PRIVACY POLICY

1 Identification of the data controller

The data controller is the company Ponder Trade, S.L., with address for contact purposes at Carrer Tuset, 5, 08006 Barcelona, Espanya (“Ponder Trade”).

2 Purposes and legitimacy of the processing of personal data. Categories of personal data and recipients

Purpose

  • Respond to requests for information, suggestions and/or queries.

  • Interact (ie respond to messages or comments, generate reactions, share content, etc.) with users of Ponder Trade profiles on social networks, which will involve the communication of certain data (ie IP address and user browsing data) to the providers of said social networks.

  • Send newsletters about Ponder Trade products, services and activities (newsletters) when interested parties show interest in Ponder Trade’s real estate developments and if there is a prior contractual relationship between Ponder Trade and the interested parties

Legal Base

  • Legitimate interest of Ponder Trade and/or third parties (article 6.1(f) of the RGPD):

    • Ponder Trade has an interest in providing an optimal service to the users of its website in a secure online environment. For this reason, Ponder Trade considers that the legitimate interest on which the processing of personal data is based prevails over the fundamental rights and freedoms of the interested parties, since the processing is within the reasonable expectations of the interested parties based on their relationship with Ponder Trade.
    • In any case, the interested parties may request more information in relation to the legitimate interest or exercise their right to object, by sending said request to admin@pondertrade.com
Category of personal data and recipients

  • Categories of personal data:

    • Identifying data (name, surnames and username on social networks)
    • Contact data (telephone number, email address)

  • Recipients:

    • Information technology service providers
    • Marketing service providers
    • Social network providers

  • Address job applications and manage, where appropriate, participation in personnel selection processes.

  • Execution of a contract or application of pre-contractual measures (article 6.1(b) of the RGPD):

    • The processing of data of the interested parties who apply for a job at Ponder Trade is lawful because it is necessary for the application at the request of said interested parties of measures pre-contractual or the intention to conclude a contract.
    • The refusal to provide the personal data that Ponder Trade requests could result in the impossibility of entering into or maintaining said contract.

  • Categories of personal data:

    • Identification data: name and surname, age/year of birth and photograph
    • Contact data: telephone number, email address and postal address
    • Academic data: training and academic titles
    • Professional data: previous professional experience, positions and members of associations /professional associations

  • Recipients:

    • Information technology service providers
    • Recruitment providers

  • Customize certain functionalities of the web page (for example, the language of content display) according to the browsing preferences expressed by users and analyze their browsing behavior (for example, sections that attract a greater or lesser number of visits) with the objective of improving the services offered through the website and so that third parties can offer personalized advertising. The information on the activities of analysis of the behavior of the interested parties is available in this Privacy Policy and in the Cookies Policy of the website.

  • Send newsletters about Ponder Trade products, services and activities (newsletters).

  • Consent (article 6.1(a) of the RGPD):

    • Data subjects can grant their consent by clicking on the acceptance or preference selection buttons or by taking any other clear affirmative action.
    • Data subjects may revoke their consent at any time, as detailed in Section 4

  • Categories of personal data:

    • Identification data (name and surname)
    • Contact data (email address)
    • User browsing data (IP address, user or device identifier, browser type and version, browsing preferences, web pages visited and country from which the connection is made)

  • Recipients:

    • Providers of information technology services
    • Providers of marketing services

Ponder Trade will ensure that the communication of personal data is made to countries on which the European Commission has decided that they guarantee an adequate level of data protection. If personal data is processed from countries that do not offer said level of protection, Ponder Trade and/or service providers (as the case may be) will adopt the appropriate guarantees to carry out said data transfers in accordance with data protection legislation unless an exception is applicable. You can request information from Ponder Trade about the appropriate guarantees regarding the international transfer of personal data at admin@pondertrade.com

Ponder Trade does not share personal data with any third party other than those indicated above, except as required by applicable law or to potential investors or buyers in the event of corporate reorganization activities.

The website uses social network plugins, which can be recognized by the logo or name of the social network, so that users can access Ponder Trade’s profile on said platforms or share certain content of the website on some of these platforms. By clicking on these buttons, the personal data of the users (among others, IP address and browsing data) will be transferred to the providers of said social networks, and Ponder Trade is not responsible for the subsequent treatment that the providers of the social networks may carry out with such personal data. The purpose and scope of the data collection and its subsequent treatment and use by the providers of said social networks, as well as the relative rights and the possibilities of configuring the privacy options can be consulted in the information on data protection of these companies.

3 Storage period

Once the purposes for which the personal data are processed have been fulfilled, Ponder Trade will keep them until the expiration of the prescription periods of the responsibilities that may arise from its relationship with the interested parties and during the periods necessary to comply with any legal obligation that result of application.

4 Data protection rights

Right Content
Access You can request confirmation of whether your personal data is being processed and, if so, access your data included in Ponder Trade’s files.
Rectification You can request the rectification of your personal data when they are inaccurate.
Suppression You can request the deletion of your personal data.
Opposition You can request that your personal data not be processed in certain circumstances.
Portability You can request to receive, in an electronic file, the personal data that you have provided to Ponder Trade, as well as the right to transmit them to other third parties.
Treatment limitation You can request the limitation of the processing of your personal data when:

  • the accuracy of your personal data is challenged,
  • the processing of your personal data is illegal and you oppose its deletion,
  • Ponder Trade no longer needs your personal data for the purposes of treatment, but you need them for the formulation, exercise or defense of claims,
  • you have opposed the processing of your personal data for the fulfillment of a mission in the public interest or when it is necessary for purposes of a legitimate interest, while verifying if Ponder Trade’s legitimate reasons prevail over yours.
Revocation of consent You can withdraw your consent without affecting the legality of the treatment based on the consent prior to its withdrawal.

You can exercise, when applicable, your data protection rights by sending a written communication to admin@pondertrade.com and indicating “Web Ponder Trade” in the subject of the communication. For these purposes, Ponder Trade may request as much information and documentation as it deems appropriate to properly identify you.

Likewise, you can exercise your right to claim before a data protection authority, including those located in your place of residence, work or in the place where the alleged infringement has taken place.