CDP GmbH & Co. KG.makes available to all users of the website the following Privacy Policy, with the objective of providing information on how we process your personal data and protect your privacy and personal information.

We recommend you to read carefully our Privacy Policy.

Introduction

This Privacy Policy applies to the website of CDP GmbH & Co. KG., which is available under the link https://www.insulaproperties.com, and will also be applicable to all interactions conducted by users with CDP GmbH & Co. KG.through the above-mentioned website.

CDP GmbH & Co. KG.may modify this Privacy Policy whenever this may be necessary. In case the said Policy is modified, we will communicate this to you through our website or through any other communication means, in order to make sure you are informed of the new privacy terms applicable to our website. If you continue making use of our website after we have informed you of the changes introduced in our Privacy Policy, this will mean that you agree to the new terms, except for the purposes for which your express consent is required.

Who is the data controller?

The data controller is CDP GmbH & Co. KG. (hereinafter, CDP), registered with identification number W/2766025-G and with place of business in Calle Lluís Martí 9; 07006 Palma de Mallorca

 In order to guarantee the adequate processing of your personal data, CDP has appointed a Data Protection Officer, to whom you can address any queries related to the processing of your personal data. You can contact our Data Protection Officer under [email protected]

For which purposes do we process your personal data?

The personal data you provide us with through our website may be processed for any of the following purposes:

1. Contact: to manage the data of the users that make contact with CDP through our website, either through contact forms, telephone calls, email or any other way.

Additionally, your data will be processed with the purposes of keeping contact with you, providing you customer service related services, and handling any requests you may address to us through our website.

CDP also may process, for the same purposes stated in the paragraph above, the personal data of users that have contacted CDP through any communication means other than our website.

1. Commercial communications on products and services of CDP (commercial communications): CDP may process personal data of users with the purpose of submitting them commercial communications on our products and services which may be of their interest. These communications may refer to a real estate development in relation to which the user has shown interest, or to any other property real estate managed by CDP

CDP informs you that the above-mentioned commercial communications may be submitted to you through the postal service, telephone calls or electronic means (email, text message, or any other electronic communication means).

CDP informs you that, with the purpose of improving the commercial communications we submit, and with a view to offer information adequate for users’ needs, before sending out any commercial communications we may conduct profile assessments and apply customer segmentation techniques, using exclusively internal data.

You can object at any time to the processing of your personal data by CDP for purposes related to commercial communications using the communication channels made available by us as explained in section Which are your rights on your personal data?

Which personal data is processed by CDP and how is it obtained?

The personal data processed by CDP is obtained from the following sources:

• Personal data provided by the user using the forms made available by CDP or through any other means that enable the communication between the user and CDP.
• Personal data generated in the course of the relation with users between CDP and the user.

CDP may process the following types of personal data:

• Identification details such us name and surname, email address, telephone number, address, IP address, etc.
• Personal data regarding personal characteristics and social conditions, such us marital status, number of children, features of your current home, etc.

Which is the legitimacy of CDP for processing your personal data?

CDP process your personal data based on the following grounds:

1. The processing of your data for the purpose “Contact” is based on the management of the legal relationship established between the user and CDP. This includes basically the handling of your request, the maintenance of the contact between the parties, and if applicable, the rendering of the service requested by the user.

1. The processing of personal data for the purpose “Commercial Communications on products and services” is based on your content.

To which receivers will your personal data be communicated?The personal data processed by CDP as referred in this Policy do not imply any communications of personal data to third parties.

How time will your data be kept?

CDP will keep your personal data for the time necessary for providing you with the services requested and/or to attain the purpose of the personal data processing in question.

Afterwards, whenever you the user has not exercised the right to erasure, your personal data will be kept for the time necessary for complying with legal data retention periods, taking into account the types of data kept and the purposes of the processing.

In any case, the user can request detailed information on the data retention periods applied by CDP by contacting our Data Protection Officer under [email protected]

Which personal data do you have to provide us with?

CDP informs all users that, whenever personal data is collected through a form located in our website, it will be necessary that users provide at least the information related to the fields marked with *. In case the necessary data is not provided, CDP will not be able to handle the request from the user.

Which guarantees shall you provide in relation with your personal data?

The user guarantees that the personal data provided is truthful, accurate and complete, and that it is up to date. The user will be responsible for any damage, direct or indirect, that may be caused due to the lack of compliance with this obligation.

