Privacy Policy
1. Introduction
Espacio Leon Propco SLU (“Multi”) and Property Technology
Solutions B.V. (“Club Espacio”) (Multi and Club Espacio are
hereinafter collectively referred to as "Data Controllers")
process personal data you provided if you access our website
and applications, if we provide products or services to you
or the organization through whom you are known to us, if you
visit our shopping centers and/or take part in our marketing
events or campaigns. Data Controllers are strongly committed
to protecting the privacy of your personal data. Data
Controllers only uses personal data legitimately and
responsibly in line with applicable privacy laws and
regulations. In this Privacy Statement, we describe who we
are, how and for which purposes we process personal data,
how you can exercise your privacy rights, and all other
information that may be relevant to you. We did our best to
provide you with all information in a clear and readable
format. However, if you have any questions about our use of
personal data after reading this Privacy Statement, you can
of course always contact us through the contact details
provided below. We are continually developing and improving
our products and services, which might result in some
changes to the way we are processing personal data. We will
make sure to reflect these changes in this Privacy
Statement. We recommend that you regularly take notice of
this Privacy Statement for any modifications. At the bottom
of this Privacy Statement you can read when this Privacy
Statement has been modified for the last time. We may use
cookies and similar technologies. For more information on
how we use cookies, you may also want to read our Cookies
Statement.
2. Who are we?
Property Technology Solutions B.V. is a company that
provides technology and marketing solutions to real estate
projects under the brand Club Espacio. We are located at
Parnassusweg 8191082 LZ Amsterdam Nederlands. For more
information, please read the paragraph “More information?
3. To which personal data does this Privacy Statement apply?
All personal data that is collected, stored, shared,
transmitted, and/or otherwise used in relation to Data
Controller’s website, applications, shopping centers,
products, and services falls within the scope of this
Privacy Statement. This includes inter alia, the personal
data of our investors, candidates, business partners,
tenants, clients to whom Data Controllers provides products
and services, suppliers, visitors, and other individuals (in
any form).`
4. What is personal data?
Personal data is any information that relates to an
identified or identifiable living individual. Different
pieces of information, collected can lead to the
identification of a particular person and also constitute
personal data. You share such data with us if you are a
client, we provide products or services to you if you are a
visitor of our shopping centers or have contact with us in
another capacity.
5. Which personal data do we collect from you?
We might collect several of the following categories of
personal data of you or your children/parents when you are
seeking contact or are in contact with Data Controllers:
• Demographic data (name, gender, date of birth, age,
nationality, marital status & dependents)
• Contact details (name, function, address, place of
residence, email address, telephone number)
• Financial data (bank account details, loan reference
number, credit card number)
• Company details (address, trade register number, tax
identification number)
• Account details (username and password)
• Marketing preferences (whether you have opted in or out
for direct marketing)
• Interaction details (contact with our client service or
digital and/or written correspondence)
• (Online) identifiers, surfing data and visitor movement
data (IP address, cookies, MAC address, browsing behavior on
our websites and applications, shopping behavior and
location)
• Participation details (whether you participate in
promotions, loyalty programs, surveys, competitions, or
social and marketing events)
• Data needed for security and fraud prevention (official
identification, camera recordings)
• Image data (photos, video images)
• Data needed to comply with anti-bribery and corruption
laws and other regulatory requirements (such as suspected
and actual criminal behavior, criminal records or
proceedings regarding criminal or unlawful behavior)
6. How do we collect, receive or generate your personal
data?
We might process the categories of personal data mentioned
above either directly from you, from external parties or
through profiling and automated decision-making techniques
in so far as permitted by law.
Personal data directly provided by and about you
The following data is collected directly from you:
• personal data which you provide when creating an account,
using our applications, concluding a contract, participating
in promotions, loyalty programs or social and marketing
events and/or other information which you enter or provide;
• your surfing behaviour on our website/apps and your buying
behavior when participating in our loyalty programs; •
personal data you provide as a visitor of our shopping
centers (this could also be movement information generated
by Wifi-tracking); • personal data you, or the organization
through whom you are known, provides to us in the
performance of our products or services; and • personal data
you provide as part of correspondence, recruitment,
feedback, help (Q&A) and dispute settlement.
Profiling techniques / automated decision-making
We might want to approach you in a relevant and personal
way. To make that possible we might analyse personal data to
determine the most relevant target groups, segments,
content, advertisements, information, moments and channels.
We only make use of such profiling or automated decision
techniques based on your explicit consent, whereby we will
inform you about the logic involved and the consequences of
such techniques. At the same time, we take the necessary
measures to safeguard your rights and to make sure that the
techniques do not legally or significantly affect you,
If you object to use of a profile to provide you with
personalized marketing, please contact us by using the
contact details set out in paragraph “More information?”.
