In compliance with Law 34/2002, of July 11, on information society services and electronic commerce, it is hereby informed that MUCH MEDIA INVEST, SL, which operates commercially under the name The Agency Barcelona, with registered office at Plaça de Catalunya, 8, 3rd 2nd, 08007 Barcelona, Spain, Tax Identification Number (NIF) B-70626734, email addressbarcelona@theagencyre.com, registration number AICAT 12896 and membership number API A14211 is the owner of this website.

Data Controller

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (RGPD) and Organic Law 3/2018, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), users are informed that the personal data that we may collect directly from the interested party will be processed confidentially by MUCH MEDIA INVEST, SL (hereinafter, “THE AGENCY BARCELONA” or the “Controller”) and will be incorporated into the corresponding processing activity.

Scope and reach of the treatment

This Privacy Policy governs the processing of personal data carried out by THE AGENCY BARCELONA in the context of its activities as an international real estate agency, including:

• Managing customers, leads, and website users
• The provision of real estate brokerage services
• The promotion of national and international real estate assets
• Coordination with partner offices and members of The Agency’s international real estate network

In particular, THE AGENCY BARCELONA’s activity focuses on residential and commercial real estate brokerage, including buying, selling, leasing, property management, property searches and the provision of advisory services to national and international clients, as well as organizing property visits and coordinating with owners, developers, partner agencies and other parties involved in real estate transactions.

For these purposes, the processing may be carried out directly by THE AGENCY BARCELONA or, when necessary to provide the requested service, in coordination with independently owned offices, agents and collaborators belonging to The Agency’s international real estate network.

Purposes of processing personal data

Personal data will be processed for the following purposes, separately and in accordance with the applicable legal basis in each case:

i. Management of queries, requests and contacts

To receive, process, and manage any request, inquiry, issue, or communication submitted by the user, including those made through web forms, email, telephone, or other available contact channels. This processing is necessary to respond to the interested party’s request, maintain communication with them, and provide them with the requested information.

ii. Management of the pre-contractual and contractual relationship

To carry out the necessary actions for the provision of real estate services and the management of the pre-contractual or contractual relationship with the interested party, including, among others, intermediation in purchase and sale transactions, leases, property management, property search or real estate investment; commercial advice; the organization of visits; document management; coordination with third parties involved in the operation; monitoring of opportunities and operations; as well as any action related to the preparation, formalization and development of the requested services.

Furthermore, in the context of providing international real estate services, information relating to properties managed by THE AGENCY BARCELONA, including their characteristics, images, approximate location and any other relevant commercial information, may be shared and disseminated among offices, agents and collaborators of independent ownership belonging to The Agency’s international real estate network, in order to facilitate their marketing, promotion and possible intermediation, both nationally and internationally.

In all cases, this information will be processed in a way that does not allow the direct identification of the property owners, except when such identification is necessary for the operation or has been expressly authorized, and in accordance with the principles of data minimization and confidentiality.

iii. Marketing and commercial communications

To send the interested party, by any means, including electronic means, commercial, promotional or informative communications relating to properties, products, services, investment opportunities, real estate market news, events, publications or content related to THE AGENCY BARCELONA and, where appropriate, to The Agency’s international real estate network.

These communications may be tailored to the profile and interests of the interested party based on the information provided, their previous requests and their interaction with the company, in order to offer them more relevant content.

This treatment will be performed:

• Based on the consent of the interested party when this is a user, subscriber or potential client who does not maintain a prior contractual relationship with THE AGENCY BARCELONA.
• When permitted by Article 21.2 of Law 34/2002, on the basis of an existing contractual relationship, provided that the contact details have been lawfully obtained and the communications refer to products or services offered by THE AGENCY BARCELONA that are similar to those previously contracted by the interested party.

In all cases, THE AGENCY BARCELONA will provide the recipient with a simple and free means to object to or unsubscribe from commercial communications, both at the initial time of data collection and in each subsequent electronic communication.

The interested party may object at any time to the processing of their data for commercial purposes and may withdraw their consent through the mechanisms enabled for this purpose or by contactingbarcelona@theagencyre.com.

iv. Communication of data within The Agency’s international network

In order to provide the interested party with a comprehensive, coordinated service adapted to their needs, both in Spain and internationally, personal data may be communicated, when necessary, to independently owned offices, agents and collaborators belonging to The Agency’s international real estate network, even when such recipients are located outside the European Economic Area.

