GRUPO DRIVEN Data Protection Policy

1. Who is responsible for processing your data?

The controllers of data processing relating to the management of users, customers, prospective customers, collaborators and suppliers are the following companies forming GRUPO DRIVEN:

DRIVEN PROPERTIES, S.L., with tax identification number (CIF) B16377277 and registered office at Calle Almirante 25, 28004 Madrid, registered in the Madrid Commercial Registry, Entry 1/2024/74564,0, Sheet No. M-822840, Folio 43, Volume 46882.

LAMAR IBERIA, S.L., with tax identification number (CIF) B10583730 and registered office at Calle Almirante 25, 28004 Madrid, registered in the Madrid Commercial Registry, Bulletin 141, Reference 327590, Volume 1, Folio 1, Section 8, Sheet 768219, Entry 7.

For the purposes of our Data Protection Policy:

DRIVEN PROPERTIES, S.L.
Email: protecciondedatos@drivenproperties.es

LAMAR IBERIA, S.L.
Email: sales@lamardevelopment.com

Contact telephone number: 607033523

We also inform you that there are no joint controllers for the processing of data concerning the management of Users, Customers and Suppliers.

2. What data do we hold about you and how did we obtain it?

The categories of personal data that GRUPO DRIVEN processes concerning customers and suppliers are:

• Identification data.
• Postal or electronic addresses.
• Commercial information.
• Financial and transaction data.

We may also process the following types of data under specific processing activities. Such processing is always carried out with your prior consent, which may be withdrawn at any time, unless a legal basis or the controller's legitimate interest authorises processing without consent: AML/CTF documentation and whistleblowing channel.

We obtained all the above data directly from you through a commercial offer, contractual proposal or similar, or from your company when it supplied identification details and other information needed for the contractual relationship. You or your company must provide updated data when changes occur.

For job candidates, we obtained your data from a CV submitted by you or through an employment portal. In the latter case, by entering your CV details on that portal you authorised their transfer to our company.

3. How long will we retain your data?

Personal data relating to individuals connected with prospective customers, customers and suppliers, collected through contact and information forms, will be retained until the data subject requests its deletion.

Data supplied by customers and suppliers will be retained for the duration of the commercial relationship, subject to applicable minimum statutory retention periods.

In all cases, GRUPO DRIVEN will retain your personal data for the period reasonably necessary to answer questions, resolve problems, make improvements, activate new services and comply with applicable law. We may therefore retain personal data for a reasonable period after you stop using our products or website. Thereafter, your data will be deleted from all GRUPO DRIVEN systems.

4. For what purposes and on what legal basis do we process your data?

GRUPO DRIVEN processes data supplied by data subjects to manage activities arising from specific procedures concerning sales, after-sales service, supplier management, candidate management, service quality and similar matters.

The purposes and legal bases are:

Regarding the legal bases above, you must provide personal data where needed to perform your contract, comply with legal obligations or meet requirements arising from public authority.

We will not create commercial profiles based on the information supplied and will not make automated decisions about you based on a commercial profile.

5. To whom will your data be disclosed?

GRUPO DRIVEN will never share your personal data with a third-party company intending to use it for direct marketing unless you have expressly authorised this.

We may provide personal data to public authorities when legally required or where, acting in good faith, we reasonably consider this necessary to comply with legal proceedings, respond to claims or protect the rights of GRUPO DRIVEN, its customers and the public.

To meet commercial, accounting, tax and administrative needs concerning users, customers or suppliers, your data may need to be communicated between DRIVEN PROPERTIES, S.L. and LAMAR IBERIA, S.L., and to our parent company LAMAR DEVELOPMENT, located in Spain/the EU and outside it in countries that may not provide protection equivalent to European standards, always subject to all necessary data-protection safeguards.

GRUPO DRIVEN may provide personal data to third parties, including internet providers assisting with the website or contracted services, IT support and maintenance companies, logistics companies, administrative agencies and tax and accounting advisers. They must maintain appropriate security and, where required, be legally bound to keep data private and secure and use it only under GRUPO DRIVEN's instructions.

