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Privacy Policy

Last updated May 25, 2018. This privacy document (Privacy Policy, Agreement) describes how Inmobiliaria Alegria, coop.V. handles personal information and protects your privacy. The Company acts as the operator (hereinafter referred to as the operator) of your data, which is described in more detail in the section “Organizations collecting personal data” of this document and the data processing and protection processes at alegria-premium.com. This Agreement may be amended or supplemented at the discretion of the Company and the administration of the site at any time by sending a special notice to you by e-mail or otherwise. However, we encourage visitors and users of our sites to review the Privacy Policy regularly. All personal (private) information that we receive and maintain, which is defined as any information that identifies an individual or identifies his or her location, is subject to the terms of this Privacy Policy, as amended. Personal information is defined as any information relating to an identified or identifiable individual based on such information. Therefore, the Company has made every effort to ensure that you have easy and unrestricted access to information about the privacy policy and at any time you can decide to comply with it and use your data. The Company’s policy regarding the processing of personal data is presented on all pages of the site in the footer and can be accessed by clicking on https://alegria-premium.com/privacy-policy. To update your personal information and preferences, see “Accessing Personal Information, Updating, Deleting Information and Changing Privacy Settings. In accordance with the European Parliament and Council of the European Union Regulation 2016/679 on the protection of individuals with regard to the processing of personal data (hereinafter GDPR), the Company is committed to comply with its obligation of secrecy with regard to personal data, to follow the EU regulations and legislation on the receipt, processing and protection of data. For this purpose, the Company will take the necessary measures to secure the personal data received and to protect it from unauthorized access.

Fundamentals of privacy protection

The company supports the EU Regulation 2016/679 of the European Parliament and of the Council of the European Union on the protection of individuals with regard to the processing of personal data (GDPR). The company makes every effort to treat all personal data received from member states of the European Union (EU) in accordance with the applicable principles of the Privacy Shield Framework. To learn more about the Privacy Shield Framework, we refer you to the European Commission’s data protection, privacy and data retention regulations and rules inside and outside the EU, https://ec.europa.eu/info/law/law-topic/data-protection_en. The company is responsible for processing the personal data it receives in accordance with the GDPR and transfers the corresponding obligations to any third-party agents acting on its behalf. The company observes the principles of confidentiality protection with respect to any further transfer of personal data from the EU, including with respect to further liability portability. The subjects whose personal data is processed by the Company, with or without the use of automation tools, are:

  • users and subscribers of the Company’s website on the Internet;
  • The Company’s employees or persons who had an employment relationship with the Company, as well as their family members;
  • Persons having civil law contractual relations with the Company or being at the stage of pre-contractual or executed relations of such nature; partners and participants of the Company;
  • The Company’s counterparties represented by the individual entrepreneurs, their employees; founders, managers, representatives (persons acting on the basis of the power of attorney) and
  • employees of the legal entities that have or have had contractual relations with the Company or wish to conclude contracts with the Operator;
  • Visitors to the Company’s offices;
  • Other persons whose processing of personal data is necessary for the Company to fulfill the purposes specified in this Policy.

When we say you””, “”your””, “”you”” or “”you””, we mean the subject. As it relates to personal data received or transmitted under the GDPR, the Company is subject to the enforcement of the European Commission. In certain situations, the Company may be required to disclose personal data as a result of a lawful request received from public authorities, including to enforce requirements related to national security and law enforcement. If you have concerns about privacy or data use that we have not been able to resolve satisfactorily, you may contact the Privacy and Data Protection Officer listed in the “”Authorized Data Processor”” section. When the dispute resolution procedure with the authorized person of the Company has been exhausted, you have the right to resort to binding arbitration or to contact the relevant authorities for the protection of user data. For official information on EU national data protection authorities, click here.

Organization collecting personal data

This Agreement and the Privacy Policy are issued on behalf of Inmobiliaria Alegria, coop.V. and/or its affiliates. When we say “Company”, “personal data operator”, “we”, “our”, “us” or “us” and “Inmobiliaria Alegria, coop.V.”, we are referring to the relevant organization responsible for processing your data. Which Company acts as the operator of your data is determined by the relevant terms of service or this Agreement. Personal data on this website is obtained by the Company: Inmobiliaria Alegria, coop.V. TIN: F42626911 Registered address: Avenida General Marva 24 Email: info@alegria-premium.com Tel: +34 664 25 76 97

Company authorized person in charge of data processing

The Company has appointed a designated person (hereinafter DPO – data protection officer) in charge of compliance with the Privacy Policy, personal data protection, communication in matters related to this privacy document. The person in charge of compliance with the Privacy Policy, control and management of personal data, systematic monitoring of data of individual users and individuals, responsible for compliance with the rules of protection is Andrey Samylin.