These communications may be made in order to offer real estate products and services tailored to the interested party’s profile, facilitate national or international investment opportunities, coordinate cross-border operations, direct requests to the most appropriate office, agent or collaborator, and ensure a consistent and efficient provision of services.

The offices and companies operating under The Agency brand may be independently owned and managed and act as separate data controllers for the personal data they receive. Where appropriate, the relevant recipient will provide the data subject with their own privacy information.

In all cases, such communications will be carried out in accordance with applicable data protection regulations and, where appropriate, through the adoption of adequate safeguards for international data transfers.

Communications will be based, as appropriate, on the performance of a contractual relationship or on the application of pre-contractual measures requested by the interested party, on the legitimate interest of the Controller in coordinating the requested real estate services or, where required by law, on the consent of the interested party.

v. Service improvement, quality control and internal control

Perform internal analyses, audits, quality controls, preparation of aggregate statistics, satisfaction surveys, follow-up actions and continuous improvement of internal processes, as well as training, supervision and internal control activities.

Whenever possible, anonymized or aggregated information will be used for statistical and analytical purposes.

vi. Use of artificial intelligence technologies

THE AGENCY BARCELONA may use artificial intelligence technologies, automated tools and algorithmic support systems in order to improve operational efficiency, optimize internal processes and enhance customer service.

In particular, these tools can be used to manage queries, assist in the drafting or translation of automated or semi-automated responses, classify requests, prioritize communications, personalize content and commercial proposals, manage information about properties, relate search requirements to available properties, and improve the user experience and the services provided.

In all cases, these systems will act as support tools and will be subject to appropriate human oversight. No decisions producing legal effects concerning the data subject or similarly significantly affecting them will be based solely on automated processing without appropriate human intervention, except where permitted by law and where the safeguards required by current data protection legislation are applied.

The use of these technologies will at all times respect the principles of lawfulness, fairness, transparency, data minimization, proportionality, security and confidentiality.

THE AGENCY BARCELONA declares that it has implemented the necessary technical and organizational measures to guarantee a level of security appropriate to the risk, in accordance with the requirements of the GDPR and the LOPDGDD, in order to prevent the loss, alteration, improper processing, unauthorized access or theft of personal data provided by users.

Personal data processed using AI-assisted systems will be retained only for as long as necessary for the corresponding purpose and in accordance with the retention periods applicable to the underlying consultation, service, or contractual relationship. Temporary copies that service providers may retain will be subject to the corresponding data processing agreement and the agreed-upon deletion periods.

Interested parties may also request additional information on the general operation of these systems and their impact on the processing of their data.

vii. Compliance with legal obligations relating to the prevention of money laundering and the financing of terrorism

THE AGENCY BARCELONA, as an obligated entity under Law 10/2010 of April 28, on the prevention of money laundering and the financing of terrorism, will process personal data in order to comply with applicable legal obligations, including the formal identification of the client and, where appropriate, the beneficial owner; the verification of their identity; the analysis of the origin of funds; the assessment of the risk of the operation; and, where appropriate, the communication of operations to the competent authorities.

This processing is based on compliance with a legal obligation and may involve the communication of data to the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences (SEPBLAC), to judicial authorities, to the security forces or to other competent authorities.

Furthermore, the data will be kept for a period of ten (10) years, in accordance with applicable regulations.

The exercise of certain rights may be restricted in the cases provided for by law.

viii. Use of instant messaging channels

THE AGENCY BARCELONA may communicate with interested parties through instant messaging applications, such as WhatsApp, in order to manage inquiries, share information about properties, coordinate visits, carry out commercial follow-up and facilitate the provision of real estate services.

The use of these channels will be voluntary and may involve international data transfers.

Interested parties are advised not to send particularly sensitive information through these channels. THE AGENCY BARCELONA may require the use of alternative and more secure channels when necessary. Furthermore, THE AGENCY BARCELONA may establish internal protocols that limit the transmission of certain documents through these channels when necessary to ensure information security.

Principles applicable to the data provided

• Principle of lawfulness, fairness and transparency: personal data will be processed lawfully, fairly and transparently, informing the interested party clearly and in advance about the purposes of the processing and obtaining, where necessary, their consent.
• Purpose limitation: the data will be collected for specific, explicit and legitimate purposes and will not be further processed in a manner incompatible with those purposes.
• Principle of data minimization: only data that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed will be processed.
• Principle of accuracy: Data shall be accurate and, where necessary, kept up to date. Reasonable steps shall be taken to ensure that inaccurate data is deleted or rectified without delay.
• Principle of limitation of the storage period: data will be kept for no longer than necessary for the purposes of the processing, without prejudice to their storage for the periods required by law.
• Principle of integrity and confidentiality: data will be processed in a manner that ensures adequate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, through the application of appropriate technical and organizational measures.
• Principle of proactive responsibility: THE AGENCY BARCELONA will be responsible for compliance with the above principles and will take the necessary measures to guarantee and be able to demonstrate compliance.

