Privacy Policy

PRIVACY POLICY

With this privacy policy we would like to inform you about the data protection aspects of our website. It explains which data we collect and what we use it for, and it informs you about your rights.

This is a translation of the German original. In case of any discrepancy, the German version at newestepona.com/de/datenschutz/ prevails.

General
Definitions
Information pursuant to Article 13 GDPR
Information on the applications used on our site
Analytics and advertising

1. GENERAL

Data transmission over the internet can always have security gaps, so absolute protection cannot be guaranteed. You are therefore free to send us your data by other means, for example by telephone.

SSL ENCRYPTION

Our website is SSL encrypted. This is a system for protecting the transmission of data; as a rule, such data cannot then be read by third parties. You can recognise an encrypted connection by the small padlock shown in the address bar of your browser and by the change from “http” to “https”.

COLLECTION OF GENERAL DATA AND INFORMATION

Every time you access our site, a number of general data and information items are recorded automatically. These are stored in what are known as the server log files. The following information may be recorded:

browser type and version used,
the operating system used by the accessing system, that is, as a rule, your computer
referrer, that is, the website from which you or the accessing system reached our website
the sub-pages accessed on our website by the accessing system
date and time of access to our site
shortened or encrypted IP address (internet protocol address)
the internet service provider of the accessing system
other similar data and information which serve to avert danger in the event of attacks on our systems

This data is collected anonymously. We do not draw any conclusions about the data subject from it. Information on those applications and functions used on our site which are relevant to data protection can be found in the section “Information on the applications used on our site”.

2. DEFINITIONS

To make the following privacy policy easier to understand, we would like to begin by explaining some definitions that we consider important:

GDPR is the abbreviation for the General Data Protection Regulation (Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016)

Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.

Controller or controller responsible for the processing means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Third country within the meaning of the GDPR is any country that is neither a member of the European Union nor of the European Economic Area.

3. INFORMATION PURSUANT TO ARTICLE 13 GDPR

NAME AND ADDRESS OF THE CONTROLLER

The controller within the meaning of the General Data Protection Regulation is

Tividal Home S.L. Calle del Manzano 374 29680 Estepona, Telephone: +49 160 92607358 E-mail: info@newestepona.com

CATEGORIES OF DATA SUBJECTS

Visitors and users of our website and our online offering.

TYPES OF DATA PROCESSED

contact data (e.g. e-mail, telephone numbers), where provided
content data (e.g. text entries)
usage data (e.g. access times, pages visited)
meta and communication data (e.g. device information, IP addresses)

PURPOSE OF THE PROCESSING

The processing is carried out for the following purposes:

to provide our online offering, its functions and its content
to optimise our site and its security
for reach measurement and marketing (for details see the section “Information on the applications used on our site”)

LEGAL BASIS FOR THE PROCESSING

Where the legal basis is not stated in this privacy policy, in particular in the section “Information on the applications used on our site”, the following applies:

the legal basis for obtaining your consent is Article 6(1)(a) GDPR
the legal basis for processing in order to provide our services and to perform contractual and pre-contractual measures, and to answer enquiries, is Article 6(1)(b) GDPR
the legal basis for processing in order to fulfil our legal obligations is Article 6(1)(c) GDPR
the legal basis for processing in order to safeguard our legitimate interests is Article 6(1)(f) GDPR.

ERASURE AND BLOCKING OF PERSONAL DATA

We process and store personal data only for the period necessary to achieve the purpose of storage, or for the period provided for by laws or regulations where applicable. If the purpose of storage no longer applies or a statutory storage period expires, the personal data is erased as a matter of routine and in accordance with the statutory provisions.

PROCESSORS

If we transfer data to other persons and companies or otherwise grant them access to the data, this is done only on the basis of a legal permission. Where we commission third parties with the processing of data on the basis of what is known as a data processing agreement, this is done on the basis of Article 28 GDPR.

