Privacy Policy of GRUPO SOCIEDAD DE TASACIÓN

On 19/06/2020

GRUPO SOCIEDAD DE TASACION (from now on, Grupo ST) hereby informs clients and users of this website https://www.grupo-st.en/ of its Privacy Policy, describing how the collected data is used, as well as the options of data subjects in relation to their data and their rights (their rights to access, rectify, object and erase their personal data, the right to the portability of their personal data, the right to file a claim with a supervisory authority, the right to limit the data processing, and the right not to be subject to a decision solely based on the automated processing of their data, including profiling, which may have legal impacts on them or may significantly affect them in a similar way). Similarly, this text hereby states the policy followed in relation to the security and confidentiality of your data, and commercial communications from the companies that are part of Grupo ST. Users of the website https://www.grupo-st.en/ are asked to read this Privacy Policy before browsing the site.

1. Method for obtaining personal data and prior consent

Pursuant to EU Regulation No. 679 of the European Parliament and Council of 27 April 2016, relating to the protection of individuals with regards to the processing of personal data and the free circulation of this data , (hereinafter, the GDPR), Organic Law No. 3 of 5 December 2018 on Personal Data Protection and Guarantee of Digital Rights (hereinafter, LOPDGDD), the user is hereby informed that personal data that may be requested in forms provided by the following member companies of Grupo ST ( we are referring specifically to: SOCIEDAD DE TASACIÓN S.A. https://www.st-tasacion.es , ST CONSULTORES INMOBILIARIOS SL https://www.stconsultores.com , ST CARTERA SL and ST INVESTIGACIÓN Y DESARROLLO DE APLICACIONES INFORMÁTICAS S.A.U https://www.stidea.com) o enviados por el usuario a las direcciones de correo electrónico de dichas empresas, se podrán incluir en los registros de datos personales titularidad y responsabilidad de la empresa a la que se hayan comunicado dichos datos.

All collected data will be processed with due confidentiality and in accordance with prevailing personal data protection legislation. Similarly, all communication addressed to users and clients (either by email or by other means) will be considered confidential and directed exclusively to said users /clients.

This website is governed by the applicable Spanish legislation, to which Spanish or foreign users of this website shall be subject.

2. Data processing purposes

Member companies of Grupo ST shall obtain personal data from users when they complete the various forms provided to them by the corresponding company via different means, treating this data as the responsibility of the company and with the following purposes:

• Processing and management of requests or provision of the service contracted with a member company of Grupo ST and maintenance, development, management and control of the contractual relationship agreed in the application.
• Participation in recruitment processes when users submit a curriculum vitae.
• Subscription to online newsletters, physical publications, websites and commercial and promotional communications related to the services offered by a member company of Grupo ST.
• Compliance with obligations and duties imposed to any member company of Grupo ST by the prevailing laws at any given time.

The personal data processing carried out by the companies part of Grupo ST shall be covered by at least one of the cases established in the GDPR as grounds for legal processing (for example, the need to process personal data to execute a contract, a legal obligation that requires such processing, or consent given by the data subject).

When the data subject communicates his/her personal data to a member company of Grupo ST by any means, the latter shall comply with the GDPR’s reporting requirements (a duty that it also complies with when it obtains personal data that has not been directly obtained from the data subject), and when the data subject’s basic consent is required to legally process the data, prior and express authorisation shall be required to use this data for each specific purpose, as well as for the purposes of periodic communications, including those made by email. Likewise, any company shall provide users with simple and free mechanisms for withdrawing their consent given for the purpose of sending electronic communications, in full compliance with legislation in this area.

Companies part of Grupo ST may process all of the aforementioned personal data, directly or via third parties acting on its behalf as data controllers, fully upholding the duty of secrecy, exclusively for the purposes indicated, and in accordance with prevailing personal data protection legislation at any given time. Furthermore, those companies shall not transfer the personal data obtained to third parties, except in those cases required by law.

