Privacy Policy

This is the privacy notice of ‘Estepona Marina Properties S.L.’.  In this document, “we”, “our”, or “us” refer to Estepona Marina Properties S.L.’.

We are Estepona Marina Properties S.L.. Our company number is B92394204 registered in Spain.

Our registered office is at:

Estepona Marina Properties S.L., Avenida Del Carmen 45, Marina Bay, Estepona 29680, Malaga, Spain.

Introduction

  1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, ‘process’ means collect, store, transfer, use or otherwise act on information.
  2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
  3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
  4. We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.
  5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
  6. The law requires us to tell you about your rights and our obligations to you regarding the processing and control of your data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
  7. Except as set out below, we do not share, sell, or disclose to a third party, any information collected through our website.

The basis on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information and to notify you of the basis for each category.

If the basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

Information we process because we have a contractual obligation to you

When you create an account on our website, buy or rent a property from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. 

To carry out our obligations under that contract, we must process the information you give us. Some of this information may be personal information. 

The personal information we collect and store is limited to that shown on our order confirmations and invoices, as follows:

  • Your name and address
  • Your telephone number
  • Your email address
  • Your payment reference and method
  • A list of the properties you purchased or rented from us
  • An indicator to show if you have opted into our mailing list.

If you have opted into receiving our occasional emails but have not purchased anything from us or sold anything to us, the only personal information we store is your name and email address.

We may use this information to:

  1. Verify your identity for security purposes
  2. Sell or rent properties to you
  3. Provide you with our services
  4. Provide you with suggestions and advice on products, services and how to obtain the most from using our website

Personal information is stored electronically with encrypted passwords to prevent unauthorised access. Any personal information in the form of printed copies of sales orders and invoices is kept in a secure storage facility.

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example, to monitor our performance concerning a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including our products and services, you provide your consent to us to process information that may be personal.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example, to monitor the performance of a particular page on our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us via our Contact Us page or email at jane@esteponamarinaproperties.com. However, if you do so, you may not be able to use our website or our services further.

Information we process for legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, in doing so.

Where we process your information on this basis, we do so after having given careful consideration to:

  • whether the same objective could be achieved through other means
  • whether processing (or not processing) might cause you harm
  • whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for:

  • record-keeping for the proper and necessary administration of our business
  • responding to unsolicited communication from you to which we believe you would expect a response
  • protecting and asserting the legal rights of any party
  • insuring against or obtaining professional advice that is required to manage a business risk
  • protecting your interests where we believe we must do so

Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Specific uses of information you provide to us

Information provided on the understanding that it will be shared with a third party

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

Examples include:

  1. Payment service providers who process your bank details
  2. Owners of properties for sale or rent
  3. Posting a message on our forum
  4. Tagging an image
  5. Clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared.

We do store it, and we reserve the right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Our third-party data processors are:

  1. Google Analytics, is a provider of user interaction tracking software, based in the United States.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion, we may agree to your request to delete the personal information that you have posted. You can request by contacting us via our Contact Us page or email at jane@esteponamarinaproperties.com

Complaints regarding content on our website

We attempt to moderate user-generated content, but we are not always able to do so as soon as that content is published.

If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

Sending a message to our support team

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us to reply with the information you need.

We record your request and our reply to increase the efficiency of our business

We keep personally identifiable information associated with your messages, such as your name and email address to be able to track our communications with you to provide a high-quality service.

Complaints

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

Affiliate and business partner information

This is information given to us by you in your capacity as an affiliate of us or as a business partner.

It allows us to recognise visitors that you have referred to us, and to credit you commission due for such referrals. It also includes information that allows us to transfer the commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and the terms of our relationship.

We expect any affiliate or partner to agree to reciprocate this policy.

Information we collect through automated systems

Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

If you choose not to use cookies or prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

  1. To track how you use our website
  2. To record whether you have seen specific messages we display on our website
  3. To keep you signed in on our site
  4. To record your answers to surveys and questionnaires on our site while you complete them
  5. To record the conversation thread during a live chat with our support team

You can find more information about cookies at:

The cookies used on this website have been categorised based on the categories found in the ICC UK Cookie guide.

Category 1: strictly necessary cookies

These cookies are essential to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services, you have asked for, like shopping baskets or e-billing, cannot be provided.

By using our website, you agree that we can place these types of cookies on your device.

Category 2: performance cookies

These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

By using our website, you agree that we can place these types of cookies on your device.

Category 3: functionality cookies

These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

By using our website, you agree that we can place these types of cookies on your device.

Category 4: targeting cookies or advertising cookies

These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organizations.

By using our website, you agree that we can place these types of cookies on your device.

No targeting or advertising cookies are currently used on this website.

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in the aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website to be able to serve you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Disclosure and sharing of your information

Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up of your personal information from third parties whose services we use.

No such information is personally identifiable to you.

Third-party advertising on our website

Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.

They may also use other technology such as cookies or JavaScript to personalise the content of and to measure the performance of their adverts.

We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

Data may be processed outside the European Union

Our websites are hosted in The United Kingdom.

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly, data obtained within the UK, Spain or any other country could be processed outside the European Union.

For example, some of the software our website uses may have been developed in the United States of America or Australia.

We use the following safeguards concerning data transferred outside the European Union:

  1. The data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union.
  2. We comply with a code of conduct approved by a supervisory authority in the European Union.

Access to your information

Access to your personal information

  1. At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
  2. To obtain a copy of any information that is not provided on our website you may send us a request via our Contact Us page or via email at jane@esteponamarinaproperties.com. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

Removal of your information

If you wish us to remove personally identifiable information from our website, you must contact us via our Contact Us page or email at jane@esteponamarinaproperties.com

This may limit the service we can provide to you.

Verification of your information

When we receive any request to access, edit or delete personally identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters

Use of site by children

  1. We do not sell products or provide services for purchase by children, nor do we market to children.
  2. If you are under 18, you may use our website only with consent from a parent or guardian
  3. We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
  4. Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity in your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust marks in your browser’s URL bar or toolbar.

How you can complain

  1. If you are not happy with our privacy policy or if have any complaints then you should tell us via our Contact Us page or email at jane@esteponamarinaproperties.com
  2. You can find further information about our complaint handling procedure on our Terms & Conditions page.
  3. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
  4. If you are in any way dissatisfied with how we process your personal information, you have a right to complain to the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

  1. To provide you with the services you have requested
  2. To comply with other laws, including for the period demanded by our tax authorities
  3. To verify a customer’s product warranty claim
  4. To support a claim or defence in court

AEAT rules require us to keep records for at least 4 years after the January tax return submission date. To make sure we comply, we keep sales and purchase invoices for 5 years before deleting or destroying them.

If you have opted into our mailing list you may request that your email address be removed from the list at any time. If we have not had any contact with you for 5 years, all your data will automatically be deleted including your entry in our mailing list.

Compliance with the law

Our privacy policy has been compiled to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we would like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any questions regarding our privacy policy, please contact us via our Contact Us page or email at jane@esteponamarinaproperties.com.

This policy is effective from November 2024.

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