Privacy policy

1) Information on the Collection of Personal Data and Contact Details of the Controller

1.1 We are pleased that you are visiting our website and thank you for your interest. Below, we provide information on how we process your personal data when you use our website. In this context, personal data means any data by which you can be personally identified.

1.2 The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is ComerciaWise S.L., Plaza de la Marina 2, 4° DR, 29015 Málaga, Spain, telephone: +4915223382966, email: info@comerciawise.es. The controller responsible for the processing of personal data is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data.

2) Data Collection When Visiting Our Website

2.1 If you use our website for informational purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the data that your browser transmits to our server (“server log files”). When you access our website, we collect the following data, which is technically necessary in order to display the website to you:

The website visited
Date and time of access
Amount of data transferred in bytes
Source/reference from which you reached the website
Browser used
Operating system used
IP address used, where applicable in anonymised form

Processing is carried out in accordance with Article 6(1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be transferred or used in any other way. However, we reserve the right to subsequently review the server log files if there are specific indications of unlawful use.

2.2 For security reasons and in order to protect the transmission of personal data and other confidential content, such as orders or enquiries addressed to the controller, this website uses SSL or TLS encryption. You can recognise an encrypted connection by the character sequence “https://” and the lock symbol in your browser’s address bar.

3) Hosting & Content Delivery Network

For the hosting of our website and the presentation of its content, we use a provider that provides its services itself or through selected subcontractors exclusively on servers located within the European Union.

All data collected on our website is processed on these servers.

We have concluded a data processing agreement with the provider, which ensures the protection of our website visitors’ data and prohibits unauthorised disclosure to third parties.

4) Cookies

In order to make visiting our website more attractive and to enable the use of certain functions, we use cookies. These are small text files that are stored on the user’s end device. In some cases, these cookies are automatically deleted when the browser is closed (“session cookies”), while in other cases they remain on the end device for a longer period and enable website settings to be stored (“persistent cookies”). In the latter case, users can find information about the relevant storage period in the cookie settings of their browser.

Where individual cookies used by us also process personal data, such processing is carried out in accordance with Article 6(1)(b) GDPR for the performance of a contract, in accordance with Article 6(1)(a) GDPR where the user has given consent, or in accordance with Article 6(1)(f) GDPR in order to safeguard our legitimate interests in ensuring the best possible functionality of the website and a user-friendly and efficient design of the website visit.

Users may also configure their browser so that they are informed about the setting of cookies and can decide individually whether to accept them, or accept cookies in certain cases or generally exclude them.

If users do not accept cookies, the functionality of our website may be restricted.

5) Contacting Us

5.1 WhatsApp Business

You have the option of contacting us via the WhatsApp messaging service provided by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. For this purpose, we use the “Business” version of WhatsApp.

If you contact us via WhatsApp in connection with a specific business transaction, for example an order placed, we store and use the mobile telephone number you use on WhatsApp and, if provided, your first and last name in accordance with Article 6(1)(b) GDPR for the purpose of processing and responding to your enquiry. On the same legal basis, we may ask you via WhatsApp to provide additional information, such as an order number, customer number, postal address or email address, in order to assign your enquiry to a specific transaction.

If you use our WhatsApp contact option for general enquiries, for example regarding our range of services, availability or our online presence, we store and use the mobile telephone number you use on WhatsApp and, if provided, your first and last name in accordance with Article 6(1)(f) GDPR, on the basis of our legitimate interest in providing the requested information efficiently and promptly.

Your data will only be used to respond to your enquiry via WhatsApp. It will not be disclosed to third parties.

Please note that WhatsApp Business has access to the address book of the mobile device that we use for this purpose and automatically transfers the telephone numbers stored in the address book to a server of its parent company, Meta Platforms Inc., in the United States. For the operation of our WhatsApp Business account, we use a mobile device whose address book contains only the WhatsApp contact details of users who have contacted us via WhatsApp.

This ensures that all persons whose WhatsApp contact details are stored in our address book have consented to the transfer of their WhatsApp telephone number from the address books of their chat contacts by accepting WhatsApp’s terms and conditions of use when first using the application on their device, in accordance with Article 6(1)(a) GDPR. The transmission of data relating to users who do not use WhatsApp and/or who have not contacted us via WhatsApp is excluded.

For information on the purpose and scope of data collection and the further processing and use of data by WhatsApp, as well as your rights and privacy protection settings, please refer to WhatsApp’s Privacy Policy:

https://www.whatsapp.com/legal/?eea=1#privacy-policy

We have concluded a data processing agreement with the provider, which protects the data of visitors to our website and prohibits its disclosure to third parties.

Within the context of the processing activities described above, data may be transferred to servers of Meta Platforms Inc. in the United States.

