Privacy Policy

DOM Tenerife

1. DATA CONTROLLER DETAILS

Company name: GUTU Y DOMÍNGUEZ ASOCIADOS S.L. (hereinafter, the “Company” or the “Controller”).

Tax ID (CIF): B76759893

Registered address: Avenida Kurt Konrad Mayer 63, El Madroñal, 38660 Adeje, Santa Cruz de Tenerife, Spain

Telephone: +34 673 560 035

Email for data protection matters: info@domtenerife.es

1.1. Applicable law

Our Privacy Policy has been drawn up in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), and with Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD).

By providing us with your data, you declare that you have read and understood this Privacy Policy and give your unambiguous and express consent to the processing of your personal data for the purposes and on the terms set out herein.

The Company may amend this Privacy Policy to adapt it to new legislation, case law or interpretations of the Spanish Data Protection Agency (AEPD). These privacy terms may be supplemented by the Legal Notice, the Cookie Policy and any General Terms and Conditions that may apply to specific products or services, where such access involves any particularity regarding the protection of personal data.

1.2. Data Protection Officer

The Company has not appointed a Data Protection Officer.

2. PURPOSES OF THE PROCESSING OF PERSONAL DATA

We process your personal data for the following purposes:

• To provide you with information about the products and services offered by our company, as described on this website, which may lead to your referral to professionals in the field of real estate services.
• To arrange the provision of our services through the acceptance of the corresponding quotation / order and/or the signing of a commercial contract.
• To send you, by email and/or post, news and updates about our company, as well as updates to our catalogue of products and services.
• To manage the Users of the Website and, where applicable, the activation and administration of User registration in the restricted area of the Website.
• To channel requests for information, suggestions and complaints from data subjects so that they can be handled and resolved.
• To keep you informed, by electronic means or mobile devices, of any information that may be of interest to you;
• To manage the sending of the Newsletter to users who subscribe to it.

2.1. Data retention period

Personal data will be kept only for as long as is reasonably necessary, taking into account the need to answer questions that arise or resolve problems, make improvements, activate your services and comply with the requirements of applicable law. This means that personal data may be kept for a reasonable period of time even after the data subject has stopped using the WEBSITE.

In the case of subscriptions, we will keep your personal data from the moment you give us your consent until you withdraw it or request the restriction of processing. In such cases, we will keep your data blocked for the periods required by law.

2.2. Phone calls and transcription

When you ask us to call you, for example through a form, we call you from +34 822 27 29 92 on weekdays between 9:00 and 21:00 your local time. The call may be started by our AI assistant, who introduces itself as such, before putting you through to one of our advisors.

Calls with DOM Tenerife may be transcribed for internal follow-up. No audio is kept: it is transcribed and deleted immediately. Only the text is kept, in our CRM and for internal use, for a maximum of 24 months.

2.3. Messages via Instagram and Facebook Messenger

If you message us on Instagram (@domtenerife) or Messenger (DOM Tenerife Real Estate page), we receive your message, your username and the identifier provided by Meta, and we store them in our CRM to answer your enquiry. Only DOM Tenerife staff can see them and we do not use them to send you advertising.

To help the advisor handling your enquiry, the conversation history may be processed with Anthropic’s Claude API to produce an internal summary. Anthropic acts as a data processor, does not use your data to train its models, and nothing is ever sent to you automatically.

We keep this data for as long as the business relationship lasts and for at most 24 months after the last contact. You can ask us to delete it at any time at info@domtenerife.es.

3. LEGAL BASIS AND DATA COLLECTED

The legal basis for processing your data is the express consent given by means of a clear affirmative act (completing the corresponding form and ticking the box accepting this policy) at the time you provide us with your personal data.

3.1. Consent to process your data

The legal basis for processing the personal data of Users and/or Clients lies in points (a), (b) and (c) of Article 6(1) of Regulation (EU) 2016/679 of 27 April 2016.

• The User and/or Client has given express consent for the purposes described that require the processing of the User’s and/or Client’s data, and, within the framework of a contractual or pre-contractual relationship, for handling their request for information and/or the performance of the service.
• The User and/or Client has given express consent by means of a clear affirmative act (completing the corresponding form and ticking the box accepting this policy) at the time of providing their personal data.

3.2. Categories of data

The data collected belong to the category of identification data, such as: first name and surname, telephone number, postal address, company, email address, as well as the IP address from which the data collection form is accessed.

4. SECURITY MEASURES

As part of our commitment to guaranteeing the security and confidentiality of your personal data, we inform you that the technical and organisational measures necessary to guarantee the security of personal data and prevent its alteration, loss, unauthorised processing or access have been adopted, taking into account the state of the art, the nature of the data stored and the risks to which they are exposed, in accordance with Article 32 of the GDPR (EU) 2016/679.

5. DISCLOSURE OF DATA AND DATA PROCESSORS

Your data are not disclosed to third parties, except where authorised by tax, commercial and telecommunications legislation, or where required by a judicial authority.

To provide our services, the Company uses the following providers, which process personal data on behalf of the Company and only to the extent necessary for the service they provide:

• Anthropic (Claude API): produces internal summaries of your enquiries for the advisor handling them. It acts as a data processor and does not use your data to train its models.
• Twilio and Vapi: telephony, processing and transcription of calls, and the AI voice assistant described in section 2.2.
• Google (Google Workspace): email, spreadsheets and internal automations (Gmail, Google Sheets and Apps Script).
• Meta Platforms (Facebook, Instagram and WhatsApp): messaging and the contact forms in its ads, through which you get in touch with us.

Some of these providers are established in the United States or may process data there. These international transfers rely on the standard contractual clauses approved by the European Commission and, where the provider is certified, on the EU–US Data Privacy Framework.

6. USER RIGHTS

Any data subject has the right to obtain confirmation as to whether or not we are processing personal data concerning them. Data subjects have the right to access their personal data and to request the rectification of inaccurate data or, where appropriate, request its erasure when, among other reasons, the data are no longer necessary for the purposes for which they were collected. In certain circumstances, data subjects may request the restriction of the processing of their data, in which case we will keep them only for the exercise or defence of legal claims. On grounds relating to their particular situation, data subjects may object to the processing of their data. The Controller will stop processing the data, except for compelling legitimate grounds or the exercise or defence of possible legal claims.

Under current legislation, you have the following rights: the right to request access to your personal data, the right to request its rectification or erasure, the right to request the restriction of its processing, the right to object to processing, the right to data portability, the right not to be subject to a decision based solely on automated processing, including profiling, and, likewise, the right to withdraw the consent given.

6.1. How can I exercise my rights?

To exercise your rights, you must contact the Controller and request the corresponding form for the right you wish to exercise. If you consider that the processing of your data does not comply with the law, you also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD), www.aepd.es. The contact details for exercising your rights are telephone +34 673 560 035 and email: info@domtenerife.es. Please remember to enclose a copy of a document that allows us to identify you.

7. CONSENT TO RECEIVE ELECTRONIC COMMUNICATIONS

Likewise, and in accordance with Spanish Law 34/2002 of 11 July on Information Society Services and Electronic Commerce, by completing the data collection form and ticking the corresponding box “I agree to receive electronic communications”, you give your express consent for us to send information about the Company to your email address, telephone, fax or other electronic means.

Authoritative version

This text is a translation provided for information purposes only. The original Spanish version (Política de privacidad) is the authentic text: it prevails in the event of any discrepancy between the versions, as well as for the interpretation of this text and the resolution of any dispute.