  • Samylin Andrei
  • Email: info@alegria-premium.com

If you have any questions or concerns about this Agreement and Privacy Policy, how we manage your personal data, or if you have any other concerns about personal information, be sure to contact our Privacy Officer.

Categories of personal data collection and information handled

You may perform some transactions on the site without providing personal information. But when you register, leave information to use the Company website and other products or services, and become a subscriber to the site so that we can provide services to you, we may collect the following personal information from you

  • Contact information (your name, phone number, email address);

Depending on the transaction, some of the information requested is mandatory and some is at your discretion. If you do not provide the required information, you will not be able to complete those transactions and to fully interact with the site. As is the case with most Web sites, the Company and its engaged third-party support operators may receive certain technical and routing information about your computer to facilitate your use of the Web site and its services as you use the Web site. For example, we may record environmental variables such as the browser type, operating system, processor speed and IP address of your computer. We use these environmental variables to track your use of the site and its services and to make them more convenient for you. The Company also uses these environment variables to track traffic to the site. We may from time to time match this data with your personal information in order to better understand the needs of site visitors. To reduce errors in our database, verify the authenticity of users and prevent misuse of the system, we may from time to time supplement the personal information you submit with information from third-party public sources. We may supplement the information we receive directly from you with information held in third party databases, such as demographic or company data, to increase the likelihood that any marketing messages sent to you will be of real use and interest to you. Please refer to this document for a list of third-party support operators that we may use. When you download and use our mobile applications or services, we automatically receive information about the type of device you are using and the version of your operating system. We may collect and use information about the geographic location of your computer or mobile device. The purpose of collecting this data is to provide you with information about services in your area that might be of interest to you and to improve the products and services offered there.

Purposes for receiving and storing data

All personal data that the Company receives is necessary in order for us to better understand your needs in interacting with the Site, to improve technical features and marketing activities for your user experience. We collect personally identifiable information and use environmental variables to track your use of the Site and its services and to make them more convenient for you. The Company also uses such environmental variables to track traffic to the site. We may from time to time match this data with your personal information in order to better understand the needs of site visitors.
How your personal information is used
The Company receives your personal information in order to provide you with services, fulfill our legal obligations and improve our products and services. We do not sell, rent or share your personally identifiable information with third parties in any way other than as described in this Privacy Policy. The Company may use this information for the following purposes:

  • Responding to inquiries the Company receives from users while interacting with the website;
  • To send you information about products or services that you have requested;
  • To respond to inquiries and complaints sent to the help desk;
  • informing you about special offers and services of the Company and selected third parties;
  • managing promotions in which you participate by accepting this Agreement;
  • investigating, preventing or taking action regarding illegal activities and/or violations of the terms of service;
  • conducting product/service research and development to improve our website and offerings and services;
  • Meet your personal requests and prepare services and offers individually for you.

Information collected through cookies, logs, transparent image data, and/or third-party resources is used to build a database of your preferences. We link your personally identifiable information and/or membership history to information in this database to customize our promotional offers, improve site content and identify your interests. In some cases the Company is required by law to disclose your personal information for national security or law enforcement purposes at the official request of authorized agencies. In situations where we are required to do so by law (such as to enforce a subpoena, warrant, order or judgment against the Company), or when we believe that disclosure is necessary to protect our rights, to avoid litigation, to protect your safety or the safety of others, to investigate fraud, and/or at the request of government authorities. We may also disclose information about you if such disclosure is necessary in the interest of national security, law enforcement or other matters of national importance.

Sharing personal information with other organizations, service providers and agents

The Company engages certain ancillary operators (which include organizations and third parties as listed below), subcontractors and content delivery networks that assist in maintaining the site and providing the services described in the service agreement.

About Auxiliary Operators.