Where legally required, THE AGENCY BARCELONA will maintain an up-to-date Record of Processing Activities in accordance with applicable data protection regulations.

Legal basis for the processing

The processing of personal data by THE AGENCY BARCELONA is based on the following legal grounds, depending on the purpose:

• Execution of a contract or application of pre-contractual measures, when the processing is necessary for the provision of the requested services, including real estate intermediation, property search, leasing, property management, operations management and customer service.
• Legitimate interest, for the management and maintenance of the business relationship, handling inquiries, improving services, preventing fraud, internal administration, security and formulating, exercising or defending claims, provided that such interests do not prevail over the fundamental rights and freedoms of the interested party.
• The data subject’s consent, given by a clear affirmative action, for specific purposes such as sending commercial communications when consent is necessary, the use of non-essential cookies, certain commercial profiling activities and the communication of personal data to independently owned offices, agents or collaborators belonging to The Agency’s international real estate network when consent is legally required.
• Compliance with legal obligations, when the processing is necessary to comply with applicable regulations, including those relating to the prevention of money laundering and terrorist financing, tax and accounting obligations and the obligations applicable to real estate professionals in Spain and Catalonia.

THE AGENCY BARCELONA may use technological tools, including artificial intelligence systems, to improve customer service and personalize services, without making decisions with legal effects or similar significant effects based exclusively on automated processing, except where permitted by law and the required safeguards are applied.

International data transfers will be carried out using appropriate safeguards in accordance with applicable data protection regulations.

When the user has not contracted services, the legal basis will primarily be consent, legitimate interest in responding to their inquiry, or the application of pre-contractual measures requested by them. In the case of clients, the legal bases will also include the performance of a contract and compliance with applicable legal obligations.

The interested party may withdraw their consent at any time, without affecting the lawfulness of the processing carried out before its withdrawal, and may request additional information on the applicable legal bases and processing activities.

Data Retention period

Personal data will be kept for the time necessary to fulfill the purpose for which it was collected and, where appropriate, for the statutory limitation periods for possible liabilities and any other period required by applicable regulations.

Personal data may be kept as long as there is a legitimate interest in maintaining the corresponding processing and provided that such interest is not overridden by the rights and freedoms of the interested party, unless its retention is necessary to comply with a legal obligation.

Notwithstanding the foregoing, and unless a different time limit applies due to a legal obligation or the need to address potential liabilities, the following indicative time limits shall apply:

• Management of inquiries, requests and contacts: the data will be kept for the time necessary to respond to the request and, in any case, for a maximum period of twelve (12) months from the last interaction, unless a contractual or pre-contractual relationship arises from this.
• Pre-contractual and contractual relationship: the data will be kept during the relationship and, subsequently, for the periods legally required for compliance with obligations and for the formulation, exercise or defense of claims.
• Commercial communications: data will be kept until the interested party withdraws their consent or objects to the processing, without prejudice to the minimum information that may be kept to ensure that their objection or withdrawal continues to be respected.
• Communication of data within The Agency’s international real estate network: data will be kept for the time necessary to coordinate the service and will be subject to any applicable legal retention obligations.
• Use of artificial intelligence technologies: data will only be retained for as long as necessary for the underlying consultation, service or contractual relationship and in accordance with applicable contracts with suppliers and agreed deletion periods.
• Selection processes: If the candidate is not selected, the data will be kept for the duration of the corresponding selection process. It may be kept for future processes for a maximum period of twenty-four (24) months when the candidate has consented to such retention, unless they withdraw their consent or request its deletion beforehand.
• Security and internal control: data will be kept for the time necessary to ensure the security of the systems and in accordance with the time limits established in the applicable regulations.
• Prevention of money laundering: the data will be kept for a period of ten (10) years in accordance with applicable regulations.

Once the applicable retention periods have expired, the data will be duly blocked and subsequently deleted or anonymized in accordance with current regulations.

In the event of withdrawal of consent or exercise of the right to erasure, data that must be kept to comply with a legal obligation or to address possible liabilities will be blocked and will remain available only to the competent authorities for the legally established periods.