For transfers of data to the United States, the provider has joined the EU-U.S. Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

5.2 Contact Form and Email

When you contact us, for example via a contact form or email, personal data is collected. The data collected when using a contact form can be seen from the relevant contact form itself. This data will be stored and used exclusively for the purpose of responding to your request, establishing contact with you and carrying out the associated technical administration.

The legal basis for processing the data is our legitimate interest in responding to your request in accordance with Article 6(1)(f) GDPR. If your contact is aimed at concluding a contract, an additional legal basis for the processing is Article 6(1)(b) GDPR.

Once your enquiry has been fully processed, your data will be deleted provided that the circumstances indicate that the matter in question has been conclusively resolved and provided that there are no statutory retention obligations preventing deletion.

6) Use of Your Data for Direct Advertising

6.1 Subscription to Our Email Newsletter

If you subscribe to our email newsletter, we will regularly send you information about our offers. The only mandatory information required for sending the newsletter is your email address. Any additional information is provided voluntarily and is used to address you personally.

For sending the newsletter, we use a so-called double opt-in procedure. This means that we will only send you the newsletter once you have expressly confirmed that you consent to receiving it. We will send you a confirmation email asking you to click on a link to confirm that you wish to receive the newsletter in the future.

By activating the confirmation link, you give your consent to the use of your personal data in accordance with Article 6(1)(a) GDPR.

When you subscribe to the newsletter, we store the IP address entered by your Internet Service Provider (ISP), as well as the date and time of registration, in order to be able to trace any possible misuse of your email address at a later date.

The data collected when you subscribe to the newsletter will only be used for advertising purposes via the newsletter.

You may unsubscribe from the newsletter at any time by clicking on the link provided in the newsletter or by sending a corresponding message to the controller named at the beginning of this Privacy Policy.

After unsubscribing, your email address will immediately be removed from our newsletter distribution list unless you have expressly consented to further use of your data or unless we reserve the right to use the data for other purposes permitted by law, about which we inform you in this Privacy Policy.

6.2 Sending Email Newsletters to Existing Customers

If you have provided us with your email address when purchasing a product, we reserve the right to regularly send you offers by email for products from our range that are similar to those you have already purchased. For this purpose, we require separate consent in accordance with Section 7(3) of the German Act Against Unfair Competition (UWG).

The processing of data is based on our legitimate interest in personalised direct advertising in accordance with Article 6(1)(f) GDPR.

If you object to the use of your email address for this purpose, we will not send you such emails.

You have the right to object at any time, with effect for the future, to the use of your email address for the advertising purposes described above by notifying the controller named at the beginning of this Privacy Policy. In doing so, you will only incur transmission costs according to the basic rates.

Upon receipt of your objection, the use of your email address for advertising purposes will be discontinued immediately.

7) Web Analytics Services

7.1 Google Analytics 4

This website uses Google Analytics 4, a service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”), which enables the analysis of website usage.

When using Google Analytics 4, cookies are set by default. Cookies are text files that are stored on the user’s end device and enable analysis of how the website is used.

The information generated by the cookies about the use of the website, including the IP address transmitted by the end device with the final digits removed, as explained in more detail below, is generally transferred to a Google server, where it is stored and processed.

In this context, information may also be transferred to servers belonging to Google LLC, based in the United States, where further processing of the information may take place.

When Google Analytics 4 is used, the IP address transmitted by the user’s end device while using the website is always collected and processed automatically and by default, but only in anonymised form, so that the information collected cannot be directly associated with a specific person.

This automatic anonymisation is carried out by Google by removing the final digits of the IP address within Member States of the European Union (EU) or other states that are party to the Agreement on the European Economic Area (EEA).

At our request, Google uses this and other information to evaluate the user’s use of the website, compile reports on website activities or user behaviour, and provide us with other services relating to website and internet usage.

The IP address transmitted by the user’s end device and shortened within the framework of Google Analytics 4 will not be merged with other Google data.

Data collected within the framework of Google Analytics 4 will be stored for two months and subsequently deleted.

Using the special “demographic characteristics” function, Google Analytics 4 can also generate statistics containing information about the age, gender and interests of website users based on an evaluation of interest-based advertising and the use of information from third-party providers.

This enables website user groups to be identified and differentiated in order to optimise the targeting of marketing campaigns.

However, data collected via the demographic characteristics function cannot be assigned to any specific individual and therefore cannot be assigned personally to the user.

Data collected via the demographic characteristics function will be stored for two months and subsequently deleted.

All processing activities described above, in particular the setting of Google Analytics cookies for storing and reading information on the end device used by the user to access the website, will only take place if the user has given us their express consent in accordance with Article 6(1)(a) GDPR.