An auxiliary operator is a third party organization (including IE Dmitry Vladimirovich Savateev and affiliated companies) engaged by the Company to process data that has or may have access to customer or user information (including that containing personal data) or the ability to process such information. The Company commits to a commercially reasonable due diligence process to evaluate the security and privacy practices of proposed auxiliary operators who will or may have access to the Company’s data or the ability to process it. The Company requires the auxiliary operators with whom it works to adopt certain terms and conditions governing the use of the information and personal data of the subjects, including without limitation the obligation to

  • Process personal data in accordance with Regulation 2016/679 of the European Parliament and of the Council of the European Union on the protection of individuals with regard to the processing of personal data (GDPR);
  • engage trustworthy employees who comply with contractual obligations in the area of privacy and data protection to the extent necessary in accordance with applicable data protection laws;
  • Provide regular training on data security and data protection to employees who are granted access to personal data;
  • Implement and apply appropriate technical and organizational measures to ensure the security, integrity and confidentiality of customer information and personal data;
  • conduct annual attestations confirming compliance with applicable data protection laws, or allow the Company to audit such compliance;
  • Immediately inform the Company of any actual or potential security incident or data breach;
  • Provide all reasonable assistance to the Company when dealing with requests from data controllers, data subjects or data protection supervisory authorities, if any.

The information provided here is intended solely to demonstrate the Company’s interactions with data controllers and to provide an up-to-date list of the third-party data controllers engaged by the Company as of the effective date of this Privacy Policy (i.e. those that the Company may engage to provide services and to operate them). If you have any questions about this notice or the Company’s use of these auxiliary operators, please contact us at info@alegria-premium.com.

A list of such third-party auxiliary operators:

  • Google.Analytics. You can find more information about using the system here: https://www.google.com/analytics/learn/privacy.html
  • Yandex.Metrika. Detailed information about using the system can be found here: https://yandex.ru/legal/confidential/
  • Yagla. Detailed information about using the system you can find here: https://yagla.ru/p_polozhenie-o-zashchite-personalnyh-dannyh/
  • Lptracker. More information about using the system you can find here: https://lptracker.io/index_land_pc1.php?&utm_source=land_pc5
  • Facebook Pixel. More information about using the system can be found here: https://www.facebook.com/privacy/explanation
  • Pixel VK application. More information about using the system can be found here: https://vk.com/page-19542789_53869861
  • RedConnect. More information about using the system can be found here: https://web.redhelper.ru/nx/eula?c=rhlp&site=https://redhelper.ru
  • Google Captcha (reCAPTCHA).
  • Subscription to Telegram-channel. More information on how to use the system you can find here: https://tlgrm.ru/privacy
  • MailChimp
  • engage trustworthy employees who comply with contractual obligations in the area of privacy and data protection to the extent necessary in accordance with applicable data protection laws;
  • Provide regular training on data security and data protection to employees who are granted access to personal data;
  • Implement and apply appropriate technical and organizational measures to ensure the security, integrity and confidentiality of customer information and personal data;
  • conduct annual attestations confirming compliance with applicable data protection laws, or allow the Company to audit such compliance;
  • Immediately inform the Company of any actual or potential security incident or data breach;
  • Provide all reasonable assistance to the Company when dealing with requests from data controllers, data subjects or data protection supervisory authorities, if any.

The information provided here is intended solely to demonstrate the Company’s interactions with data controllers and to provide an up-to-date list of the third-party data controllers engaged by the Company as of the effective date of this Privacy Policy (i.e. those that the Company may engage to provide services and to operate them). If you have any questions about this notice or the Company’s engagement of these auxiliary operators, please contact us at info@alegria-premium.com.

The security of personal data processed by the Company is ensured by implementing legal, organizational and technical measures necessary to ensure the requirements of federal legislation in the field of personal data protection. To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

  • Appointment of officials responsible for the organization of processing and protection of personal data;
  • Restricting the list of persons allowed to process personal data;
  • Familiarization of data subjects with the requirements of the EU legislation and the Operator’s regulatory documents related to processing and protection of personal data
  • Organization of accounting, storage and circulation of media containing information on personal data
  • Identification of personal data security threats in the course of personal data processing, formation of threat models based on such threats models
  • Development of personal data protection system based on the threat model;
  • Verification of readiness and efficiency of use of information protection means;
  • Delimitation of user access to information resources and software and hardware for information processing
  • registration and accounting of actions of users of personal data information systems;
  • Use of antivirus and recovery tools of personal data protection system;
  • Use of firewall, intrusion detection, security analysis and cryptographic protection of information where necessary;
  • Organization of access control to the Operator’s territory, security of premises with technical means of personal data processing.”

