Additional information on Data Protection
This Privacy Policy describes how the personal data you provide to us as a User through the public and private areas, as applicable, of the TodoHoliday.com website (henceforth, the “Website”) and mobile apps (henceforth, the “mobile app”) is collected, used, stored, shared and protected.
Your personal data will be processed effectively, proportionally and responsibly, in strict compliance with the General Data Protection Regulation (EU) 679/2016 (“GDPR”), Act 3/2018 on Personal Data Protection and Guarantee of Digital Rights (“LOPDGDD”), and other regulations that may apply. All the information you need about how we process your personal data and protect your privacy is set out below, clearly and transparently.
You, as a User, must guarantee: (a) the authenticity and veracity of all data (in particular, but not limited to, personal data) that you communicate or provide through the Website or the mobile app; (b) that you are the owner of this personal data and (c) that you will keep the information provided up to date, ensuring it matches your current situation at all times. You shall be the only party liable for any false or inexact statements you make, and any harm that may result therefrom.
1. DATA CONTROLLER
Who is the data processor for your data?
Marpul Buildings 78 Sl.
Avenida Cerro del Viento Nº25
CP 29631 Benalmádena Málaga
CIF: B92847227
2. TYPE OF DATA PROCESSED
What personal information will we process?
We manage your personal data in order to provide the services you have requested through your interactions on the Website and mobile app when we request certain personal information. This personal data we process may include but are not limited to: your first name, surname(s), email, profile photograph, user identification, password, telephone number, complete information of the property you are going to advertise (including its physical address), browsing data, bank details and/or billing data.
All the fields indicated with an asterisk (*) in the forms will be compulsory. Therefore, if not provided or provided incorrectly, it may be impossible to provide the services or information requested, without detriment to the ability to continue viewing the content of Website and/or mobile app.
3. PURPOSES OF PROCESSING AND LEGITIMATION
How we will process your personal data and what allows us to do so?
The list of services you can request and we can provide includes:
3.1. REGISTRATION ON OUR PLATFORMS AND PROVISION OF OUR SERVICES
Management of TodoHoliday.com user registrations, so you can access our platform and benefit from TodoHoliday.com services, administering your user account. The legitimate basis shall be the execution of a contract.If you choose to register with TodoHoliday.com using your Google or Apple account, you will be directed from our platform to the Google or Apple website, where you will have to enter your account login details. The data we obtain from Google or Apple will be used to configure your TodoHoliday.com account. This means we will use your Google or Apple username as your username for TodoHoliday.com, and this will be visible to other users of the Website and app, as applicable. Any other data obtained from Google or Apple will not be visible to other users of the platform. You may dissociate your account from your Google or Apple profile whenever you wish. The collection and use of these data are based on your consent.
Account and profile configuration.
The legitimate basis shall be your consent.
Save and manage your property searches. The legitimate basis shall be your consent.
You may contact advertisers directly through our platform, meaning they will be provided with your personal data and the information you include in the contact form. The legitimate basis shall be the execution of a contract.
Management of notifications sent to inform you of the publication of adverts that match the search preferences you have saved. The legitimate basis shall be your consent.
Publication of your adverts on the TodoHoliday.com. Website and/or mobile app. The legitimate basis shall be the execution of a contract.You will also be offered the option to publish your advert on other websites owned by our Official Advertisers. If you decide to do so, an account will be created for you on that website, and you will be asked to activate it in order to access and manage your advert. The legitimate basis shall be your consent.
Instant messaging service between users to facilitate the transaction and communication with each other. When you use the contact form or the chat in the user area, you will be using our instant messaging service. The legitimate basis shall be the execution of a contract. All messages and adverts are revised using manual and/or automatic processes. We do this to prevent fraud or abuse or misuse of our services, including the sale of illegal goods. If we detect suspicious or illegal activity or behaviour, our team may review the messages sent and received. In those cases in which we use automated processes, you shall have the right ask for intervention by TodoHoliday.com staff, to express your viewpoint, and to lodge a complaint if you do not agree. The legitimate basis shall be legitimate interest.
Request for support service from a property expert who will help you buy, sell or rent a property. The legitimate basis to communicate your data to this expert shall be your consent.
Sending of important, necessary communications related to the provision of our services, including sending reminders, technical alerts, upgrades, security alerts and support messages, among others. The legitimate basis shall be the execution of a contract and the fulfilment of legal obligations, where applicable.
In those cases in which, due to the activity carried out, it is identified that you could fit the profile of a professional user, we will contact you in order to offer the most advantageous options that suit your professional profile, and ask you to update your account. The legitimate basis shall be the execution of a contract.
Contact form, which you can use to contact us and send us your doubts, queries and orders. The legitimate basis shall be your consent.
Provision of customer support services to attend to your complaint or query. The legitimate basis shall be the execution of the contract.