The ST Group and the different companies that constitute it reserve the right to decide whether or not to include the personal data of the users in their respective records, for the inclusion of which they will request prior consent from the holders of said data.

In case of cvs sent applying to job offers of any of the companies part of Grupo ST published in its webs (Sociedad de Tasación, S.A: ; ST Consultores Inmobiliarios SL: https://www.stconsultores.com/ ST Investigación y Desarrollo de Aplicaciones Informáticas S.A.U: https://www.stidea.com/ ) or in external job portals, those companies, according to the 26 GDPR article, may be considered co-responsible for the data treatment, due to the co-responsibility agreement in relation to personal data protection signed by the companies of the Group. Whether a job applicant may not be select for a specified offer published, one of the companies of Grupo ST, he/she can apply to other job in other member company of Grupo ST, by giving his/her express consent to it, and taking in accounts the data rights explained in the third section of this Policy, which can be exercised before any of the companies. The company which has published the offer may be the one in charge of informing the applicant according to the 13 GDPR article.

The data that may be requested from data subjects shall be relevant, specific and necessary for the purpose for which it is collected. It shall not be used for a purpose other than that for which it has been collected without the prior and express consent of the user, who under no circumstances shall be forced to provide this personal data to any corresponding company of Grupo ST. Nevertheless, the user must be warned that failure to provide this data may make it impossible for the company to provide the services that the user may have requested in the usual way.

In the event that the user accesses different web pages outside of the control of the companies of Grupo ST, for which links appear in their websites, those companies shall not be liable for the personal data processing that those web pages may carry out with the data provided.

Unless indicated otherwise, every field in each form must be completed. The data provided by the user must be accurate, precise, complete and up-to-date.

The user shall be solely responsible for any losses or damage, direct or indirect, caused to a member company of Grupo ST, or to any third party, in the event that it completes the forms with false, inaccurate, incomplete or out-of-date information, or with data from third parties without having previously obtained their consent, prior to providing it to the company part of Grupo ST.

3. Rights of data subjects: access, rectification, objection; right to erasure (right to be forgotten), right to portability of personal data, right not to be subject to solely automated data processing decisions, and the right to restrict the processing.

Users have the right to:

• Access their personal data contained in the files and records owned by the corresponding company of Grupo ST to which they may have previously provided this data, consisting of the right to obtain information about the purposes of the data processing, the categories of processed data, the recipients of the data, the envisaged retention period, and other information established under art. 15 of the GDPR, among other aspects.
• Request its rectification in the event that the data is inaccurate or incomplete.
• o Object to its processing, under the terms established in art. 21 of the GDPR and other legislation in force relating to personal data protection.
• Erasure, which reflects a user’s right to the erasure of the personal data that he/she may have communicated to the member of Grupo ST without any undue delay, under the terms established in art. 17 of the GDPR.
• Portability of his/her data, which represents the right of the data subject to obtain a copy of his/her personal data in a structured, commonly-used and machine-readable electronic format, and to transfer his/her data from one electronic processing system to another.
• Not to be subject to decisions solely based on the automated processing of his/her data, including profiling, which produces legal effects concerning him/her or similarly affects him/her in a significant way.
• Restriction of processing, consisting of data subjects’ right to request and obtain from the data controller or file, a restriction on the processing of his/her personal data when any of the following conditions applies:
  • The data subject contests the accuracy of the personal data, for a period enabling the controller to verify this accuracy.
  • The processing is unlawful and the data subject opposes the erasure of the personal data, and requests the restriction of its use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but the data is required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing, pending the verification whether the legitimate grounds of the controller override those of the data subject.

Those rights can be exercised before the corresponding company of Grupo ST, by e-mail sent to:

Sociedad de Tasación SA: [email protected]

ST Investigación y Desarrollo de Aplicaciones Informáticas S.A.U: [email protected]

ST Consultores Inmobiliarios SL: [email protected]

Similarly, you may exercise these rights by writing to the corresponding company at the address Calle Príncipe de Vergara 43, planta 7ª, C.P. 28001 Madrid, attaching a photocopy of your national identity document (DNI) or document accrediting the identity of the entity that you represent, stating an address for the purposes of notifications.