Depending on the purpose of the service, GRUPO DRIVEN may communicate your data to the following recipient outside the EU; this data flow constitutes an international transfer under applicable law:

Recipient name: Lamar Development
Destination country: United Arab Emirates
Purpose of transfer: Reporting to the parent company
International transfer mechanism: Standard Contractual Clauses approved by the European Commission
Recipient profile: Transferee

6. What are your rights as a data subject?

Everyone has the right to obtain confirmation as to whether GRUPO DRIVEN processes personal data concerning them. Data subjects may request access to their personal data and receive it in a commonly used, machine-readable format where processing is electronic—the right to data portability.

They may also request rectification of inaccurate data or deletion where, among other reasons, the data is no longer needed for the purposes for which it was collected. In certain circumstances, they may request restriction of processing or object to processing for reasons relating to their particular situation.

GRUPO DRIVEN will cease processing unless compelling legitimate grounds exist, for the establishment or defence of claims, or where applicable law provides otherwise. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

You may exercise these rights by writing to:

DRIVEN PROPERTIES, S.L.: protecciondedatos@drivenproperties.es
LAMAR IBERIA, S.L.: sales@lamardevelopment.com

The entity reserves the right to request supporting documentation to verify the applicant's identity only where verification cannot be carried out by other means.

You also have the right to lodge a complaint with the Spanish Data Protection Agency, particularly where you have not obtained satisfaction in exercising your rights:

Agencia Española de Protección de Datos
C/ Jorge Juan, 6
28001 Madrid
Tel.: 901100099 / 912663517

7. Data protection for website users

Under Regulation (EU) 2016/679, GRUPO DRIVEN informs Users that personal data from https://brisasdemarbella.com/—including form data and associated metadata such as submission date, time and IP address—will be processed for the activity specified in each website data-collection form.

Such processing is based on your consent. By clicking “SEND”, the User consents to GRUPO DRIVEN processing their data.

Unless required by law or expressly consented to by you, GRUPO DRIVEN will not disclose your data to third parties.

The User may exercise rights of access, rectification or deletion and all other rights recognised herein and under Regulation (EU) 2016/679 by writing to the controllers using the contact details above.

Under Spanish Law 34/2002 of 11 July on Information Society Services and Electronic Commerce, GRUPO DRIVEN undertakes not to send advertising by email without first obtaining the recipient's express authorisation. The User may object to advertising by selecting the corresponding checkbox.

8. Other relevant information about our Privacy Policy

8.1. Security measures

GRUPO DRIVEN adopts the security levels required by current European and Spanish data-protection law, considering the state of the art, implementation costs, the nature, scope, context and purposes of processing, and risks of varying likelihood and severity to individuals' rights and freedoms.

8.2. Processing children's data

Under Regulation (EU) 2016/679 and Spanish Organic Law 3/2018, minors over 14 may consent to certain information-society services, such as completing a contact form. GRUPO DRIVEN is responsible for verifying the stated age. Data from children under 14 will always be collected with the express consent of parents or legal guardians.

8.3. Changes to our Data Protection and Privacy Policy

GRUPO DRIVEN may occasionally amend or correct this Data Protection Policy for Customers, Suppliers and Users. Please review it regularly for changes and how they may affect you.

8.4. Why is it necessary to accept this Data Protection and Privacy Policy?

This section provides accessible information on the types of data GRUPO DRIVEN holds concerning users, prospective customers, customers and suppliers, the purposes pursued, the rights granted by data-protection law and how to exercise them.

By deliberately sending personal data through our contact channels and/or beginning a commercial relationship with us, you acknowledge and accept processing as described in this policy. Personal information will be used only for the purposes for which it was supplied or as authorised by national or regional law.

Refusal to provide requested data could hinder the contractual relationship and affect delivery of the services contemplated in the commercial contract.

For questions about this GRUPO DRIVEN Data Protection Policy for Users, Prospective Customers, Customers and Suppliers, contact:

DRIVEN PROPERTIES, S.L.: protecciondedatos@drivenproperties.es
LAMAR IBERIA, S.L.: sales@lamardevelopment.com

9. Applicable law

This Data Protection Policy shall at all times be governed by Spanish and European legislation on personal data protection and privacy.