How long will we keep your information?

We will retain your information as long as your account is active, as long as the information is needed to provide you services, or for as long as necessary to fulfill our legal obligations. If you wish to delete your account or request that your information no longer be used to provide services to you, you may contact an authorized person at info@alegria-premium.com or the company address. We will respond to your request within 30 days. We will retain and use your information for as long as we need it to fulfill our legal obligations, resolve disputes, and enforce our agreements.
Opting Out of Marketing Activities, Updates, Newsletters and/or Newsletters

You may opt-out of receiving email updates and newsletters from the Company and/or email communications from partners by making an opt-out choice or by contacting the Data Privacy Officer (DPO) at info@alegria-premium.com. You may also opt out of receiving such communications during the registration process. However, you will be notified by the Company if the Terms of Service or the Terms of Service for Website Users change. In addition, we will send you service-related communications, including a registration letter, in any event. Generally, you cannot opt out of receiving these communications, which are not advertisements. If you do not wish to receive them, you may delete your personal information and cancel your receipt, contact the DPO responsible person to have your data deleted by info@alegria-premium.com, or not use the site. If you do not agree to be bound by all or some of the terms of this agreement – do not use the site and leave it immediately.

Changes to the Privacy Policy

The Company reserves the right to change this Privacy Policy at any time at its sole discretion and will specifically notify you of material changes by e-mail or other means. Any changes to the Privacy Policy can always be found on the pages of the website or by contacting the DPO’s responsible person, Andrei Samylin, by e-mail at info@alegria-premium.com, requesting information about the changes. We do our best to make information about changes in the Privacy Policy available to you at any time. If due to such changes you would like to change the way the Company is permitted to use your personal information, you may do so by following the procedure described in the Updating personal information and privacy settings or by contacting us at info@alegria-premium.com or the responsible DPO employee. Once you have posted changes and updates to the Privacy Policy on the website, you are deemed to be aware of any material changes to the Privacy Policy and they will apply to you with the following exception: if at the time you provide personal information to the Company you are given the opportunity (as at this time) to restrict the Company or third parties from using such information to communicate with you, the Company is not permitted to change your preferences in this regard without your explicit consent. However, if the Company ceases to exist as a legal entity, transfers its assets, control and management to another company, merges with or into another company, the Company may, without your consent, provide that company with user and customer information relating to that portion of its business or nonprofit activities that has been transferred to another company. In doing so, the Company is required to post a notice of such a sale, merger or acquisition on this site.

Cookie and tracking technologies

When you search the web, the site may automatically collect information such as information about your Internet Service Provider, browser type and version, operating system and device type, average time spent on our site(s), pages viewed, information accessed, the Internet Protocol (IP) address used to connect your computer to the Internet, and other relevant statistics. This information is sometimes called Web analytics or clickstream data. We may combine this automated log information with other information we collect about you. We do this in order to improve the services we offer you, improve our marketing strategy and analytics, and ensure that the site is well functioning. The Company and our affiliated companies, analytics and services use technologies such as cookies, beacons, tags and scripts to provide site functionality. These technologies are used to analyze trends, administer the site, track users’ movements around the site, and gather demographic information about our users in general. We may receive reports based on these technologies from these companies both on an individual basis and in aggregate form. A cookie is a small, unique text file that a website sends to your computer when you visit that site. We may use session cookies, which are automatically deleted when a user closes their browser, and/or persistent cookies, which remain on your computer until manually deleted. Most web browsers can either warn you about the use of cookies or refuse to accept cookies altogether. If you do not want us to involve – cookies in your browser, you can set your browser to refuse cookies or to notify you when a website attempts to set cookies on your computer. Refusing cookies may affect your ability to use this site. We work with a third party organization either to display ads on our website or to manage the display of our ads on other websites. The third party with whom we partner may use technology, such as cookies, to collect information about your activities on this website and other websites in order to serve ads to you based on your browsing activities and interests. If you are located within the European Union and do not want this information to be used to offer you ads based on your interests, you can opt out by clicking here. You can also adjust the display of advertisements by deleting cookies from the browser you are using. Please understand that this does not mean you are opting out of receiving ads. You will still receive normal advertising.

