Valid from August 17, 2022.

Controller and your rights as data subject

Responsible Entity

The entity responsible (Controller) for the data processing regulated in this Privacy Policy is “CITY BROKER ACTIVOS, S.L.” (hereinafter “we” or “us”). Our contact details are:

José Luis Martínez

Calle Hermosilla Numero 46 Primero Izquierda. 28001 MADRID

jlm@cityholding.es

Engel & Völkers GmbH

Your rights as a data subject

You have the right to information about the processing of your personal data (for example, the origin of the data, the purpose of the processing and the methods of data processing). In addition, you have the right to object to the future processing of your data, as well as to restrict the use or deletion of such data, under certain conditions. Finally, you can stop the sending of advertising material or the carrying out of market research or commercial communications at any time.

In summary, you have the right to:

Information,

Correction,

Deletion (or request to be forgotten),

Restriction of processing,

Data portability,

Object to the processing of your personal data,

Complaint to supervisory authorities.

In addition, you have the right to object at any time to the processing of your personal data for direct marketing purposes. If you object to processing for direct marketing purposes, we will no longer process your personal data for these purposes.

In accordance with Art. 7 III of the EU General Data Protection Regulation (hereinafter "GDPR"), you may revoke your initial consent to us at any time. Once consent is revoked, we will no longer continue to process the data.

Please note that your right to deletion of your data is subject to certain restrictions. For example, we are not obliged to delete data that we are obliged to retain due to statutory retention periods. Data that we need to assert, exercise or defend due to legal claims is also excluded from your right to deletion.

If you have a complaint about the way we process your data, you can appeal to a supervisory authority, in particular in the member state of your residence, place of work or the place of the alleged infringement.

We reserve the right to disclose information about you if required to do so by law enforcement agencies or other legal authorities. Legal basis: Art. 6 I sentence 1 lit. c GDPR (legal obligation).

___________________________________________________________________________________________

Overview of our data processing procedures

Our privacy policy is structured as follows and provides you with an overview of the following data processing procedures:

Visit our company's web presence on the Internet

You conclude a search request or marketing contract with us, request an exhibition from us or have a property appraisal from us.

We search for a property for you together with another Engel & Völkers (Recommendation)

You are applying on your own initiative or in response to a job offer

Storage and deletion of your data

Collection and processing of personal data when visiting our corporate web presence on the Internet

We only process personal data if personal data is sent to us via the contact forms on our corporate web presence. In this regard, personal data is only processed if you have given us your explicit consent to the processing of your data or if the processing is permitted by legal provisions. For certain services that we offer on our corporate web presence, we require a minimum amount of data. We have marked mandatory information with an "asterisk". Without the mandatory information, we cannot provide our services.

What data of yours (hereinafter "you" or "user") do we process?

In the context of your use of our company's web presence, we process the following personal data:

The email address, first name, last name, title, address, telephone number and real estate data that you provide to us in the case of services offered on our company's web presence, for example in the context of contact inquiries and newsletter dispatch, as well as a determination of the market price (valuation) - hereinafter "Data" or "Personal Data".

__________________________________________________________________________________________

Please refer to the description of data processing related to the use in connection with the use of cookies and other tracking technologies in the "Cookie Policy" of:

Engel & Völkers GmbH

Vancouverstraße 2a

D-20457 Hamburg

Germany

Email: info@engelvoelkers.com

You will find the Cookie Policy at the bottom of our company website.

Purpose of processing and legal basis for processing

We process your data for the following purposes:

Fulfillment of contact requests (legal basis is the fulfillment of the contract, as well as in case of transfer of user data to other license partners of the Engel & Völkers Group (for definition, see section 3 below) your consent);

If applicable, in order to fulfill a property valuation request as described by the user, as well as the implied interest in the sale of the property as presented by the valuation request (legal basis is (a) the fulfillment of the contract, as well as, (b) your consent in case we need to share your contact data with (i) a suitable license partner Spanish: partner of the Engel & Völkers Group based on experience or geographic location (for definition see section 3 below) or (ii) to the company that technically implements the evaluation and (c) the legitimate interest in marketing our services or your consent in the case of the use of your contact data for direct marketing);

Telephone contact by us (legal basis is the fulfillment of the contract or, in the case of the use of the telephone number for advertising purposes, your consent);

Sending an e-mail newsletter with our offers as well as our own and third-party advertising to the extent permitted by law or based on consent (the legal basis is your consent or our legitimate interest in direct marketing, provided that the marketing is carried out in accordance with the requirements of data protection and competition law)

In summary:

The legal basis for the processing of personal data is Art. 6 I, sentence 1 lit. a GDPR if the processing is based on consent, Art. 6 I, sentence 1 lit. b GDPR if the basis for processing is a contractual (or, where applicable, pre-contractual) relationship and Art. 6 I, sentence 1 lit. f GDPR if the basis is our legitimate interest. If the processing of personal data is necessary for compliance with a legal obligation to which we are subject, Art. 6 I, sentence 1, letter c of the GDPR serves as the legal basis.