TRANSFERS TO THIRD COUNTRIES

If we process data in a third country, or if this occurs in the course of using the services of third parties, this is done only to the extent permitted by law. Where we process data in a third country, or have it processed there by third parties (processing on our behalf), this is done on the basis of Articles 44 et seq. GDPR.

YOUR RIGHTS AS A DATA SUBJECT

RIGHT OF ACCESS (ART. 15 GDPR)

You have the right to obtain from us confirmation as to whether or not we process personal data concerning you, and, where that is the case, you further have the right to obtain information on the following points:

the purposes of the processing
the categories of personal data processed
the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you, or to object to such processing
the existence of the right to lodge a complaint with a supervisory authority
where the personal data are not collected from the data subject: any available information as to their source
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and — at least in those cases — meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Where personal data concerning you are transferred to a third country or to an international organisation, you also have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer. In responding to a request for access we will provide you, pursuant to Article 15(3) GDPR, with a copy of the personal data undergoing processing. For any further copies we may charge a reasonable fee. If you make the request electronically, we will provide the information in an electronic format, unless you request otherwise.

RIGHT TO RECTIFICATION (ART. 16 GDPR)

You have the right to obtain from us the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you also have the right to have incomplete personal data completed.

RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”; ART. 17 GDPR)

You have the right to obtain from us the erasure of your personal data where one of the following applies and to the extent that the processing of the personal data is not necessary:

The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
You withdraw the consent on which the processing is based and there is no other legal ground for the processing.
You object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR.
The personal data have been unlawfully processed.
The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

Where we have made the personal data public and are obliged pursuant to Article 17(1) GDPR to erase the personal data, we shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other controllers which are processing the published personal data that you have requested the erasure by those controllers of any links to, or copy or replication of, those personal data, to the extent that the processing is not required.

RIGHT TO RESTRICTION OF PROCESSING (ART. 18 GDPR)

You have the right to obtain from us restriction of processing where one of the following applies:

You contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data.
The processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead.
We no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.
You have objected to the processing pursuant to Article 21(1) GDPR pending the verification whether our legitimate grounds override yours.

Where the processing of your personal data has been restricted under the above conditions, such data may — with the exception of storage — only be processed with your consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State. We will inform you before the restriction is lifted.

RIGHT TO OBJECT (ART. 21 GDPR)

You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR (processing in the public interest or to safeguard a legitimate interest); this also applies to profiling based on those provisions. We will then no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.

RIGHT TO WITHDRAW CONSENT (ART. 7(3) GDPR)

If you have given us consent to process your personal data, you have the right to withdraw that consent at any time without giving reasons. The lawfulness of processing carried out on the basis of the consent before its withdrawal remains unaffected.

AUTOMATED INDIVIDUAL DECISION-MAKING, INCLUDING PROFILING

You have the right not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning you or similarly significantly affects you, unless the decision is necessary for entering into, or performance of, a contract between you and us, or is authorised by Union or Member State law to which we are subject and which lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or is based on your explicit consent. Where the decision is necessary for entering into, or performance of, a contract between you and us, or is based on your explicit consent, we implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on our part, to express your point of view and to contest the decision.

RIGHT TO DATA PORTABILITY (ART. 20 GDPR)

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. You also have the right to transmit that data to another controller without hindrance from us, where the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, or on a contract pursuant to Article 6(1)(b) GDPR, and the processing is carried out by automated means. You have the right to have the data transmitted directly by us to another controller, where technically feasible and where this does not adversely affect the rights and freedoms of others.

RIGHT TO LODGE A COMPLAINT (ART. 77 GDPR)

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority if you consider that we process your personal data in breach of the GDPR. The supervisory authority may in particular be the one in the Member State of your habitual residence, place of work or place of the alleged infringement. A list of the German supervisory authorities can be found, for example, on the website of the Federal Commissioner for Data Protection. https://www.bfdi.bund.de/EN/Service/Anschriften/anschriften_node.html

4. INFORMATION ON THE APPLICATIONS USED ON OUR SITE

COOKIES

Our web pages partly use what are known as cookies. Cookies do no harm to your computer and do not contain viruses. Cookies serve to make our offering more user-friendly, more effective and more secure. Cookies are small text files that are placed on your computer and stored by your browser.