7. For which purposes do we process your personal data?
We collect and process your personal data for the following
purposes:
1. execution of an agreement: to enter into and fulfill
agreements with you and other clients, tenants, suppliers or
(business) partners;
2. communication, (direct) marketing and personalization
purposes: to maintain contact, promote and provide
information about Multi’s products and services or the
businesses of others (marketing);
3. quality and management purposes: to monitor and improve
our products and services;
4. security and safety: for security reasons, accidents,
insurance claims, etc.; and
5. legislation and regulation: to comply with legislation
(e.g. verification requirements) or court orders to which
Data Controllers (together or separately) are subject.
In more detail, we process your personal data for the
following purposes.
Execution of an agreement
We process your personal data to prepare, effect, perform
and (possibly) terminate several kinds of agreements, e.g.
membership agreements, activity agreements, loyalty program
subscriptions etc. To that end, we could require demographic
data, contact details, company details and financial
details.
Communication, (direct) marketing and personalization
purposes
• Client relationship management – Your relationship with
Data Controllers is important to us and as such, we take the
utmost care to ensure that your personal data is accurate
and up-to-date. Client relationship management includes the
contact creation and registration of your account as a
client. It also includes facilitating the sharing of your
contact information with Data Controllers to draft marketing
proposals and send invoices to the right client. To that
end, we collect your demographic data, contact details and
company details.
• Client service and support – We want to be able to assist
you as quickly as possible whenever you contact us for
support or want to file a(n) additional request or
complaint. Therefore, we need to process your personal data
in the form of taking notes and registering reports and
telephone conversations that you have with our employees. We
use this information not only to facilitate the resolution
of your query, but also to analyze and improve the quality
of our services. To that end, we collect your demographic
data, contact details, company details, financial details
and your request or complaint.
• Marketing and promotional offerings – If you are already a
client of Multi and Club Espacio or have indicated that you
want to receive information about Multi and Club Espacio’s
products and services or the businesses of others, we can
include you in a mailing list through which newsletters,
brochures and other information are sent. In order to send
these (personalized) offerings, we process your demographic
data, contact details and company details.
• Loyalty program participation – We may also process
personal data if you indicated that as a visitor of our
shopping centers, you want to participate in loyalty
programs to receive personalized offerings and provide
feedback through customer satisfaction and/or interest
surveys. To that end, Data Controllers collects your
demographic data, contact details, financial data, account
details and participation details.
Quality and management purposes
We process your personal data to monitor and improve the
quality of our products and services, processes, and
systems, to inform the management and to perform internal
audits. For example, we might use WIFI tracking to monitor
visitor movement and flow and to assess the performance of
certain shopping centers. To that end, collect interaction
details, surfing behavior data and visitor movement data
Security and safety
We process your personal data to ensure the safety of our
visitors and for the prevention and detection of crime. For
this purpose, Closed Circuit Television (“CCTV”) might be in
operation during your visit to any of Multi’s premises all
in accordance with the relevant image capture laws. CCTV is
well designed and selectively used and the necessary
precautionary measures and restrictions have been taken
(into account) by to minimize the impact on your privacy
rights. If you are subject to CCTV, you are informed through
signs.
Legislation and regulation
We process your personal data to verify whether or not Multi
can accept someone as a client or (business) partner, to
counter fraud, to perform audits, to comply with legislation
(e.g. civil, criminal, administrative, tax law) and
regulation and to take the necessary legal action to enforce
our rights.
8. On which legal grounds do we process your personal data?
To be lawful, personal data which is processed for certain
purposes (as identified above) has to be based on a legal
ground . Multi processes personal data on the following
legal grounds:
(1) The performance of a (service) agreement with you
We process your personal data, which is necessary for our
performance under an agreement with you. Without these data,
we would not be able to fulfil our side of the agreement.
(2) Compliance with a legal obligation or permitted by the
laws We are legally obliged to process your personal data in
order to comply with our legal obligations. In certain
cases, we process your personal data if and when such
processing is permitted by the laws.
(3) Legitimate interests pursued by us
We use your personal data for our legitimate interests,
provided that your fundamental rights and freedoms are not
harmed, such as:
• to improve the quality and effectiveness of our
services;
• to protect our visitors and stakeholders interests;
• to detect fraud and security incident (e.g. on our
website/app and in our shopping centers);
• to defend ourselves in legal proceedings;
• to comply with the law;
• To establish exercise or protect a right.
(4) Your consent
If the previous three legal grounds do not apply, we can
only process your personal data with your prior unambiguous
explicit consent. Note that you can always withdraw your
given consent. Please keep in mind that you can only
withdrawal in case you have given your consent first and
such withdrawal has no retrospective effect.
Multi processes personal data it has collected for the
purposes as identified above on the following legal grounds:
Purpose Legal basis
Execution of an agreement: to enter into and fulfill
agreements with you and other clients, suppliers or
(business) partners.
(1) The performance under a (service) agreement;
(2) Compliance with a legal obligation or permitted by the
laws.
Communication, (direct) marketing and personalization
purposes: to maintain contact, promote and provide
information about Multi’s products and services or the
businesses of others (marketing).