You may use the services of our chatbot, which you can interact with to get the information you request from us about your TodoHoliday.com account, products or services. The legitimate basis will be the adoption of precontractual measures when you access the chatbot, make the relevant query and send it voluntarily, or the contractual relationship if you are a registered user and decide to use this feature of the service to communicate with us.
Location feature: When you use TodoHoliday.com, you will be given the opportunity to select your exact location, in order to deliver more accurate services and offer you tailored content, including products and services of interest relating to your last search that are near your location. This will also allow you to make more concise posts and to search for products by closeness or sort them by distance from you. To deliver these services, which require you to share your location by enabling native permissions in your web browser or mobile app, TodoHoliday.com may, for the sole purpose stated above, process exact data about your location. TodoHoliday.com will process these data when you request the service and whenever the app is running in the foreground (when the app is open and on the screen). To use these services, you must give your express consent in your browser or app. These location data will not, under any circumstances, be processed by TodoHoliday.com without consent. The legitimate basis shall be your consent. You can deactivate the location permissions you have given at any time in your mobile settings or in the relevant browser.
3.2. ANALYTICAL AND STATISTICAL PURPOSES
Drafting of statistical reports on your user profile according to your access habits and activity on the Website and/or mobile app, in accordance with our cookies policy, in order to develop and improve the functioning of TodoHoliday.com. The legitimate basis shall be your consent, provided through the cookies configuration.
Improve the services you subscribe to and TodoHoliday.com’s performance by studying your behaviour as a user. The legitimate basis shall be legitimate interest.
3.3. MARKETING ACTIVITY AND MARKET STUDIES
Drafting of a commercial profile based on the information you provide, to carry out commercial actions in accordance with it via any channel using your personal data as derived from management of the products contracted and data on browsing, access habits, traffic, etc. Automated decisions based on this profile that may affect you legally or that will affect you significantly or similarly will not be made.
Sending of communications to inform of our products and services, as well as new products by TodoHoliday.com, recommendations and offers by TodoHoliday.com in order to improve the visibility of your advert, multiply visits to your advert and the contacts received, based on our legitimate interest of maintaining commercial contact with you unless you indicate otherwise (for registered users).
Sending of newsletters with real estate news through subscription to the TodoHoliday.com blogs. The legitimate basis shall be your consent.
Sending of tailored communications by our official advertiser sites about the various services they provide and which may be of interest to you based on your profile, via different channels. The legitimate basis shall be your consent.
Sending of tailored communications, via different channels, on third-party products and services that may be of interest to you based on your profile, such as offers and promotions related to the following sectors: Financial, editorial, education or training, employment, cars, telecommunications, IT, technology, household, beauty, real estate, distance selling, consumer products, textiles, food, collections, audiovisual content, music, hobbies, leisure, travel and tourism, insurance, energy and water, NGOs and services provided by the public administration. The legitimate basis shall be your consent.
Sending of push alerts on new products and recommendations by TodoHoliday.com. The legitimate basis shall be your consent.
Sending of satisfaction surveys regarding the services provided and the analysis and processing of the information resulting from these surveys, including the possibility of contacting you regarding the responses you provide voluntarily, in order to ensure the quality and improve our products and services. The legitimate basis shall be legitimate interest.
Management of your participation in prize draws and competitions that TodoHoliday.com may run, if you wish to take part, in accordance with their specific terms and conditions. The legitimate basis shall be your consent.
TodoHoliday.com may select certain users and invite them to participate in market studies by conducting interviews. If you accept the invitation, your opinions will be used to improve our products and services. The legitimate basis for participation in these studies shall be your consent.
3.4. ACCOUNT AND PLATFORM SECURITY
Prevention of abuse and fraud in the use of our services (for example, fraudulent activities, denial-of-service attacks, sending of spam, among others). The legitimate basis shall be legitimate interest.
3.5. COMPLIANCE WITH LEGAL OBLIGATIONS
Ensure compliance with all obligations set out in the regulations, including assistance in the exercise of data subjects’ rights as recognised in applicable regulations. If necessary, we will use your information as required to meet our legal obligations. The legitimate basis shall be the fulfillment of a legal obligation.
4. RETENTION PERIODS
How long will we keep your personal data?
You are hereby informed that, while you are a TodoHoliday.com user and use our services, your data will be kept for the duration of the contractual and commercial relationship with us. In those cases in which the processing of your data is based on your consent, until you revoke it. In the cases legally envisaged, we will process your data until you ask for them to be deleted, without detriment to the fact that we keep the data for the time necessary to fulfil our legal obligations and the timelines established in law.