It is important that users report any changes to their data to keep this data up-to-date as the corresponding company of Grupo ST shall not be liable for the accuracy of this data.

If the user does not expressly request the erasure of his/her personal data from the files of the corresponding company of Grupo ST, it shall be assumed that the data subject continues to be interested in the inclusion of their data, while this data is appropriate for the purpose for which it has been obtained, or its retention is necessary for legal or contractual reasons, or for the establishment, exercise and defence of any claims. Accordingly, and by way of example, data obtained for the purposes of a recruitment process shall cease to be appropriate for the purpose for which it was provided after a period of two years, at which point the data shall be destroyed, provided that the candidate has not previously requested the erasure of his/her data.

If the user believes that his/her data has not been processed in accordance with the prevailing legislation, he/she may file a claim with the Spanish Data Protection Agency (the control authority): https://www.aepd.es

A co-responsibility agreement in relation to personal data protection with the member companies of Grupo ST (ST Cartera SL, Sociedad de Tasación S.A, ST Investigación y Desarrollo de Aplicaciones Informáticas S.A.U and ST Consultores Inmobiliarios SL) has been signed. This agreement governs cases in which the personal data is jointly processed by two or more companies in Grupo ST, so that the data of any client or employee of any of the aforementioned companies will be protected at all times and from the initial moment that it is communicated. Nevertheless, any data subject may exercise the aforementioned rights with any of the companies, which shall be considered to be the data controller due to their role in its processing. Similarly, the aforementioned agreement includes the duty of confidentiality of all companies in Grupo ST, the security measures that they must fulfil at all times, and the reporting mechanisms between all companies when jointly processing one or more elements of personal data. When any of those companies processes any personal data subject to this co-responsibility agreement, the company will inform the data subject of the processed data of this fact.

4. Security measures for personal data

Grupo ST hereby states that it has adopted all the necessary technical and organisational measures to safeguard the security of the files that contain personal data, under the terms established in art. 32 of the GDPR, and is committed to adopting any other security measure that may be established in the future, either legally or by the state of the art, informing users of this website and websites of the member companies of Grupo ST.

5. Sending commercial communications by email

Pursuant to article 21 of the Information Society and e-Commerce Services Act (Law 34 of 11 July 2002) – which forbids the sending of commercial communications by email that have not been expressly authorised by their recipients, except in cases in which a prior contractual relationship exists, the corresponding company of Grupo ST may use a recipient’s legally obtained contact details to send them commercial communications referring to the company's own products or services, that may be similar to those that were initially contracted by the client. All of this shall be pursuant to section 2 of this Privacy Policy. Nevertheless, in the event that the client does not wish to receive these commercial communications by email, it may inform via the following email addresses:

Sociedad de Tasación SA: [email protected]

ST Consultores Inmobiliarios SL: [email protected]

ST Investigación y Desarrollo de Aplicaciones Informáticas S.A.U: [email protected]

It may also send this communication in writing to the corresponding company at the address Calle Príncipe de Vergara 43, planta 7ª, CP 28001 Madrid, attaching a photocopy of his/her national identity document (DNI) or a document accrediting the identity of the entity that he/she represents.

6. Amendments to this Privacy Policy

Grupo ST reserves the right to amend this Privacy Policy included in this website in the future, according to its own criteria or due to changes in legislation, case law or business practices, respecting the prevailing personal data protection legislation at all times. If Grupo ST introduces any changes, the new text will be published on this same page, where the user will be able to find the new policy, and for which his/her consent shall be sought if legally required, and notwithstanding the possibility of the user’s right to erase his/her data as indicated in point 3. In all cases, the relationship with the user shall be governed by the rules and regulations at the specific time that the user accesses the website, and it is therefore essential that the user reads the policy prior to using the website or communicating his/her data.