Communications and recipients of personal data

The communications described below may be necessary to fulfill the purposes outlined above, to perform a requested service or contract, to comply with a legal obligation, or to satisfy a legitimate interest. Where required, the communication will be based on the data subject’s consent.

Personal data may be communicated to:

• Offices, agents and collaborators of independent ownership belonging to The Agency’s international real estate network, when necessary to offer or promote real estate opportunities, coordinate inquiries or facilitate national or international transactions.
• Other collaborating agencies or business partners within the framework of shared or collaborative real estate transactions.
• Owners, landlords, potential buyers, tenants, developers and property managers when necessary to handle an inquiry or transaction.
• Public administrations, SEPBLAC, judicial authorities, security forces and courts.
• IT service providers, including cloud computing providers, CRM, web hosting, electronic signature, communications and data storage.
• Marketing providers, newsletters, social media, real estate portals and advertising.
• Notaries, property registrars, financial institutions, insurance companies, rental guarantee providers, lawyers, tax advisors, architects, experts and other professionals necessary for the formalization and execution of real estate transactions.

When a supplier processes personal data on behalf of THE AGENCY BARCELONA, the corresponding data processing agreement will be formalized in accordance with Article 28 of the GDPR.

Recipients acting as independent data controllers will process personal data under their own responsibility and in accordance with their respective privacy policies.

International Data Transfers

As a general rule, the processing of personal data will be carried out by providers located in the European Union or the European Economic Area, or in countries that have been recognized as having an adequate level of data protection in accordance with applicable regulations.

International transfers may result from the use of customer management technology tools, including CRM platforms, marketing platforms, communication tools, social media, cloud computing services, electronic signature services and instant messaging applications, as well as from coordination with independently owned offices, agents or collaborators belonging to The Agency’s international real estate network located outside the European Economic Area.

In certain cases, for the purposes described above, THE AGENCY BARCELONA may contract with suppliers or coordinate with recipients who access personal data from outside the European Economic Area, which may involve international data transfers.

These transfers will be carried out using an appropriate transfer mechanism and safeguards in accordance with applicable data protection regulations. Depending on the recipient and the destination country, they may include:

• A suitability decision adopted by the European Commission.
• The recipient’s participation in an adequacy framework recognized by the European Commission, where applicable.
• Standard Contractual Clauses approved by the European Commission.
• Complementary technical, contractual or organizational measures.
• Another transfer mechanism permitted by the GDPR.

Where necessary, impact assessments of the transfers will be carried out to determine whether personal data will receive an essentially equivalent level of protection.

The interested party may request additional information from the Data Controller regarding the corresponding international transfer and the applicable safeguards by contactingbarcelona@theagencyre.com.

Rights of interested Parties

Interested parties may exercise their rights of access, rectification, erasure and portability of their data, as well as their rights to limitation of processing and to object, and the right not to be subject to decisions based exclusively on the automated processing of their data, against THE AGENCY BARCELONA.

They may also withdraw their consent at any time for specific purposes, without affecting the lawfulness of the processing carried out before its withdrawal, and they may modify their preferences. In particular, where the processing is based on a legitimate interest or is carried out for direct marketing purposes, the data subject has the right to object at any time.

The following is a brief description of these rights:

• Right of access: allows the interested party to know what personal data is being processed, for what purpose, its origin and, where appropriate, the communications made or planned.
• Right of rectification: allows you to request the correction of inaccurate or incomplete data.
• Right to erasure: allows you to request the deletion of your data when, among other reasons, it is no longer necessary for the purposes for which it was collected, without prejudice to legal obligations that require its retention.
• Right to object: allows the interested party to object to the processing of their data, especially when it is based on a legitimate interest or is carried out for direct marketing purposes.
• Right to restriction of processing: allows you to request the restriction of processing when:
  • The accuracy of the data is challenged.
  • The processing is unlawful and the data subject opposes its erasure.
  • The data are no longer necessary for the purposes of the processing, but the data subject needs them for the establishment, exercise or defense of legal claims.
  • The right to object has been exercised and the corresponding verification is pending.
• Right to data portability: allows the interested party to receive the personal data they have provided in a structured, commonly used and machine-readable format and, where technically feasible, transmit it to another controller when the applicable legal requirements are met.
• Right not to be subject to automated decisions: allows the interested party not to be subject to a decision based solely on automated processing, including profiling, when such decision produces legal effects or similarly significantly affects him or her, except in the cases permitted by law.