Most of the cookies we use are what are known as “session cookies”. They are deleted automatically at the end of your visit. Other cookies remain stored on your device until you delete them. These cookies enable us to recognise your browser on your next visit.

You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when the browser is closed. If cookies are deactivated, the functionality of this website may be limited.

Cookies that are required to carry out the electronic communication process or to provide certain functions you have requested are stored on the basis of Article 6(1)(f) GDPR. The website operator has a legitimate interest in storing cookies for the technically error-free and optimised provision of its services. Where other cookies are stored (e.g. cookies for analysing your browsing behaviour), these are dealt with separately in this privacy policy.

COOKIE CONSENT

The first time you visit our website, a notice appears in which you decide whether, in addition to the technically necessary cookies, cookies for reach measurement may also be set. There are two categories:

Essential covers exclusively those technically necessary operations without which the website does not work. This category cannot be deselected; the legal basis is Article 6(1)(f) GDPR.

Statistics covers Google Analytics and Google Ads (see section 5). These services are only loaded after you have given your consent. Without your consent, no connection to Google servers is established and no cookie belonging to these services is set. The legal basis is your consent pursuant to Article 6(1)(a) GDPR in conjunction with Section 25(1) TDDDG.

We store your decision in a cookie named ne_cookie_consent on your device. It contains the time of your decision, the version of the notice and the categories you selected. The storage period is 180 days; after that you will be asked again.

You may withdraw your consent at any time with effect for the future. To do so, delete the cookie named above in your browser or open the notice again. The lawfulness of the processing carried out up to the withdrawal remains unaffected.

SERVER LOG FILES

The provider of these pages automatically collects and stores information in what are known as server log files, which your browser transmits to us automatically. These are:

browser type and browser version
operating system used
referrer URL
host name of the accessing computer
time of the server request
shortened IP address

This data is not merged with other data sources.

The basis for the data processing is Article 6(1)(f) GDPR, which permits the processing of data for the performance of a contract or pre-contractual measures.

CONTACT FORM

If you send us enquiries via the contact form, the details you provide in the enquiry form, including the contact data you give there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We do not pass this data on without your consent.

The processing of the data entered into the contact form therefore takes place exclusively on the basis of your consent (Article 6(1)(a) GDPR). You may withdraw this consent at any time. An informal message by e-mail to us is sufficient. The lawfulness of the data processing operations carried out up to the withdrawal remains unaffected.

The data you enter in the contact form remains with us until you ask us to delete it, withdraw your consent to its storage, or the purpose for storing the data no longer applies (e.g. after your enquiry has been dealt with). Mandatory statutory provisions — in particular retention periods — remain unaffected.

DATA PROTECTION FOR JOB APPLICATIONS

If you send us application documents via our website or by e-mail, we process the personal data for the purpose of carrying out the application procedure. If no employment contract is concluded between you and us, we delete the application documents six months after the rejection decision has been announced, provided that no other legitimate interests prevent deletion. Such a legitimate interest is, for example, a duty to provide evidence in proceedings under the German General Equal Treatment Act (AGG). If an employment contract is concluded, we process the personal data for the purpose of carrying out the employment relationship; you will then be informed separately again pursuant to Article 13 GDPR when the contract is concluded.

5. ANALYTICS AND ADVERTISING

GOOGLE ANALYTICS

This website uses functions of the web analytics service Google Analytics. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses what are known as “cookies”. These are text files stored on your computer that enable an analysis of your use of the website. The information generated by the cookie about your use of this website is generally transmitted to a Google server in the USA and stored there.

Google Analytics is only loaded after you have consented to the “Statistics” category in the notice. The legal basis is your consent pursuant to Article 6(1)(a) GDPR in conjunction with Section 25(1) TDDDG. Without this consent the script is not embedded, no cookies belonging to this service are set, and no connection to Google servers is established. You may withdraw your consent at any time with effect for the future.

