

The particular conditions regarding communication via WhatsApp can be consulted here.

The categories of personal data that can be processed include:

• Identifying data: first and last name, email, telephone number, and when necessary for the formalization of real estate operations or management related to the purchase of a home, identifying document (passport and/or residence permit) and date of birth.
• Economic data: bank details strictly necessary for the management of payments or collections derived from the products or services contracted.
• Communication data: information contained in messages sent by Users through the contact forms of the Web, emails or other enabled channels, including instant messaging applications.
• Browsing data: information relative to the use of the Web, including that collected through tracking technologies such as cookies or similar technologies related to navigation and User interaction with the Web.

The Web is not directed at minors and personal data of minors will not be deliberately processed.

5. PURPOSES OF PROCESSING AND LEGAL BASIS

Personal data collected through the Web and other communication channels will be processed exclusively for the following purposes:

a) Management of information requests, queries and communications

Purpose: Management of communications made through the contact forms of the Web, email, WhatsApp or other enabled channels. The data collected is strictly necessary to attend to and manage information requests relative to the homes or services offered by VENTALL 2020, SLU, as well as to respond to queries sent by Users.

Legal basis:

• Application of pre-contractual measures at the User's request (art. 6.1.b LQPD).
• Legitimate interest of the Controller in properly managing communications received (art. 6.1.f) LQPD).

b) Sending information about news, activities and other communications from VENTALL 2020, SLU

Purpose: Sending informative or commercial communications relative to news, activities or initiatives of VENTALL 2020, SLU, including communications related to real estate promotions or projects under development.

These communications can be sent via email or other communication channels authorized by the User.

Legal basis: express consent of the User (art. 6.1 a) LQPD).

c) Customer management and contractual relations

Purpose: Processing of personal data necessary to manage the commercial relationship with customers, including the management of purchase requests for homes, verification of the identity of the interested person, formalization of contracts and administrative management derived from the contractual relationship.

Legal basis:

• Execution of a contract or application of pre-contractual measures (art. 6.1. b) LQPD).
• Compliance with legal obligations applicable to the Controller (art. 6.1 c) LQPD).

d) Improvement of User experience and browsing analysis

Purpose: Analyze the use of the Web and improve the browsing experience of Users through analysis tools, statistics or similar technologies (such as cookies or equivalent technologies), with the purpose of optimizing the operation of the Web and the services offered.

Legal basis:

• Express consent of the User for the use of analytical or tracking Cookies (art. 6.1 a) LQPD).
• Legitimate interest of the Controller in improving the operation and security of the Web, provided that the rights and freedoms of the Users do not prevail (art. 6.1 f) LQPD).

e) Compliance with legal obligations

Purpose: Personal data can be processed when necessary to comply with legal obligations applicable to the Controller or to respond to requirements from administrative or judicial authorities.

Legal basis:

• Compliance with a legal obligation (art. 6.1 c) LQPD) and,
• Legitimate interest of the controller in the defense of its rights, when necessary (art. 6.1.f) LQPD).

Personal data will not be used for purposes other than those described in this Privacy Policy. In no case are automated decisions made based exclusively on the processing of personal data.

6. CONSERVATION PERIODS FOR EACH TYPE OF PROCESSING

Users' personal data will be kept only for the time necessary to fulfill the purposes for which it was collected in accordance with the principle of limitation of the conservation period provided for in the applicable data protection regulations.

Once these purposes are fulfilled, the data will be blocked and kept only to attend to possible legal responsibilities derived from the processing, during the legally established prescription periods.

In the event that a legal provision requires the conservation of data for a specific period, it will be kept for the period established by the applicable regulations. During this period, the data will remain blocked and will only be processed to guarantee its conservation and for the formulation, exercise or defense of possible claims. Once these periods have ended, personal data will be deleted or, where appropriate, safely anonymized.

