Introduction
Truliving Vallecas, S.L.U., as owner of the building (hereinafter, «Truliving Vallecas», the «Company» or «we»), in accordance with the legislation in force on Personal Data Protection, hereby informs the natural persons who have entered into a lease or reservation contract for a flex-living space or have expressed an interest in doing so (hereinafter, the «Tenant», the «Potential Tenant», «You» or «Yourselves») of the Privacy and Data Protection Policy that applies to the processing of their personal data.
The Company undertakes to process the Tenant’s and Potential Tenant’s data in accordance with the personal data protection regulations applicable and in force at any given time. Specifically, the Company will comply with the provisions of the General Data Protection Regulation («GDPR«) and the Spanish Organic Law on Data Protection and Guarantee of Digital Rights («LOPDGDD«), as well as any other related regulations in force at any given time.
The Company hereby informs you of its Privacy Policy in order to make you aware of the processing of your data, as well as of the fundamental principles on personal data protection that it applies.
You should read this policy carefully in order to understand what data of yours we process, how it is processed, for what purposes, for how long, with whom it may be shared, and what your rights are in this respect and how you may exercise them.
Who is the controller?
The controller of the Tenants’ personal data is Truliving Vallecas S.L.U., a company with registered office at Luchana 23, 7th floor, 28010 Madrid, and Tax ID No. B-88476775.
Contact details of the controller.
If you have any questions regarding the processing of your Personal Data, you may contact us by sending a communication (i) by post to Luchana 23, 7th floor, 28010 Madrid; or (ii) by email to privacidad@grupogmp.com.
What personal data do we collect and what do we use it for?
Under this Privacy Policy, «Personal Data» means any information that identifies you or can be used to identify you, such as your name, telephone number or email address, and that is necessary to provide the services properly.
This data is processed when you interact with the Company for the management of your request for information or the management of your stay, as described in this Privacy Policy.
The Company asks that you update your Personal Data whenever changes occur and that you always provide truthful information, since the Company must hold up-to-date information.
The Company will process the Tenant’s Personal Data in accordance with the purposes set out below:
| Purpose | Legal basis | Category of Personal Data |
|---|---|---|
| Reservation management | Necessary for performance of the contract or for taking pre-contractual measures (Art. 6.1.b GDPR) | Name, surname(s), telephone, email |
| Provide the services included in the rental (Wi-Fi, electricity, water, gym, etc.) | Necessary for performance of the contract or for taking pre-contractual measures (Art. 6.1.b GDPR) | Name and surname(s), email, card identifier |
| Control access to the building and common areas by card | Necessary for the Tenant’s security on the basis of the Company’s legitimate interest in maintaining the security and control of the facilities (Art. 6.1.f GDPR) | Card identifier, access logs |
| Video surveillance | Necessary for the Tenant’s security on the basis of the Company’s legitimate interest in maintaining the security and control of the facilities (Art. 6.1.f GDPR). More information on this processing at privacidad@grupogmp.com | Image |
| Send satisfaction surveys after use of our services | Necessary for the Company to improve the quality of the service it provides on the basis of its legitimate interest (Art. 6.1.f GDPR) | Name and surname(s), email |
| Send commercial communications about events, additional services and promotions | Only if the Tenant has given consent for this in accordance with Art. 6.1.a GDPR or Art. 21 of the LSSI | Name and surname(s), email |
| Send notices and important updates about your stay or reservation | Necessary for performance of the contract or for taking pre-contractual measures (Art. 6.1.b GDPR) | Name and surname(s), email, contractual information |
The Company will process the Potential Tenant’s Personal Data in accordance with the purposes set out below:
| Purpose | Legal basis | Category of Personal Data |
|---|---|---|
| Reservation management | Necessary for performance of the contract or for taking pre-contractual measures (Art. 6.1.b GDPR) | Name, surname(s), telephone, email |
| Assess you as a potential Tenant (pre-contract assessment) | Necessary to assess whether the Potential Tenant meets the requirements before formalising the contract, on the basis of the Company’s legitimate interest / performance of the contract or for taking pre-contractual measures (Art. 6.1.f / Art. 6.1.b GDPR). More information on this processing at privacidad@grupogmp.com | Name and surname(s), ID card/Passport, payslips, employment contract for employed workers; income tax return, bank account statement and registration for economic activities tax (IAE) for self-employed workers; bank account statement for unemployed applicants; and data obtained from previous stays relating to compliance with community rules. |
| Send commercial communications about events, additional services and promotions | Only if the Potential Tenant has given consent for this in accordance with Art. 6.1.a GDPR or Art. 21 of the LSSI | Name and surname(s), email |
| Send notices and important updates about your potential reservation | Necessary for performance of the contract or for taking pre-contractual measures (Art. 6.1.b GDPR) | Name and surname(s), email, contractual information |
| Respond to requests submitted through our communication channels | Necessary to handle and manage the relationship established for taking pre-contractual measures (Art. 6.1.b GDPR) or to respond to any request that you have submitted to us (on the legal basis of your consent under Art. 6.1.a GDPR) | Name and surname(s), email |
Retention periods
Your Personal Data will be retained for the time strictly necessary for the processing purposes for which it has been provided, provided that, to the extent applicable, you have not withdrawn your consent.