Suitable security measures will be applied to avoid any risk of destruction, loss, accidental alteration of or unauthorised access to your personal data during the whole storage period. You are hereby informed that before your personal data are completely deleted, they will be blocked when the purpose of their processing ends and during the limitation periods of any obligations, for the sole purpose of responding to or complying with any liabilities resulting from the processing.
5. THIRD-PARTY LINKS OR PAGES
In order to offer the best services related to the real estate sector at TodoHoliday.com, we may make reference to and/or provide access to third-party services we believe to be of interest to you, which you may access via links to websites external to TodoHoliday.com. In these cases, we remind you that the service will be provided directly by each of them, and TodoHoliday.com is not liable for the processing they carry out and does not transfer any type of information, meaning you must accept their respective privacy policies and legal text before you provide your personal data.
6. RECIPIENTS
Who are your data communicated to?
TodoHoliday.com will only share or provide your data to third parties to the extent necessary and permitted or required in accordance with current regulations. In this regard, your data may be communicated:
To allow interactions on the TodoHoliday.com platform; whenever you decide to contact other users of TodoHoliday.com, your personal contact data will be communicated to the advertiser indicated in the details of each advert in order to contact them.
In those cases in which you request help or consultancy from an expert or real estate agent outside of TodoHoliday.com, we will transfer your data to those parties you determine, always with your prior consent.
To carry out our activity, we use certain trusted suppliers and services that may access our systems in order to provide the services, or to provide them to you on our behalf. These suppliers have the contractual obligation to fully protect your personal data and may only access them to carry out the services contracted by TodoHoliday.com. In some cases, these suppliers are established outside of the European Economic Area, which may mean that your data are subject to an international transfer. In these cases, your personal data will be protected by the service providers thanks to the implementation of suitable measures and/or by the signing of contractual clauses such as those of the European Union, related to international data transfers approved by the European Commission, guaranteeing a level of protection equivalent to that in Europe.
The personal data that you provide may also be available for access to members of our companies in Adevinta Group for administrative and support purposes.
We may communicate your personal data to public organisations, police forces, courts and tribunals, tax authorities and regulatory organisations when required in accordance with legal and regulatory provisions, to fulfil our legal obligations or a legally binding requirement/request, and to respond to lawsuits presented against TodoHoliday.com.
7. RIGHTS
What are your rights when you provide your data and how can you exercise them?
You are entitled to obtain confirmation as to whether or not our official advertisers are processing your personal data.
You are also entitled to access your personal data, and request the rectification of inexact data or, if applicable, request their erasure when, among other reasons, the data are no longer necessary for the purposes they were collected for.
In certain circumstances, you may ask for the processing of your data to be limited, in which case we will only store them to exercise or defend ourselves from complaints.
You may also oppose the processing of your data in certain circumstances and for reasons related to your specific location.Our Official advertisers will stop processing the data, except on compelling legitimate or contractual grounds or to exercise or defend itself from any complaints.
You may also exercise your right to data portability and withdraw the consent provided at any time, without this affecting the legality of the processing based on the consent prior to its withdrawal.
Regarding the data provided to advertisers you have contact with, you can exercise your rights before the advertiser as a user, writing to the advertiser’s address at the bottom of the advert. In this case, the advertiser is understood to be any natural or legal person who offers any type of products or services on our Websites.
8. COOKIES
TodoHoliday.com uses cookies and other similar technologies on its Website and mobile app. For more information about the cookies we use on the Website and mobile app, see our cookies policy via the following link cookies policy.
9. ANALYSIS AND TRACKING TOOLS
To carry out remarketing and behavioural retargeting activity, we use tools provided by suppliers such as:
Remarketing tool “Custom Audiences” from Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (henceforth, “Facebook”). There are certain social networks, applications or third-party websites that allow the sending of commercial communications or advertising to specific or determined users. With this information the social network or application verifies whether the user has an account on their platform, and TodoHoliday.com may do what is known as a “Custom audience” with users that also have an account on the social network or application, showing then advertising directly, in accordance with section 3.3 of this privacy policy.
“Facebook Custom Audiences” can be disabled by registered users at https://www.facebook.com/settings/?tab=ads#.
More information about data processing by Facebook is available here: https://www.facebook.com/about/privacy.
10. CONFIDENTIALITY AND SECURITY
TodoHoliday.com guarantees that it will process your data confidentially, maintaining the compulsory and fullest duty of secrecy at all times, in accordance with applicable regulations. Similarly, you are hereby informed that TodoHoliday.com periodically reviews the technical and organisational security measures that it applies to its information and communication systems in order to prevent any loss, alteration, misuse or any other unauthorised processing of your personal data.
11. AMENDMENTS TO THE PRIVACY POLICY
TodoHoliday.com reserves the right to amend this privacy policy at any time in order to adapt it to current legislation. All amendments will be published on both the Website and the mobile apps, so we recommend that you check them regularly.
Last update: 27 October 2023