By using the website, the user intrinsically accepts these conditions, which he/she has had the opportunity to read, prior to using the services on this site.

7. Obligation to correctly use the website and its content

All of the content included on this website is provided solely for information purposes and under no circumstances may act as the basis for claims or appeals, or constitute any entitlement. Grupo ST reserves the right to modify the contents of the website that are unrelated to the user data protection policy, without prior warning.

The User hereby agrees to correctly use this website and its functionalities, which are provided in accordance with the law and this Privacy Policy.

The User may only use the website and its contents for lawful and non-prohibited purposes, which do not infringe current legislation and/or could damage the legitimate rights of Grupo ST or any other third-party, and/or could cause any damage or loss, directly or indirectly.

To this effect, the User shall refrain from using any of the content of this website for unlawful purposes or effects, or those forbidden under this clause, which may damage the rights and interests of third parties or that in any way damage, render unusable, overload, impair or prevent the normal use of this website.

In particular, and including but not limited to, the User agrees not to transmit, disseminate or make available to third parties any information, data, content, messages, graphics, drawings, sound and/or image files, photographs, recordings, software and in general, any type of material that:

• • breaches, disregards or contravenes in any way the constitutionally recognised fundamental rights and public freedoms in international treaties and any other legislation;
• • induces, incites or promotes criminal, denigrating, defamatory, dishonourable or violent conduct, or that in general is contrary to the law, morality and generally accepted good conduct or public order;
• • induces, incites or promotes actions, attitudes or ideas that discriminate on grounds of gender, race, religion, beliefs, age or condition;
• incorporates, makes available or facilitates access to products, elements, messages and/or services that are criminal, violent, offensive, harmful, degrading or that in general are contrary to the law, morality and generally accepted good conduct or public order;
• may be false, ambiguous, inaccurate, exaggerated or untimely, so that it induces or may induce misunderstanding over its purpose or the intentions or purposes of the informing party;
• is protected by any intellectual or industrial property rights belonging to third-parties, unless the user has previously obtained the necessary consent from its owners to carry out the use made or attempted;
• infringes third party trade secrets;
• infringes other people's right to reputation, personal and familial privacy or the right to self-image;
• diminishes the reputation of a member company of Grupo ST in any way;
• infringes regulations on the confidentiality of communications;
• constitutes, if applicable, illegal, misleading or unfair publicity, and unfair competition in general;
• incorporates a virus or other physical or electronic elements that could damage or prevent the normal functioning of the network, system or IT equipment (hardware and software) of any member company of Grupo ST or third parties, or that could damage the electronic documents and files stored on that equipment;
• causes difficulties in the normal functioning of the Service due to its characteristics (such as format, extension, etc.);

The user hereby agrees to refrain from:

• reproducing, copying, distributing, making available or in any way publicly communicating, transforming or modifying the contents of this website, unless he/she has the authorisation of the owner of the corresponding rights or is legally permitted to do so;
• erasing, manipulating or in any way altering the copyright and other identifying details of the reservation of rights of a member company of Grupo ST
• trying to obtain the contents of this website using means or procedures other than those that may have been made available or indicated for this purpose on this website, if applicable, or those that are generally used on the internet, unless they do not represent a risk of damaging the Website, Services and/or Contents or rendering them unusable.

The user shall be liable for losses and damages of any type that a company member of Grupo ST may suffer, directly or indirectly, as a result of the breach of any of the obligations derived from these general conditions or the law in relation to the use of this website.

8. Intellectual property rights

All contents of the member companies of Grupo ST are the intellectual property of them,and are protected under current Spanish and international intellectual property legislation.

Any use, exploitation, reproduction, distribution, assignment, transformation or modification and/or public dissemination of the contents of their websites, (or of any kind of confidential information sent by Grupo ST using e-mail or any other means) whether for public or commercial purposes or otherwise, without the prior written authorisation of the corresponding company of Grupo ST, is strictly forbidden.