Without the user’s consent, Google Analytics 4 will not be used during their visit to the website.

Users may withdraw their consent at any time with effect for the future. To exercise this right, users simply need to deactivate this service using the cookie consent tool provided on the website.

The “Google Signals” service may also be used on this website as an extension of Google Analytics.

With Google Signals, Google can create cross-device reports, known as “cross-device tracking”.

If you have activated “personalised ads” in your Google Account settings and have linked your internet-enabled devices to your Google Account, Google may analyse user behaviour across different devices and create database models based on this information, provided that you have consented to the use of Google Analytics in accordance with Article 6(1)(a) GDPR as described above.

The login information and device types of all website visitors who are logged into a Google Account and have completed a conversion are taken into account.

Among other things, the data shows on which device an advertisement was first clicked and on which device the associated conversion subsequently took place.

Where Google Signals is used, we do not receive any personal data from Google, but only aggregated statistics based on Google Signals.

You have the option of deactivating the “personalised ads” function in your Google Account settings and thereby disabling cross-device analysis.

To do so, please follow the instructions on this page:

https://support.google.com/ads/answer/2662922?hl=es

Further information can be found here:

https://support.google.com/analytics/answer/7532985?hl=es

As an extension of Google Analytics, the “User IDs” function may also be used on this website.

By assigning individual User IDs, we can enable Google to generate cross-device reports, known as “cross-device tracking”.

This means that your usage behaviour may also be analysed across different devices if you have provided the relevant consent to the use of Google Analytics in accordance with Article 6(1)(a) GDPR, if you have created a personal account by registering on this website, and if you have logged into your personal account on different end devices using the corresponding login details.

The data collected in this manner shows, among other things, the end device on which you first clicked on an advertisement and the end device on which the corresponding conversion subsequently took place.

We have entered into a data processing agreement with Google regarding the use of Google Analytics, under which Google is obliged to protect the data of visitors to our website and not to disclose it to third parties.

For transfers of data to the United States, the provider participates in the EU-U.S. Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

Further legal information concerning Google Analytics 4 can be found at:

https://business.safety.google/intl/es/privacy/

and

https://policies.google.com/privacy?hl=es&gl=es

Detailed information about the processing carried out through Google Analytics 4 and Google’s processing of data obtained from websites can be found here:

https://policies.google.com/technologies/partner-sites?hl=es

7.2 Google Tag Manager

This website uses Google Tag Manager, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Google Tag Manager enables various web applications, including tracking and analytics services, to be grouped together and configured, controlled and linked to specific conditions through a single user interface.

Google Tag Manager does not itself store or read any information on users’ end devices. Nor does it independently carry out any data analysis.

However, when the website is visited, Google Tag Manager transmits the user’s IP address to Google, where it is stored. It is also possible that data may be transmitted to servers belonging to Google LLC in the United States.

This processing only takes place if the user has given us their express consent in accordance with Article 6(1)(a) GDPR.

Without this consent, Google Tag Manager is not used during the website visit.

Users may withdraw their consent at any time with effect for the future. To do so, they simply need to deactivate this service using the cookie consent tool provided on the website.

We have entered into a data processing agreement with Google, under which Google undertakes to protect the data of visitors to our website and not to disclose it to third parties.

Further information about privacy and Google Tag Manager can be found at:

https://business.safety.google/intl/es/privacy/

and

https://support.google.com/tagmanager/answer/9323295?hl=es

Specific information regarding the services and applications relevant to data protection that are managed via Google Tag Manager can be found in the relevant sections of this Privacy Policy.

8) Retargeting, Remarketing and Recommendation Advertising

Meta Pixel with Advanced Data Matching

Within our online offering, we use the “Meta Pixel” service provided by the following provider in advanced data matching mode:

Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Meta”).

If a user clicks on an advertisement placed by us on Facebook or Instagram, the “Meta Pixel” is used to add a parameter to the URL of the linked page on our website.

This URL parameter is entered into the user’s browser following the redirection by means of a cookie set by our own linked website.

In addition, this cookie collects specific customer data, such as the email address, which we collect on our website linked to the Facebook or Instagram advertisement during processes such as purchase transactions, account logins or registrations (“advanced data matching”).

The cookie is then read and enables data, including specific customer data, to be transmitted to Meta.

We use the “Meta Pixel” with advanced data matching in order to make our advertisements (“Ads”) on Facebook and/or Instagram more effective and to ensure that they correspond to users’ interests or certain characteristics, for example interests in specific topics or products determined on the basis of websites visited, which we transmit to Meta in connection with so-called “Custom Audiences”.

In addition, we analyse the effectiveness of our advertisements by tracking whether users were redirected to our website after clicking on an advertisement (“conversion”).

