Privacy Policy

DATA PROTECTION POLICY

Accumin Holdco, S.L.U. (whose brand name is ACCUMIN) wishes to maintain a transparent relationship, informing you of how we collect and securely process any data you provide us with when using our services.

To this end, we have drawn up this Data Protection Policy (hereinafter the "Policy") which will enable our customers and/or service users to consult any information they may need or to clear up any doubts they may have about how we handle personal data.

This "Policy" applies to all the environments through which we interact with our customers and request personal data from them, in particular websites, e-mail or postal mail and telephone.

Accordingly, this "Policy" does not apply to third party websites, including those that may be accessed through a web link from our environments.

1. Data Controller

Accumin Holdco, S.L.U., hereinafter Accumin, NIF 87232633 and registered office at Calle José Echegaray nº 9, Las Rozas de Madrid, 28232 Madrid, is the Data Controller.

2. Whose personal data does this Policy apply to?

This privacy policy, in accordance with the personal data protection regulations, describes the processing, management and purpose for which the personal data of:

a) People who contact Accumin to request a quote and/or contract a service.

b) People who register as Users of the corporate website to contract a service offered on the WEBSITE or to request to receive commercial communications.

3.Through what sources do we collect personal data?

3.1. Directly from our customers or service users.

Accumin will collect personal data provided directly by our users/customers through the following sources:

a) Through the website:

We collect the personal data that you provide when you register, as well as the information derived from accessing and using the services that we offer on this website, and from your own browsing, such as (i) the data provided when registering; (ii) the data provided when using the services; (iii) the data derived from the communications that you have with us; (iv) data derived from your browsing, such as cookies (information about user preferences when you visit a website), links and system information, more details of which can be found in the Cookie Policy on our website; (v) any other data that you authorise us to process.

b) By email, telephone or in person:

We collect data provided by customers through our commercial or customer services and/or through external collaborators authorised to collect data from our customers as data processors, in particular our energy appraisers and certifiers,

4.What personal data we collect

4.1 Customer and User Data

We collect the data necessary for the management of the requested service, in particular:

(a) Identification data: Name and surname, NIF/CIF, Address, telephone, e-mail.

5. Purpose and Legitimation.

5.1 In general terms, the purpose of the processing will be to manage the request made through the website, either through the contact form or any other type of on-line form, or through a request by e-mail. Such a request may be, but is not limited to, the management of a request, answering a request for commercial information, managing a request for a quote, requesting duplicate invoices, finding out the status of a job in progress, reviewing reports already completed, applying for a job or, where appropriate, registering for Accumin newsletters, answering user queries and requests, as well as any other interaction between the website user and Accumin that tends to satisfy the user's needs. All the data requested is necessary in order to be able to deal with the request.

Accumin will process the personal data provided by its clients and users mainly to manage the preparation of estimates and/or the provision of the contracted service. The legitimacy is based on the execution of the contractual relationship and the application of pre-contractual measures.

If you have made a telephone call for security, integrity and quality of service reasons, the call will be recorded and the data will be kept by Accumin. The legitimate basis is Accumin's legitimate interest in guaranteeing and keeping record of the accuracy and integrity of the information provided by this means, as well as guaranteeing the quality of the service. Due to the fact that the reception, transmission and execution of customer orders made by telephone entails the need to keep these recordings in order to guarantee the integrity of the information linked to a specific date, avoiding errors and misunderstandings that could be detrimental to the parties. Legitimate interest is also based on the need to prove a conversation in legal proceedings, as evidence in court, in the event of litigation between the parties.

5.2. If you have contracted a service with us and are therefore our client, we may use your data for the purpose of sending you by e-mail promotional information from the company in relation to services similar to the one you have contracted. The processing will be carried out in compliance with the provisions of Law 34/2002, of 11 July, on information society services and electronic commerce. The sending of information about the company's activity is legitimised by the legitimate interest of Accumin, which is responsible for the processing, and the customer can express their opposition to this type of processing at any time, without the exercise of this right conditioning the maintenance or termination of the contractual relationship that links them to the company.

5. 3 If you have expressly accepted to receive commercial and advertising communications (promoting our products, sending you reports and studies prepared by our companies, inviting you to participate in real estate conferences and meetings, presentation of reports, participation in draws organised by our company.... ), by ticking the corresponding boxes, we will process your data for this purpose, by means of drawing up a commercial profile based on the information provided and by means of automated processing, without in any case the withdrawal of this consent conditioning the execution of the contract or the provision of the services that you may have contracted. The legitimacy of the processing will be based on your express consent, although you may revoke it at any time.

5.4 If you have registered as a Website User, we will process your data to create and manage your Website User account, to facilitate the provision of the Online Services you request, and to compile statistics on the usability of our Online Services. The applicable legal basis in this case is the express consent you give for the management of your registration as a user of the website and the execution of a contract, in the event that you contract any of our services.

6.How long we keep your data

6.1 If you are our client and we have provided you with a service, we inform you that the data provided will be kept for the management of the services and for the period of time necessary to (i) verify prior to accepting an assignment whether a report on the same object has been issued previously and thus avoid possible situations of conflicts of interest that are related to the service that has been provided to you, (ii) for compliance with the legal obligations to which we are subject, (iii) as well as to respond to queries or complaints that you or a third party may make to us.