These rights may be exercised by sending a request tobarcelona@theagencyre.comor by mail addressed to:

MUCH MEDIA INVEST, SLThe Agency BarcelonaPlaça de Catalunya, 8, 3.º 2.ª08007 Barcelona, Spain

The request must state the right the applicant wishes to exercise and include sufficient information to verify the applicant’s identity. THE AGENCY BARCELONA may request additional information when reasonably necessary to confirm the applicant’s identity.

Applications will be processed within the timeframes established by applicable data protection regulations.

The interested party also has the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es), especially when you believe that the processing of your personal data does not comply with applicable regulations.

Data on minors

THE AGENCY BARCELONA will not knowingly collect or process personal data of children under 14 years of age without the prior consent of their parents, guardians or legal representatives, in accordance with applicable data protection regulations.

Therefore, when the interested party is under 14 years of age, the processing of their personal data will only be considered lawful if the corresponding consent has been given or authorized by the person holding parental authority or guardianship, and only to the extent that such consent has been given.

THE AGENCY BARCELONA reserves the right to request any documentation reasonably necessary to verify the user’s age or the authenticity of the consent given by their legal representatives.

Personal data of thirs parties

When the user provides THE AGENCY BARCELONA with personal data relating to third parties, they must ensure that they are authorized to provide such information and that the affected persons have been previously informed of the content of this Privacy Policy where required.

The user must also ensure that there is consent or any other legal basis necessary to carry out the communication.

Furthermore, the user guarantees that the data provided is accurate, truthful and up-to-date, and assumes responsibility for any damage that may arise from non-compliance with these obligations.

Curriculum Vitae Processing

The personal data provided by candidates will be processed by THE AGENCY BARCELONA for the purpose of managing their application and participation in current selection processes.

The legal basis for the processing is the application of pre-contractual measures at the request of the candidate.

When the candidate separately authorizes the retention of their candidacy for future selection processes, the legal basis for such additional retention will be their consent.

Personal data may be communicated to selection service providers acting as data processors and, where necessary and legally permitted, to independently owned members of The Agency’s international real estate network, solely for the purpose of managing the relevant selection process.

The data of an unsuccessful candidate will be deleted after the applicable selection process has ended, unless the candidate has consented to its retention for future professional opportunities. In that case, the data may be retained for a maximum period of twenty-four (24) months, unless the candidate withdraws their consent or requests its deletion beforehand.

The candidate may exercise their data protection rights at any time, in accordance with the provisions of this Privacy Policy.

THE AGENCY BARCELONA reserves the right to modify this Privacy Policy to adapt it to new legislation, regulations or case law, to guidelines issued by the competent data protection authorities, to changes in its processing activities and to industry practices.

USERS WHO DO NOT AGREE WITH THIS POLICY SHOULD REFRAIN FROM PROVIDING PERSONAL DATA THROUGH THIS WEBSITE.

Website terms of use

All content included on the website, including, but not limited to, text, photographs, graphics, images, icons, videos, technology, software, graphic design, trademarks and source code, are the property of THE AGENCY BARCELONA or, where applicable, of third parties who have authorized their use.

Access to this website does not grant users any ownership or exploitation rights over its content. Therefore, its reproduction, distribution, public communication, transformation, or any other form of exploitation, in whole or in part, is expressly prohibited without the prior written authorization of the corresponding rights holder.

THE AGENCY BARCELONA will not be responsible for third-party content that may be published or made available through the website, provided that it has no actual knowledge that such content is illegal or infringes the rights of third parties or that, upon becoming aware of it, it acts diligently to remove it or prevent access to it.

The user agrees to make appropriate use of the website’s content and services in accordance with applicable regulations, good faith and public order and, in particular, to refrain from:

• Using the website for illegal purposes or in a manner contrary to the rights and interests of third parties.
• Reproducing, distributing, modifying or exploiting the website’s content without authorization is prohibited.
• Introducing viruses, malware, or other harmful technological components.
• Causing damage to the physical or logical systems of THE AGENCY BARCELONA, its suppliers or third parties.
• Attempting to access restricted systems, accounts, or information without authorization.

The relationship between the user and THE AGENCY BARCELONA will be governed by Spanish law and, where applicable, by the regulations in force in Catalonia.

To resolve any dispute arising from access to or use of the website, the parties submit to the courts of Barcelona, unless consumer protection regulations or applicable procedural rules establish another mandatory jurisdiction.