Who is the Data Controller of your data?
The controller of the data processing relating to the different procedures used in the management of website visitors, customers and vendors is 1810 Capital Investments, with registered office in Madrid, C/ Suero de Quiñones 34 – 36, 1º, 28002, and VAT number B-86306818. The company is registered in the Companies Register of Madrid, Volume 29.363, Sheet 109, Section 8, Page M-528554, Entry 1.
For the purposes of our data protection policy, the contact e-mail is email@example.com.
What kind of data do we have about you and how have we obtained them?
The categories of personal data that 1810 Capital Investments processes about its customers and vendors are:
Identification data, their postal or electronic addresses, commercial information and economic and transaction data, professional data and data complying with prevention of Money Laundering and Terrorist Financing regulations.
All the aforementioned data we have obtained either directly from you through the submission of a contact form or through the presentation of a commercial offer or contractual proposal or through your company on providing us with identification data and other information needed to fulfil the purpose of the relevant contractual relationship between the parties. In the event of any changes in the data, you or your company are obligated to provide us with an update.
For what purpose do we process your data?
At 1810 Capital Investments we process the data provided by you to manage different activities relating to sales, after sales services, vendor management, service quality, etc. In this way, we will use your data to carry out some of the following actions:
To send the information requested through the contact form on our website or any other means of contact with our company, to provide both potential customers and our customers with product and service offers of interest, to perform the administrative, fiscal and accounting management of our customers and/or vendors, to carry out the necessary formalities for compliance with prevention of Money Laundering and Terrorist Financing obligations, to manage the rights of data subjects with regard to data protection, formalities relating to procurement with customers and to manage relations, advertising and marketing with customers and potential customers.
We will not prepare commercial profiles based on the information provided and consequently neither will we make automated decisions about you based on commercial profiling.
How long will we retain your data?
Personal data on individuals linked to potential customers, customers and vendors that 1810 Capital Investments collects through the different contact and/or information collection forms will be retained as long as their erasure is not requested by the data subject. The personal data provided by our customers and vendors will be retained as long as the commercial relationship between the parties is maintained, abiding in all cases by the minimum statutory retention periods according to the subject matter.
In any case, 1810 Capital Investments will keep your personal data for a period of time that is reasonably necessary, taking into account our needs to respond to matters that may arise or to solve problems, make improvements, activate new services and meet applicable legal requirements. This means that we can retain your personal data for a reasonable period of time even after you have stopped using our products or have stopped using this website. After this time, your personal data will be deleted from all 1810 Capital Investments systems.
What is the legal basis for processing your data?
We summarise below the legal basis for this data processing, according to its type:
When the data processing relates to accounting management and billing management with customers and/or vendors, the legal basis is the maintenance, development and control of the contractual relationship between the parties.
When the data processing relates to tax management, such as application of withholdings, rebates, etc., the legal basis is the maintenance, development and control of the contractual relationship between the parties and compliance with legal obligations.
When the data processing relates to administrative formalities, such as the management of logistics, the warehouse, customer deliveries, goods reception, etc., the legal basis is the maintenance, development and control of the contractual relationship between the parties.
When the data processing is marketing related, we carry out commercial actions with regard to our products or services targeted at our customers or any persons who have requested related information from us in the past, including conducting customer satisfaction surveys. In these cases, the legal basis is the freely given, unambiguous consent of the data subjects themselves (potential customers), making them state for the record that under no circumstances does withdrawal of this consent affect the enforcement of any agreement in place between the parties or the legitimate interest of the company in promoting and commercialising products or services similar to those acquired or requested by the data subjects in the past.
When the data processing relates to management of the prevention of Money Laundering and Terrorist Financing, the legal basis is the freely given, unambiguous consent of the data subject and the legal obligation in accordance with applicable laws and regulations on the prevention of Money Laundering and Terrorist Financing.
When the data processing relates to management of the rights of data subjects with regard to data protection, the legal basis is the legal obligation in accordance with applicable data protection laws and regulations.
When the data processing relates to procurement with customers, the legal basis is the preparation of a private purchase agreement and the subsequent deed engaging both parties.
When the data processing relates to the management of relations, advertising and marketing by the data processors with customers and potential customers, the legal basis is the legitimate interest of the data processor and the express consent of the data subject.
With respect to the aforementioned legal basis, you are obligated to provide your personal data; if you fail to do so, we cannot enforce your agreement or fulfil legal obligations or those resulting from public authority.
Who will your data be shared with?
1810 Capital Investments, as the data controller, will share the data submitted with third parties with which it has signed service vendor agreements. These third parties, who are data processors, carry out their duties in a manner regulated in agreements signed with 1810 Capital Investments, which set out in writing that the data processor will only process data in accordance with the instructions issued by the data controller, that it will not apply or use them for a purpose other than that set down in said agreement, nor will it share them, not even for their retention, with other people. It will never share personal data with any third company that intends to use them in its direct marketing actions, unless we have been explicitly authorised to do so.