If the legal basis is your consent, you have the right to revoke your consent at any time without affecting the lawfulness of the processing of your personal data carried out on the basis of consent until revocation. If the legal basis is legitimate interest, you also have the right, as a rule, to object at any time to the processing of personal data concerning you for reasons arising from your particular situation. In this respect, Art. 21 of the GDPR applies.

Disclosure of your personal data

We will only pass on your personal data to third parties if this is necessary for the performance of the contract, if the third party or we have a legitimate interest in the transmission, if there is a legal obligation or if you have given your consent. If data is passed on to third parties on the basis of legitimate interest, this will be explained in this Privacy Policy.

If your contact request concerns offers from other companies in the Engel & Völkers Group, we will transfer the personal data you have entered in this case to the relevant company in the Engel & Völkers Group with your prior consent or, if permitted by law, on the basis of a so-called legitimate interest. We will not pass on your personal data beyond this.

When we refer to the "Engel & Völkers Group" in this Privacy Policy, we mean the companies that belong to the Engel & Völkers group of companies in accordance with §§ 15ff. AktG (German Stock Corporation Act) as well as the (principal) license partners who are directly or indirectly contractually affiliated with this group of companies and to which we also belong. A current overview of these license partners can be found here: https://www.engelvoelkers.com/en-de/company/locations/).

Data transfer to non-EEA countries

In addition to the above paragraph "Disclosure of your personal data", the following applies:

Recipients of the personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which the personal data is transferred ensures an adequate level of protection (Article 45 GDPR) or because the transfer is subject to adequate safeguards (e.g. standard contractual clauses) as agreed between the European Union and the recipient of the data (Article 46 GDPR), unless the GDPR provides for an exception (Article 49 GDPR). In addition, where necessary, we intend to agree additional measures with recipients to ensure an adequate level of data protection. Copies of the appropriate safeguards (where we rely on them) and a list of recipients outside the EEA/UK are available on request. Please note that these copies may be redacted to the extent necessary to protect trade secrets or other confidential information.

You enter into a search or marketing contract with us, request a property exhibition from us or commission us to carry out a property valuation.

  What data do we process about you?

When searching for, selling or renting a property, requesting a property exhibition or evaluating a property, we regularly process the following personal data about you:

First name, surname, title, address, telephone number and, in the case of a property search, the data of the desired property or, in the case of a property marketing or property valuation, the data of the valued property;

Email address: provided that you have agreed to receive promotional information, in particular the offer or valuation of properties, or wish to receive communications by email;

In the case of purchase/sale or rental of a property, bank details, identity data, copy of the ID (in the case of purchase/sale of a property), as well as the property register, electricity, gas and/or oil bills, detailed general invoices, partition declarations, WEG minutes (resolutions) and/or sales contract (in the case of sale of a property) or in the case of rental of a property, bank details, identity data, CV if applicable, proof of salary, proof of solvency, confirmation from the landlord and/or lease agreement.

Purpose of processing and legal basis

We process personal data for the following purposes:

Fulfillment of the contractual relationship or a pre-contractual legal relationship, also by independent real estate agents cooperating with us, including billing and credit assessment (legal basis is Art. 6 I lit. b GDPR as well as Art. 6 I lit. f GDPR; our legitimate interest in connection with the transfer of data to independent real estate agents arises from the freedom of choice to also fulfill contractual relationships with independent brokers or sub-brokers. The legitimate interest in carrying out credit checks arises from the legitimate interest in protecting against credit losses);

Compliance with a legal obligation, in particular in connection with the anti-money laundering law (legal basis is Art. 6 I, letter c, GDPR);

Advertising information about real estate that we or other license partners of the Engel & Völkers Group market (legal basis is Art. 6 I, letter f GDPR; we have a legitimate interest in processing personal data for direct advertising. The legal basis is also your consent in accordance with Art. 6 I, letter a GDPR if the advertising information is sent to you by email, fax or telephone).

If the legal basis is your consent, you have the right to revoke your consent at any time without affecting the lawfulness of the processing carried out on the basis of consent until revocation. If the legal basis is legitimate interest, you also have the right to object at any time to the processing of your personal data for reasons arising from your particular situation. In this respect, Art. 21 GDPR applies.

Disclosure of your personal data

If your enquiry (e.g. in the context of an evaluation request) concerns offers from other license partners of the Engel & Völkers Group, we will pass on the personal data you have entered to the relevant company of the Engel & Völkers Group after your prior consent.

For further information, please refer to the information on referrals in Section III.

In addition, we pass on your data to contractual partners (landlords, landlords, search clients) and support service providers such as notaries, lawyers, property managers and real estate developers as part of the processing of a contractual relationship, as well as in the context of credibility reporting or to supervisory authorities (e.g. for money laundering documentation). We may also transfer your data to third parties to the extent permitted by law. Third parties to whom we may disclose your personal data, independently of our performance, include external advisors (e.g. lawyers and auditors), public authorities within their jurisdiction to comply with legal obligations and/or protect our rights (e.g. tax authorities, police, prosecutors, courts), potential buyers or acquirers of all or part of our assets and/or activities, and other third parties when you instruct us to disclose data or give your consent to do so.