The applicable conservation periods according to the type of processing are indicated below:

7. DATA RECIPIENTS

Personal data collected through the Web and/or through the enabled communication channels will not be communicated to third parties, except in the following cases:

• When express consent from the interested person is available;
• When there is a legal obligation that justifies the communication;
• When it is necessary for the data to be processed by data processors who provide services to VENTALL 2020, SLU, acting on behalf of the Controller and in accordance with their instructions, by virtue of the corresponding data processor contract, which guarantees the application of appropriate technical and organizational measures to preserve the confidentiality, integrity and security of the information.
• When it is necessary to guarantee, exercise or defend the rights or legitimate interests of VENTALL 2020, SLU, including the protection of its property, image or reputation.

8. INTERNATIONAL DATA TRANSFERS

In general, VENTALL 2020, SLU does not plan to carry out international transfers of personal data outside the Principality of Andorra.

However, in the event that certain technological service providers used for the management of the Web or the communication channels are located outside the Principality of Andorra, these transfers will be carried out in accordance with what is established by the LQPD and always guaranteeing an adequate level of protection equivalent to that provided by Andorran regulations.

In these cases, VENTALL 2020, SLU will adopt the appropriate guarantees provided by applicable regulations to ensure the protection of personal data.

9. YOUR RIGHTS

As the owner of your personal data, the interested person can exercise the rights indicated below, in accordance with what is established by the regulations in force regarding the protection of personal data:

a) Right of access

You can obtain confirmation as to whether personal data concerning you is being processed and, in this case, access this data and clear and understandable information about the processing being carried out (purposes, categories of data, recipients, conservation periods, rights, etc.). Likewise, you have the right to obtain a copy of your personal data in a structured, commonly used and easily readable format.

b) Right to rectification

You can request the rectification of inaccurate personal data without undue delay and you also have the right to request that incomplete personal data be completed by means of an additional statement.

c) Right to erasure ("right to be forgotten")

You can request the erasure of your personal data when it is no longer necessary for the purposes for which it was collected, or when you withdraw the consent on which the processing was based, among other cases provided for by applicable regulations.

d) Right to object

You can object to the processing of your personal data when it is based on the legitimate interest of the controller or when the data is processed for direct marketing purposes.

e) Right to restriction of processing

You can request the restriction of the processing of your personal data in the following situations: (i) when you challenge the accuracy of the personal data, while the veracity is verified; (ii) when the processing is unlawful, but the interested person prefers the restriction of its use instead of its erasure; (iii) when the controller no longer needs the data, but the interested person needs it to formulate, exercise or defend claims; or (iv) when you have objected to the processing while it is verified whether the controller's legitimate reasons prevail over those of the interested person.

f) Right to data portability

When the processing is based on consent or on the execution of a contract and is carried out by automated means, the interested person has the right to receive their personal data in a structured, commonly used and machine-readable format, and to transmit it to another controller when technically possible.

g) Right to withdraw consent

When the processing of data is based on consent, the interested person can withdraw it at any time, without this affecting the lawfulness of the processing based on the consent prior to its withdrawal.

Channels to exercise your rights:

The interested person can exercise their rights through:

• Email to info@adriyatik.ad
• Postal mail to Avinguda del Pont de la Tosca, 11, Edifici Paris Londres Bloc París, L1, AD700, Escaldes-Engordany (Principality of Andorra).

Subject: Exercise of data protection rights - right being exercised

In order to protect the confidentiality and security of personal data, VENTALL 2020, SLU reserves the right to request additional information that allows verification of the identity of the person exercising the right, when it is not possible to identify them with the information provided.

Right to file a complaint:

In the event that the interested person considers that their rights regarding data protection have been violated, especially if they have not obtained a satisfactory response in the exercise of their rights, they can file a complaint with the Andorran Data Protection Agency ("APDA"), through its website: www.apda.ad

10. CONFIDENTIALITY OF PERSONAL DATA

VENTALL 2020, SLU will adopt from the moment the processing of personal data begins, the technical, organizational and security measures necessary, taking into account the state of technology, to guarantee the integrity, confidentiality, availability and resilience of personal data and avoid its alteration, loss, unauthorized processing or access.

11. VALIDITY OF THE PRIVACY POLICY

VENTALL 2020, SLU reserves the right to modify this Privacy Policy to adapt it to legislative developments or changes in the personal data processing carried out.

The current version of the Privacy Policy will always be the one published on the Web https://adriyatik.ad