IP anonymisation

We have activated the IP anonymisation function on this website. As a result, your IP address is shortened by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with further services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.

Browser plug-in

You can prevent the storage of cookies by setting your browser software accordingly; please note, however, that in this case you may not be able to use all functions of this website to their full extent. You can also prevent the collection of the data generated by the cookie and relating to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Objection to data collection

You can withdraw your consent at any time by deleting the cookie ne_cookie_consent in your browser. The next time you visit, the notice will appear again and you can choose “Essential only”. Google Analytics will then no longer be loaded.

More information on how Google Analytics handles user data can be found in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.

Processing on our behalf

We have concluded a data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

GOOGLE ANALYTICS REMARKETING

Our websites use the functions of Google Analytics Remarketing in conjunction with the cross-device functions of Google Ads and Google DoubleClick. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

This function makes it possible to link the advertising target groups created with Google Analytics Remarketing to the cross-device functions of Google Ads and Google DoubleClick. In this way, interest-based, personalised advertising messages that have been adapted to you depending on your previous usage and browsing behaviour on one device (e.g. a mobile phone) can also be displayed on another of your devices (e.g. a tablet or PC).

If you have given the relevant consent, Google will link your web and app browsing history to your Google account for this purpose. In this way, the same personalised advertising messages can be served on every device on which you log in with your Google account.

To support this function, Google Analytics collects Google-authenticated IDs of users, which are temporarily linked to our Google Analytics data in order to define and create target groups for cross-device display advertising.

You can permanently object to cross-device remarketing and targeting by deactivating personalised advertising in your Google account; to do so, follow this link: https://www.google.com/settings/ads/onweb/.

The consolidation of the collected data in your Google account takes place exclusively on the basis of your consent, which you may give or withdraw with Google (Article 6(1)(a) GDPR). For data collection operations that are not consolidated in your Google account (for example because you do not have a Google account or have objected to the consolidation), the collection of the data is based on Article 6(1)(f) GDPR. The legitimate interest arises from the fact that the website operator has an interest in the anonymised analysis of website visitors for advertising purposes.

Further information and the privacy provisions can be found in Google’s privacy policy at: https://www.google.com/policies/technologies/ads/.

GOOGLE ADS AND GOOGLE CONVERSION TRACKING

This website uses Google Ads. Google Ads is an online advertising programme of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).

Within the framework of Google Ads we use what is known as conversion tracking. When you click on an advertisement placed by Google, a cookie for conversion tracking is set. Cookies are small text files that the internet browser places on the computer of the user. These cookies expire after 30 days and are not used to identify users personally. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognise that the user clicked on the advertisement and was forwarded to this page.

Every Google Ads customer receives a different cookie. The cookies cannot be tracked across the websites of Ads customers. The information obtained with the help of the conversion cookie is used to compile conversion statistics for Ads customers who have opted for conversion tracking. Customers learn the total number of users who clicked on their advertisement and were forwarded to a page with a conversion tracking tag. However, they do not receive any information that personally identifies users. If you do not wish to take part in tracking, you can object to this use by easily deactivating the Google conversion tracking cookie in your internet browser under user settings. You will then not be included in the conversion tracking statistics.

Conversion cookies are stored on the basis of your consent pursuant to Article 6(1)(a) GDPR in conjunction with Section 25(1) TDDDG. Without consent to the “Statistics” category, Google Ads is not loaded.

More information on Google Ads and Google conversion tracking can be found in Google’s privacy provisions: https://policies.google.com/privacy?hl=en.

About us

In Estepona we have found a place with a special quality of life. The climate, the Spanish culture, a variety of leisure activities and an international community offer a unique attitude to life throughout Europe.

With many decades of real estate experience our team will find the right property for you. From the first contact through all administrative procedures to the final notary appointment we are a reliable partner on your side.

Do you have any questions?

We are also happy to be there for you personally:

Christiane Tiebel
+49 160 92607358
info@newEstepona.com

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