6.2 In the event that our contracting proposal is not finally accepted by you, we inform you that we will keep your data for a period of 24 months for the purpose of verifying special situations of conflicts of interest, as well as to have your data available for future offers or for the fulfilment of any other purposes and processing that you have consented to.

6.3. If you have registered as a User of our website, we will store your personal data for the purpose of facilitating new contracts for our services. However, if we detect that you have not used or interacted with your account or any of our online services for a period of two years, we will proceed to cancel your user account by blocking your data.

6.5 If you have expressly consented to receive commercial information, we will keep your data for this purpose until such time as you unsubscribe from the service.

6.6 In any case, we remind you that you have the right to cancel your personal data at any time.

7.With whom we share your data.

Accumin may share your data in the cases necessary for the strict and exclusive fulfilment or satisfaction of the aforementioned purposes, or for any other purpose necessary for the correct development of the relationship with you or justified in Accumin's legitimate interest, as well as in the cases provided for by law. In particular, we may provide access to or communicate your personal data without the owner's consent in the following cases:

a) With the Courts and Tribunals, State Security Forces and Corps and with other Administrative Authorities, especially the Bank of Spain, CNMV, Public Treasury, or any other authority, when we understand that we may be legally required to do so.

b) With Accumin's third party data processors that perform functions on our behalf (including external consultants and professional advisors, accountants, auditors, IT providers that develop our technological systems or guarantee their security and other data processors) when the correct provision of the service requires access to our clients' personal data, with whom Accumin will sign the corresponding contract regulating the obligations of each of these data processors in order to guarantee the security of their data.

c) We may also share your data with Accumin group companies for internal administrative purposes. The list of group companies that may access your data, you can find it on this website in the CONTACT section.

8. International Data Transfer

Accumin belongs to a multinational group, so in order to fulfil the purposes set out in this "Policy", as well as for internal administrative purposes, it is possible that your personal data may be accessed from one of the companies in the GROUP. You can access the updated list of companies at the end of the document.

These companies are located in different countries, some of which are located outside the European Economic Area (EEA), as in the case of a processing order provided by one of the companies of the group, located in Mexico, which could process your data in the event that you contact them outside the hours established in Spain, in order to provide you with a service on an ongoing basis, in the position of processing processor of the organisation. The legal basis is the signature of the standard contractual clauses approved by the European Commission.

However, in the event that we transfer Personal Data to countries or territories that do not offer a level of protection comparable to that of the EU, we will establish the necessary technical and legal measures to guarantee the security and legitimacy of the international transfer, as well as the appropriate confidentiality and secrecy of the data transferred. In this regard, we inform you that Accumin uses the services of third partyproviders that involve international transfers to the United States, a country that guarantees a level of protection equivalent to that of the European Union for personal data transferred from Europe to third party providers in the United States that are members of the Data Privacy Framework (https://www.dataprivacyframework.gov/s/), which includes these providers.

Having clarified the above, if you wish, you may request additional information on the specific protection measures and guarantees applied by Accumin to the export of your Personal Data to countries without a comparable level of protection, as well as on the specific locations of the companies that may have access to your personal data in compliance with the aforementioned purposes, by contacting us at the following address gdpr@accumin.com.

9. Security measures

We undertake to process your data in accordance with the provisions of the applicable regulations and, in particular, to (i) process the data to which we have access with sufficient guarantees of confidentiality; and (ii) adopt the necessary technical and organisational security measures to prevent the alteration, loss and unauthorised processing of or access to your data.

All your data is stored on secure servers (or secure physical copies) owned by us or our sub-contractors or business partners and is accessed and used in accordance with our (or our sub-contractors' or business partners') security policies and standards.

Although it is not possible to guarantee absolute protection against intrusion when transmitting data over the internet or from a website, we and our subcontractors and business partners make every effort to maintain the necessary physical, electronic and procedural safeguards to ensure that your information is protected in accordance with applicable data protection requirements.

10. Your rights

Finally, we inform you that you have the following rights:

(A) Access: You can ask us to provide you with more details about how we process your personal data and request a copy of the personal information we hold about you.

(B) Rectification: You can ask us to change any inaccuracies in the personal information we hold about you.

(C) Erasure: You can ask us to delete your personal information when we no longer have lawful grounds for using it and the relationship between you and us has ended.

(D) Restriction of processing: you can restrict the processing of your data by Accumin for one or more specific purposes.

(E) Opposition: you can oppose the processing of your data by the company for a specific purpose, provided that such processing is not necessary for the fulfilment, development and control of your relationship.

(F) Data portability: You may ask us to transfer the personal information you have provided to us to a third party.

You can exercise your rights of access, rectification, deletion, limitation of processing, opposition and data portability before the company that has been identified as the data controller at the time of registration of the data, as follows:

Accumin Holdco, S.L.U. NIF 87232633 and registered office at Calle José Echegaray nº 9, Las Rozas de Madrid. 28232 Madrid.

By sending an email to the address gdpr@accumin.com. or by letter to the address indicated above addressed to our Legal Department, enclosing proof of identity and stating the rights you specifically wish to exercise.

As a last resort, you may request information about your rights and file a complaint with the Spanish Data Protection Authority, located at calle Jorge Juan, nº 6, 28001 Madrid.