Subsequently, your Personal Data will be blocked, as appropriate, and retained until the expiry of the statutory blocking periods relating to the liabilities to which Truliving Vallecas is subject.
Recipients of Personal Data
We inform you that your Personal Data will not be disclosed to other persons or companies for use for their own purposes.
Service providers or suppliers with whom the Company has entered into the relevant agreements may have access to your Personal Data when they need access to such data in order to preserve Truliving Vallecas’ relationship with you. In any event, the necessary legal and organisational measures will be taken to guarantee the security of and access to Personal Data.
However, Truliving Vallecas will disclose Personal Data and any other information in its possession or accessible through its systems to the competent authorities where required in accordance with the legal and regulatory provisions applicable to the case. In particular, where appropriate, it will provide contracting and overnight stay data to the Ministry of the Interior in compliance with the obligations laid down in Royal Decree 933/2021 of 26 October, on the legal basis of compliance with a legal obligation (Art. 6.1.c GDPR).
Rights of Tenants and Potential Tenants
In accordance with data protection regulations, you have the right to:
| Right | What does it involve? |
|---|---|
| Right of access | Obtain confirmation as to whether or not Personal Data is being processed and, where that is the case, access to that data and to information on the purposes of the processing, the categories of Personal Data concerned, the recipients to whom the Personal Data is disclosed, and the envisaged period during which the Personal Data will be stored, among other information |
| Right to rectification | Obtain the rectification of inaccurate Personal Data concerning you |
| Right to portability | Receive the Personal Data concerning you in a structured, commonly used and electronically readable format, and to share such data with another controller without hindrance, in the cases provided for by law |
| Right to object | Withdraw consent at any time, without affecting the lawfulness of processing carried out previously. Right to object to a processing activity based on legitimate interests |
| Right to erasure | Erase the Personal Data concerning you where the data is no longer necessary for the purposes for which it was collected |
| Right to restriction | Obtain restriction of the processing of Personal Data, which will thereafter only be processed for the establishment, exercise or defence of legal claims |
If you wish to exercise any of these rights, you may contact Truliving Vallecas, S.L.U. by sending a written request to Luchana 23, 7th floor, 28010 Madrid, or by email to privacidad@grupogmp.com.
We inform you that Truliving Vallecas will deal with the right exercised within a maximum period of one month from the date of receipt of the request, although this period may exceptionally be extended to two months, taking into account the complexity of the request, in which case the Tenant or Potential Tenant who has exercised the data protection right will be notified.
Likewise, if you consider that the processing of your Personal Data does not comply with the regulations in force, you have the right to lodge a complaint with the competent supervisory authority. In Spain, you may contact the Spanish Data Protection Agency (AEPD) or any body that may replace it in the future.
International data transfers
The Company informs you that, although no international transfer is envisaged, the provision of services or the handling of requests for information by Truliving Vallecas for the Tenant and Potential Tenant may be associated with implicit international data transfers.
Should this be the case, such transfers will be governed in accordance with the provisions of the legislation in force on data protection, as indicated by such third parties.
Personal Data of third parties
If you include Personal Data relating to another person, you must first inform that person of the contents of this Privacy Policy. In any event, you warrant that you have obtained the prior consent of such third parties for the communication of their Personal Data to the Company.
Security measures
Truliving Vallecas will process your Personal Data in an absolutely confidential manner. It has also implemented appropriate technical and organisational measures to guarantee the security of your Personal Data and prevent its destruction, loss, unlawful access or unlawful alteration. In determining these measures, criteria such as the scope, context and purposes of the processing, the state of the art and the existing risks have been taken into account.
Amendment of the Privacy Policy
The Company reserves the right to amend and/or update this Privacy Policy at any time in order to adapt it to the applicable legislation. In any event, you will be notified of any substantial change affecting the processing of your Personal Data, whether by direct communication or by any other means that guarantees adequate information.