In case the user provides personal data regarding third persons, the user guarantees that he/she has informed them about the content of the current Policy and obtained their prior consent to provide us with their data with the objective to process it for the necessary purposes.

In order to be allowed to provide us with your personal data you must be older than 16 years old. Users providing data through our website declare and guarantee that there are older than 16 years old, being totally responsible of that declaration.

Which security measures do we apply to protect your personal data?

CDP is a company concerned by the security and confidentiality of its data. This is the reason why we have adopted the required security levels for the protection of personal data, and why we have set up technical measures to avoid the loss, misuse, alteration, unauthorized access and theft of the personal data provided through our website. Having said that, please bear in mind that security measures in the internet are not unfailing.

What are your rights in relation to the processing we make of your personal data?

CDP informs you that you have the right to obtain confirmation of if whether or not we are treating your personal data.

Moreover, we inform you that you have the following rights on your personal data:

• Right of Access: you have the right to access to your personal data in order to know which ones we are processing.
• Right of rectification: under certain circumstances you have the right to have your personal data rectified where you considered that we are processing inaccurate data. You can also request the erasure of your personal data, when, among other reasons, the data is no longer necessary for the purposes for which they were collected.
• Right of restriction of the processing: under certain circumstances, you will be entitled to request us the restriction of the processing of your personal data. In those cases, we only keep your personal data for the exercise or defence of possible legal claims.
• Right to data portability: under certain circumstances, you will be entitled to receive from us in a structured, common used and machine-readable format the personal data we have from you. You also have the right to have this data transferred to another data controller.
• Right to object: under certain circumstances, and based on grounds related to your personal situation, you may be entitled to object to the processing of your personal data. In that case we will stop processing your data unless we must continue processing it based on legal grounds or for purposes related to the exercise or defence of possible legal claims.

Moreover, we remind you that you have the right to object, at any time, to the submission of commercial communications of products and services from CDP. You are also entitled to withdraw your consent for the processing of your data, but this will not affect the data processings carried out based on your consent before this was withdrawn.

You will be able to exercise your rights on your personal data through the submission of a written communication to CDP, with reference “Exercise of customer rights”, and to which you will need to attach a copy of your ID card or passport with the objective of confirming your identity.

You can submit your written communications to the following address:

CDP GmbH & Co. KG. in Calle Lluís Martí 9; 07006 Palma de Mallorca

[email protected]

CDP will respond to your query within a maximum time period of one month from the date of receipt of your request. Nevertheless, we inform you that this time period could be extended by 2 months considering the complexity of your request and the volume of requests received.

• Finally, CDP informs you that you are entitled to file a complaint to the Supervisory Authority in matters of data protection, which in Spain is the Agencia Española de Protección de Datos www.agpd.es . Nevertheless, in a first step you can file your complaint to our Data Protection Officer, who will respond to your query within a maximum time period of two months

USE OF COOKIES

A cookie is a file that downloads onto your computer when you access certain websites. Amongst other things, cookies enable a website to save and retrieve information about a user or their computer’s browsing habits and, depending on the information they contain and the way in which their computer is used, it may help to identify the user.

The cookies used on this website are, in any event, of a temporary kind, the only purpose being to make their subsequent transmission more efficient. Under no circumstances will cookies be used to collect personal information.

The CDP. website uses cookies to:

• Ensure that its web pages can run correctly
• Store your preferences, such as the language or font size you have chosen
• Learn your browsing experience
• Collect anonymous statistical information, such as which sections you have visited, or how long you stayed on our site.

Cookies are only associated to an anonymous user and their computer/device and do not provide references that reveal personal details. You can, at any, time, access enter browser configuration to modify and/or block cookie installation. Service functioning quality may, however, be affected.

From the technical viewpoint, cookies enable websites to work more nimbly and adapted to users’ preferences, such as saving the language or detecting the access device, for example.

They establish protection and security levels that impede or hinder cyber-attacks against the website or its users and provide web managers with statistical data collected in the cookies to improve their service quality and experience, also serving to optimise the advertising we show users, offering them what best matches their interests.

COOKIE TYPES

Session cookies expire when the user leaves the website or logs out of their browser, i.e., they are active whilst the visit to the website lasts and are then deleted from our computer when we leave it.

Persistent cookies expire when the purpose for which they have been created has been fulfilled or alternatively when they are deleted manually, they have a deletion date and they are usually in online purchasing processes, personalisations or in logins so we do not have to be constantly entering our password.