It is forbidden to establish this page as a background for other pages, although links may be established to our URL (http://www.grupo-st.es/) provided that this is not associated with any false, inaccurate or incorrect representations that could be misleading or lead to confusion or that may be contrary to the law, morality and good conduct.

Infringement of any of the aforementioned rights may represent a breach of these terms and conditions, as well as a crime punishable under article 270 and following articles of the Spanish Criminal Code.

The trademarks, logos and any other industrial property that appears on this site are the property of the corresponding company member of Grupo ST. The use of these trademarks without the prior written authorisation of that company or the owning third parties, as applicable, is forbidden.

9. Duration of the service provided

Grupo ST does not guarantee the availability and permanent continuity of the functioning of this website. It shall warn about interruptions to its website service in advance, when reasonably possible; Grupo ST cannot guarantee the operability of the website for carrying out any specific actions, nor its infallibility.

Access to the Grupo ST website is for an indefinite duration. Nevertheless, Grupo ST reserves the right to suspend the access of users, without prior warning, who in its opinion fail to comply with the rules of use of its website, similarly reserving the right to take the corresponding legal measures. Furthermore, Grupo ST reserves the right to restrict the access of the general public to certain sections of this website, limiting it solely to a group of specific users by providing them with an access password, if applicable, for which they will be responsible.

10. Exemption from liability

Grupo ST has adopted the security levels required to protect its clients’ personal data, and has implemented the technical and organisational measures available to it to prevent the loss, improper use, alteration, unauthorised access and theft of the personal data that may be provided to it via this website.

Grupo ST makes every effort to avoid any errors in the contents of the website, but cannot guarantee or be responsible for potential mistakes in this content.

Grupo ST is exempt from any liability for damages or losses of any type that may result from:

• An interruption in the operations or the lack of access or availability of the website.
• • The additional mechanisms and methods that users may employ, at their own initiative, to ensure their privacy and security when using the website, and/or in relation to improper access by unauthorised third parties.
• The potential transmission of elements that negatively affect IT systems due to causes beyond the control of Grupo ST.
• • The accuracy, completeness and timely updating of the contents of its website. Accordingly, Grupo ST cannot guarantee the reliability, availability nor the continuity of its website, nor of the contents, and the use of these by the User shall therefore be at its own risk and accord and Grupo ST shall not be liable at any time in this regard.

Grupo ST shall not be liable in the event of interruptions to the service, delays, mistakes, malfunctioning, and in general any other inconvenience that may derive from causes beyond the control of Grupo ST and/or that may be due to the intentional or negligent actions of the User, or due to force majeure. In all cases, whatever the underlying causes, Grupo ST shall not be liable in any way for such issues, either for direct or indirect damages, consequential damages and/or loss of earnings. Grupo ST shall have the right to temporarily suspend the website’s services and contents to carry out maintenance, improvement or repair work, without any right to compensation for the user in this regard.

Grupo ST is exempt from any liability for damages and losses of any kind that may be due to the lack of reliability, accuracy, completeness and/or the outdated nature of the contents transmitted, disseminated, stored, made available or received, obtained or that may have been accessed via this website, nor for the contents provided by third parties or entities.

Grupo ST shall seek to update and correct any information on its website that does not meet the minimum standards of accuracy, as far as possible. Nevertheless, it shall be not be liable for failure to update or correct information, or for the content and information displayed on its website.

Grupo ST shall not be liable for use of the website’s services and products by the user, nor for users’ passwords, nor for any other material on the website, that infringes the intellectual or industrial property rights or any other right of third parties.

Grupo ST reserves the right to remove any content that may be false or inaccurate or that is contrary to the law, morality, public order and good conduct.

11. Applicable legislation and jurisdiction

The provision of the service is governed by Spanish legislation and the User hereby expressly submits to the courts and tribunals of Madrid.