Please take note that we may give your personal data to Government Agencies and competent authorities whenever 1810 Capital Investments receives an injunction from these authorities or whenever, acting in good faith, we believe that said action is reasonably necessary in order to comply with court proceedings, in order to answer any claim or legal action, or to protect the rights of 1810 Capital Investments or of its customers or of the public at large.
Likewise, your data may be shared with the Executive Service for the Prevention of Money Laundering (SEPBLAC) or Government Agencies, by legal imperative, in accordance with applicable regulations on the prevention of Money Laundering and Terrorist Financing.
Personal data will not be transferred to third countries.
1810 Capital Investments may share your personal data with third persons (e.g. Internet service providers that help us manage our website or carry out the services hired, IT support and maintenance firms, logistics companies, administrative, tax and accounting agencies, etc.). In any event, these third persons will maintain, at all times, the same security levels as 1810 Capital Investments with respect to your personal data and, whenever necessary, they will be bound by legal undertakings to store your personal data in a private and secure way and to only use the information according to the specific instructions of 1810 Capital Investments.
What are your rights as a data subject?
You have the right to obtain confirmation of whether 1810 Capital Investments is processing your personal data (right to access) and you are also entitled to amend these data (right to rectification).
You are entitled to request access to your personal data and to receive them in a commonly used and machine readable format if the processing is carried out by electronic means (right to data portability).
You may request restriction of the processing of your data (right to erasure), or in certain circumstances and on grounds relating to your particular situation, you may exercise your right to object to the processing of your personal data (right to objection).
1810 Capital Investments will cease the processing of data, except for compelling legitimate reasons or the exercise or defence of possible claims or in the exceptions set down in applicable regulations.
Likewise, please be advised that you are entitled to withdraw your consent at any time, without affecting the legality of the processing based on the consent given prior to its withdrawal.
Likewise, please take note that at any time you may exercise the aforementioned rights by sending an e-mail to firstname.lastname@example.org. You are also entitled to file a complaint with the Spanish Data Protection Agency, especially when you have not obtained satisfaction in the exercise of your rights.
Spanish Data Protection Agency
C/ Jorge Juan, 6
28001 – Madrid
Tel: 901100099 / 912663517
Pursuant to valid Regulation (EU) 2016/679, ASG HOMES PROPCORP, S.L.U. wishes to inform you that your personal data will be processed by reason of the legal basis and protection provided by your consent. By clicking on the “SEND” button, you agree to the processing of your personal data by 1810 Capital Investments.
Likewise, please be advised that except for any legal obligation or express consent on your part, 1810 Capital Investments will not transfer your data to third parties.
We also wish to inform you that at any time you may exercise the aforementioned rights of access, rectification or erasure of data, and enforce the other rights recognized in this document and regulated in Regulation (EU) 2016/679, by notifying 1810 Capital Investments, email@example.com. Furthermore, in accordance with the provisions of Information Society Services and E-Commerce Act 34/2002, of July 11, 1810 Capital Investments will not send advertising via e-mail without having previously obtained the explicit consent of the recipient. You may object to the sending of advertising by ticking the relevant box.
The personal data submitted by you to 1810 Capital Investments may be stored in automated databases or otherwise, of which it is the sole owner. 1810 Capital Investments implements all the technical, organisational and security measures that guarantee the non-disclosure, integrity and quality of the information contained there in accordance with the provisions of applicable data protection regulations.
Processing the personal data of minors
With respect to the processing of data of minors under the age of 14, data will always be collected with the explicit consent of parents or legal guardians.
Changes in our Privacy and Data Protection Policy
From time to time, 1810 Capital Investments may make changes and corrections to this section on the Data Protection Policy for Website Visitors, Customers and Vendors. Please check this section regularly to refer to any changes that may have been made and how they affect you.
Why is it necessary to agree to this Privacy and Data Protection Policy?
Through the deliberate sending of your personal data via our means of contact and/or via commencement of the commercial relationship with our company, we consider that you acknowledge and agree to the processing of your personal data as described in this policy. This personal information will only be used for the purposes you have provided it for or for those allowed by specific national or regional regulations.
In any case, please be advised that any refusal on your part to provide certain data requested could hinder the enforcement of the contractual relationship between the parties with possible serious consequences when it comes to providing the various services foreseen in the commercial agreement entered into with the contracting party.
If you have any questions regarding this section on the Personal Data Protection Policy for Potential Customers, Customers and Vendors of 1810 Capital Investments, please contact the company using the e-mail address provided and we will be happy to assist you and answer any further questions you may have.
Applicable laws and regulations
These conditions are governed at all times by the provisions of Spanish and European laws and regulations on the protection of personal data and privacy.