Apart from that, we will only share your personal data with staff (permanent staff, such as employees and freelance real estate consultants) and third-party companies (e.g. IT service providers, hosting providers, etc.) to whom we have subcontracted services involving processing operations under a contract processing agreement.

Transfer of data to non-EEA countries

In addition to the above paragraph "Disclosure of your personal data", the following applies:

Recipients of the personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which the personal data is transferred ensures an adequate level of protection (Article 45 GDPR) or because the transfer is subject to appropriate safeguards (e.g. standard contractual clauses) as agreed between the European Union and the recipient of the data (Article 46 GDPR), unless the GDPR provides for an exception (Article 49 GDPR). In addition, where necessary, we intend to agree additional measures with recipients to ensure an adequate level of data protection. Copies of appropriate safeguards, where we rely on them, and a list of recipients outside the EEA/UK are available on request. Please note that these copies may be redacted to the extent necessary to protect trade secrets or other confidential information.

If your enquiry concerns Engel & Völkers license partners outside the European Union, we will pass on your data to the local/subject-related license partner with your consent.

We are looking for a property for you together with another Engel & Völkers license partner (Referral).

If we are looking for a property for you together with another license partner, your data will only be passed on with your prior consent. Please note that both we, as your initial contact, and the license partner of the Engel & Völkers Group to whom your data is provided process your personal data. Both we and this license partner are independently responsible for the respective data processing. This other license partner and we do not have access to each other's data and do not process your data jointly. If you wish to assert your rights as a data subject, please check in advance whether you wish to do so against us or against the other licensee partner of the Engel & Völkers Group, the Völkers Group, which also processes your data.

In the information above, you can find out how we process your data in connection with the marketing of your property, what rights you have in this context and who your contact persons are if you wish to assert your rights as a data subject.

You apply on your own initiative or in response to a job offer

What data do we process about you?

If you apply via our website or a job offer, we process your name as well as your address, telecommunications and application data. The provision of your address and telecommunications data, which is stipulated as mandatory information, is necessary in order to contact you regarding your application and to be able to assign the application to you.

Purpose of processing and legal basis

We process your personal data for the following purposes:

● To check the application for an employment relationship in our company (legal basis is Art. 6 I lit. GDPR, if applicable in conjunction with § 26 BDSG (for the scope of application of the Federal Republic of Germany)).

● Defence against possible legal claims imposed on us as a result of the application process, if necessary (the legal basis for this is our legitimate interest in fulfilling our obligation to provide evidence in proceedings pursuant to the General Equal Treatment Act (AGG); Art. 6 I lit. f GDPR).

● In addition, we process your personal data on the basis of prior consent in order to inform you about possible job offers (the legal basis is Art. 6 I lit. a GDPR).

If the legal basis is your consent, you have the right to revoke your consent at any time without affecting the legality of the processing carried out on the basis of consent until revocation. If the legal basis is legitimate interest, you also have the right to object at any time to the processing of your personal data for reasons relating to your particular situation. In this respect, Art. 21 GDPR applies.

We need your personal data to fulfill the processing purposes listed above. You are free not to disclose any personal data to us. In this case, you will not be able to participate in the application process for vacant positions.

Disclosure of your data

We will only pass on your personal data to third parties if this is necessary for the performance of the contract, if we or the third party have a legitimate interest in the disclosure, if there is a legal obligation or if you have given your consent. If data is passed on to third parties on the basis of a legitimate interest, this will be explained in this Privacy Policy.

If you have applied via the global online job portal of Engel & Völkers Holding GmbH, Engel & Völkers Holding GmbH has transmitted your application documents to us. The manner in which Engel & Völkers Holding GmbH processes your personal data is described during the application process and can be viewed at any time via the global online job portal on the relevant Engel & Völkers Holding GmbH website.

Transfer of data to countries outside the EEA

In addition to the above paragraph "Disclosure of your personal data", the following applies:

Recipients of the personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which the personal data is transferred ensures an adequate level of protection (Article 45 GDPR) or because the transfer is subject to adequate safeguards (e.g. standard contractual clauses) as agreed between the European Union and the recipient of the data (Article 46 GDPR), unless the GDPR provides for an exception (Article 49 GDPR). In addition, where necessary, we intend to agree additional measures with recipients to ensure an adequate level of data protection. Copies of the appropriate safeguards (where we rely on them) and a list of recipients outside the EEA/UK are available upon request. Please note that these copies may be redacted to the extent necessary to protect trade secrets or other confidential information.

Storage and deletion of your data

We retain your personal data for as long as necessary to achieve the purposes for which it is collected, including any retention period required by law (e.g. retention of accounting records).

In the context of application procedures that end without employment, your data is stored for six months for the purpose of documentation and then deleted or destroyed, including any additional documents provided to us in connection with the application process.

In the event that you provide us with your express consent to retain your data for future applications, we will retain the relevant data for a longer period of time.