Alternatively, depending on which entity it is that the computer or domain from where the cookies are sent and processes the data obtained, we can differentiate between first-party and third-party cookies.

First-party cookies are those cookies sent to your computer and managed exclusively by CDP. for our website to run better. The information we gather is used to improve the our service quality and your user experience.

If you interact with our website contents, third-party cookies may also be installed (for instance, when you press a social media button or view videos housed on another website); these are cookies set by a domain other than our website. We cannot access the data stored in other website cookies when you browse said websites.

Browsing this web portal implies the following kinds of cookies may be installed:

1. FUNCTIONAL COOKIES

This type of cookie remembers your preferences for the tools located in the services, so you do not have to reconfigure the service every time you visit. These cookies will not gather any information about you that may be used for advertising purposes or information about your preferences (such as your user data) beyond that visit in particular.

2. ANALYTICAL PERFORMANCE COOKIES

Every time a user visits a service, a tool from an external provider (Omniture, Netscope, Comscore and other similar ones that may be added to this list in the event of them varying with respect to those currently existing) generates an analytics cookie on the user’s computer. This cookie, which is only generated in the visit, will enable [email protected] services to anonymously identify the visitor in subsequent visits.

The main aims they pursue are:

• To allow anonymous identification of browser users through the ”cookie” (it identifies browsers and devices, not people) and hence approximate recognition of the number of visitors and their trend over time.
• To anonymously identify the most frequently visited contents and hence those that are most attractive to users.
• To know whether the user that is accessing is a new or repeat visitor.

3. BEHAVIOURAL ADVERTISING COOKIES

This type of cookies enables expansion of the information about the advertisements shown to each anonymous user, if there are any. Amongst others, they store the duration, how frequently advertising positions are viewed, interaction with them or the user’s browsing patterns or behaviour because they help to build an advertising interest profile. They thus enable advertising to be targeted that is more relevant to the user’s interests.

Google Analytics:

The application we use to obtain and analyse browsing information is: Google Analytics:

www.google.com/analytics/ and

http://www.google.es/intl/es/analytics/privacyoverview.php.

This application has been developed by Google, which provides the service that analyses our website traffic. This company can use this data to improve its own services and to offer services to other companies. The links above will inform you about these other uses.

This tool does not obtain users’ names or surnames, nor the postal address from where they log in. The information obtained is related, for instance, to the number of page hits, the language, the social media on which our news is published, the city to which the IP address from which users access is assigned, the number of users visiting us, visit frequency and repetition, the length of the visit, the browser they use, the operator or terminal type used for the visit.

We use this information to improve our website, detect new requirements and assess the improvements to be introduced to provide the users visiting us with a better service.

HOW TO MANAGE COOKIES:

Users can configure their browser to advise them of cookies being received and to impede them from being installed on their computer or device.

CDP cannot guarantee that this website will work correctly if the cookies policy is modified.

The majority of browsers support the use of cookies. As a user, however, you can choose whether or not to accept cookies.

The most common options browsers offer are:

• Reject all cookies.
• The browser asks the user whether it should accept each cookie individually.
• Accept all cookies.

Your browser may also include the option of better specifying which cookies should be accepted and which not. You also have the option of viewing and deleting cookies individually. If you do not know how to manage your cookies and your web browser’s privacy policy, you can find out how in your browser’s “Help” menu.

HANDLING COOKIES ON DIFFERENT BROWSERS:

We recommend you consult your browser’s “Help” menu. Or you can access the support pages of the main web browsers:

Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=es&answer=95647

Firefox: http://support.mozilla.org/es/home

Internet Explorer: http://support.microsoft.com/ph/807/es-es

Safari: http://support.apple.com/kb/HT1677?viewlocale=es_ES

Opera: http://help.opera.com/Windows/8.54/es-ES/index.html

PRIVACY POLICY

• Exclusion of responsibility for graphic information on the portal   Images and animations are not contractual but merely illustrative may be subject to technical, legal or commercial changes.  

• The infographics and 3D models of the facades, common elements and remaining spaces are orientative and may be modified in the technical projects.  

• The furniture of the infographics and 3D models is not included in the houses. The equipment of the homes will be indicated in the corresponding quality report.  

• All the information will be given or will be delivered according to the provisions of Real Decreto 515/1989 and other regulations that may complement it, whether they are state or autonomous.