Compared with the standard version of the “Meta Pixel”, the advanced data matching function helps us to measure the effectiveness of our advertising campaigns more accurately by recording a greater number of attributable conversions.

All transmitted data is stored and processed by Meta so that it can be assigned to the relevant user profile, and Meta may use the data for its own advertising purposes in accordance with Meta’s Data Use Policy:

https://www.facebook.com/about/privacy/

The data may enable Meta and its partners to display advertisements both within and outside Facebook.

All processing activities described above, in particular the setting of cookies for reading information from the end device used, will only take place if you have given us your express consent in accordance with Article 6(1)(a) GDPR.

You may withdraw your consent at any time with effect for the future by deactivating this service in the cookie consent tool provided on the website.

We have concluded a data processing agreement with the provider, which ensures the protection of the data of visitors to our website and prohibits unauthorised disclosure to third parties.

The information generated by Meta is generally transferred to a Meta server and stored there. In this context, it may also be transferred to servers belonging to Meta Platforms Inc. in the United States.

9) Tools and Miscellaneous

Cookie Consent Tool

This website uses a cookie consent tool to obtain effective user consent for the use of cookies that require such consent.

The cookie consent tool is displayed to users when they access the website in the form of an interactive user interface through which they can give their consent to the use of specific cookies or cookie-based applications by selecting the relevant options.

Through the use of this tool, all cookies and services requiring consent will only be loaded if the user has provided the relevant consent by selecting the appropriate options.

This ensures that such cookies are only placed on the user’s end device if the user has previously given their consent.

The tool sets technically necessary cookies in order to store the user’s selected cookie preferences.

As a general rule, no personal data is processed in this context.

If, in individual cases, personal data such as an IP address needs to be processed for the purpose of storing, assigning or recording cookie settings, this processing is carried out in accordance with Article 6(1)(f) GDPR on the basis of our legitimate interest in the lawful, user-specific and user-friendly management of cookie consent and, consequently, in ensuring that our website is designed in compliance with applicable law.

A further legal basis for processing is Article 6(1)(c) GDPR.

As the controller, we are legally obliged to make the use of cookies that are not technically necessary dependent on the user’s consent.

Further information about the operator and the available settings of the cookie consent tool can be found in the corresponding user interface on our website.

10) Rights of the Data Subject

10.1 Applicable data protection legislation grants you comprehensive rights in relation to the controller with regard to the processing of your personal data. These rights of access and intervention are set out below:

Right of access pursuant to Article 15 GDPR
Right to rectification pursuant to Article 16 GDPR
Right to erasure pursuant to Article 17 GDPR
Right to restriction of processing pursuant to Article 18 GDPR
Right to information pursuant to Article 19 GDPR
Right to data portability pursuant to Article 20 GDPR
Right to withdraw consent granted pursuant to Article 7(3) GDPR
Right to lodge a complaint pursuant to Article 77 GDPR

10.2 RIGHT TO OBJECT

IF WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF A BALANCING OF INTERESTS IN CONNECTION WITH OUR OVERRIDING LEGITIMATE INTERESTS, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO SUCH PROCESSING, WITH EFFECT FOR THE FUTURE, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING THE DATA CONCERNED.

HOWEVER, WE RESERVE THE RIGHT TO CONTINUE PROCESSING IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR WHERE THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR SUCH MARKETING PURPOSES.

YOU MAY EXERCISE YOUR RIGHT TO OBJECT AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

11) Retention Period for Personal Data

The period for which personal data is stored is determined on the basis of the respective legal basis, the purpose of the processing and, where applicable, the relevant statutory retention period, for example retention periods under commercial and tax law.

Where personal data is processed on the basis of explicit consent in accordance with Article 6(1)(a) GDPR, such data will be stored until the data subject withdraws their consent.

Where statutory retention periods apply to data processed in connection with legal or quasi-legal obligations on the basis of Article 6(1)(b) GDPR, such data will routinely be deleted after the relevant retention periods have expired, provided that it is no longer required for the performance or initiation of a contract and/or we no longer have a legitimate interest in continuing to store it.

Where personal data is processed on the basis of Article 6(1)(f) GDPR, such data will be stored until the data subject exercises their right to object pursuant to Article 21(1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or unless the processing serves the establishment, exercise or defence of legal claims.

Where personal data is processed for direct marketing purposes on the basis of Article 6(1)(f) GDPR, such data will be stored until the data subject exercises their right to object pursuant to Article 21(2) GDPR.

Unless otherwise stated in the other information contained in this Privacy Policy regarding specific processing situations, stored personal data will be deleted when it is no longer required for the purposes for which it was collected or otherwise processed.

Privacy Policy

Sunward HOMES

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