Web Beacon

A web beacon is a small graphic file on a web page that can be used to retrieve certain information from your computer, such as your IP address, how long the web page has been viewed, the browser type, and the presence of cookies previously created by the same server. We use these web beacons in strict compliance with applicable laws. The Company or third-party service providers may use web beacons to monitor the effectiveness of web sites of third parties providing various services to us, including marketing services, or to collect aggregated statistics about online visitors to the site and cookie management. You have the option of disabling certain web beacons by blocking the cookies associated with them. In this case, the web beacon will register an anonymous visit from your IP-address, but the information in the cookie will not be recorded. If you subscribe to our newsletters or other materials, we may monitor the activities of recipients, for example, through embedded links within messages we may collect information about the number of recipients who have opened a particular message. We collect this information in order to assess which areas of the site are of most interest to users.

Links to Third Party Sites

Our website contains links to other websites whose privacy policies may differ from those of the Company. If you submit personal information to any of these sites, your information will be treated in accordance with this site’s privacy policy. We encourage you to carefully read the privacy policies of each site you visit.

Widgets for social networks

Our website may contain social media related features and widgets, such as a “Share” button and interactive mini-programs that run when you interact with the site. These features may acquire your IP address, track which page you are visiting on our site, and set cookies to function properly. Social Media Features and Widgets may run either directly on our site or on third-party resources. Your interaction with these features is governed by the privacy policy of the company providing them.

Email addresses for the recommendation program

If you want to use our referral program to tell a friend about our site or a particular site page, you need to provide their name and email address to the DPO responsible. We will send them a one-time email inviting them to visit our site. The company stores this information for the sole purpose of sending this email and tracking the effectiveness of our referral program. Your friend may contact the responsible DPO person at info@alegria-premium.com to request that this information be removed from our database. Receiving and Processing Personal Information from Children – Subjects Under 21 We do not intend to solicit or receive personal information from anyone under the age of 18. If you are under 18, do not enter information on this site or use our services. If you believe that your child under the age of 18 has entered personal information, please notify the responsible DPO person at info@alegria-premium.com so that we can delete your child’s information and account. If there is any suspicion related to the minority of a website user or company customer, the company employee interacting with the subject or an authorized DPO employee has the right to request the consent of the parent or guardian to the processing of the child’s personal data.

Privacy Complaints

Individuals residing in certain countries, including the European Economic Area, have certain legal rights with respect to their personal information. You may have the right to request access to the information and to request that the information be updated, deleted or corrected, subject to any exemptions set out in the law. To the extent that the Company processing your personal data is subject to the EU General Data Protection Regulation, the Company relies on its legitimate interests described above to process your data. When the Company processes certain personal data for its own targeted marketing activities, you have the right to object at any time to the Company’s use of your personal information for such purposes. The Company takes user privacy seriously. If you believe that the Company is not complying with this Privacy Policy with respect to your personal information, you may contact the DPO Privacy Officer at info@alegria-premium.com. In your letter, describe in as much detail as possible the instances of the Company’s alleged violation of the Privacy Policy. We will review your complaint as soon as possible. If you do not receive confirmation of receipt of your complaint within 30 days of sending the letter or your complaint is not resolved in a satisfactory manner, you can always contact an outside partner in information and data protection dispute resolution, or file a complaint with the local data protection dispute resolution authorities. Information about updates to data protection laws and regulations and authorized data protection authorities: https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules_en If you have any questions about this Privacy Policy, our practices or your interaction with the website, you can contact our Data Protection Officer, Andrei Samylin, at info@alegria-premium.com. Details of Inmobiliaria Alegria, coop.V. TIN: F42626911 Address: Avenida General Marva 24 Email: info@alegria-premium.com Tel: +34 664 25 76 97 Reference to Regulation 016/679 of the European Parliament and Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repeal of Directive 95/46 / EC (General Data Protection Regulation): https://eur-lex. europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2016.119.01.0001.01.01.ENG&toc=OJ%3AL%3A2016%3A119%3ATOC Information on updates to data protection legislation and regulations as well as data protection authorities: https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules_en