(1) The performance under a (service) agreement;
(3) Legitimate interests pursued by us;
(4) Your consent;
Quality and management purposes: to monitor and improve our
products and services;
(3) Legitimate interests pursued by us;
(4) Your consent.
Security and safety: security reasons, accidents, insurance
claims, etc.
(3) Legitimate interests pursued by us;
Legislation and regulation: to comply with legislation (e.g.
verification requirements) or court orders to which Multi is
subject.
(2) Compliance with a legal obligation or permitted by the
laws;
(3) Legitimate interests pursued by us.
9. To whom do we provide your personal data?
We can provide your personal data to third parties in
accordance with this Privacy Statement and in so far as
permitted by law. Your personal data can be received by the
following categories of recipients.
Authorities
We may provide your personal data to supervisory authorities
such as Tax and Customs Administration, the police and other
statutory bodies. We provide your personal data:
• to comply with a statutory obligation, court order or law;
or
• if this is necessary to prevent, trace or prosecute
criminal offence; or
• if this is necessary to enforce our policies, or to
protect the rights and freedoms of others.
Business service companies (data processors)
We make use of business service companies to support us
execute our business. These organizations act only on our
instructions and are contractually bound by us not to use
your data for their own purposes. This may include Group
companies of Multi, who may process your data for the
purpose of providing you with information and/or services
(such as registration and client support), the development
of new websites, applications, services, promotions and
communication, and to prevent, trace and examine possible
illegal activities, infringements of our policies, fraud
and/or breaches of our data security.
Other
Each external party to which we – with your given consent –
provide your personal data (for example within the context
of a collaboration, mandate or (service) agreement), and/ or
to which other company now or in the future forms part of us
as a result of a restructuring, merger or acquisition.
10. Are your personal data being transferred abroad?
Your personal data might be transferred abroad. We have
taken all necessary measures to ensure that the transfers
are safe and take place within the limits set by law.
To ensure a proper level of protection we make sure your
data is only transferred if subject to one of the following
safeguards:
Adequacy decision
We are allowed to transfer your personal data abroad based
on a so-called ‘adequacy decision’. An adequacy decision is
a decision of the European Commission or Turkish Data
Protection Authority, depending on the sort of personal
data, that decides that the country in question ensures an
adequate level of protection with regard to personal data.
EU-US Privacy Shield and Undertaking Introduced by the
Turkish Data Protection Authority Your personal data is only
transferred abroad if the recipient or data processor
guarantees an adequate level of data protection in line with
the US Privacy Shield framework and the undertaking
framework introduced by the Turkish Data Protection
Authority.
Standard Contract Clauses and Governance
The (lawful) transfer of personal data abroad is made
possible as a result of appropriate safeguards provided by
us and recipients or data processors. We have implemented
such safeguards through Multi’s governance rules and our
standard data protection clauses to which we agree upon with
all parties that process data on our behalf
11. How long do we store your personal data?
Your personal information is kept as long as necessary for
the purpose for which the data are processed or allowed by
law. Hereinafter your personal data will be removed or made
anonymous.
12. How can you exercise your privacy rights?
You have the right to request the following from us
regarding your personal data:
• information about whether your personal data has been
processed,
• if your personal data has been processed, information
about such data and processing and access to an overview of
your personal data,
• Information about the purpose for the data processing and
whether your personal data was used for this purpose;
• rectification and/or erasure or removal of your personal
data,
• information about the identities of natural or legal
persons whom the data is transferred to,
• if data is transferred, request us to advise the recipient
about correction, erasure and removal of such personal
data,
• restriction of processing concerning your personal
data,
• the right to object to processing and
To invoke your rights stated above, please contact us by
using the contact details set out above and in paragraph
“More information?” in the way stated under paragraph “Can
you lodge a complaint?”.
Please keep in mind that we may ask for additional
information to verify your identity.
If you no longer want to receive direct marketing
communication, please contact us by using the contact
details set out in paragraph “More information?”.
For information on how to object to profiling, please see
the information on profiling techniques below.
13. Can you lodge a complaint?
You can lodge a complaint concerning the usage of your
rights mentioned above:
• to our registered e-mail address (=KEP) with using secure
e-signature or mobile signature, or
• to our e-mail address via your e-mail address registered
within our systems, or
• to our contact details set out in paragraph “More
information?” by personally submitting your complaint with
we-ink-signed request.
Furthermore, you can lodge a complaint with the relevant
data protection supervisory authority. For example, if you
believe that we do not use your personal data carefully, or
because you have sent us a request to access or
rectification of your personal data and you are not
satisfied with our reply, or we did not reply in a timely
manner.
14. More information?
If you have any questions about the way we process personal
data that are not answered by this privacy statement, you
want to exercise your privacy rights or want to file a
complaint, please contact us:
Espacio León Propco SLU
Prim, 19, 2ª planta, 28004 Madrid, SPAIN
T. +34 987 23 79 29
E. privacy@multi.eu
Registered E-mail: espacioLeón@multi.eu
Property Technology Solutions
B.V
Parnassusweg 8191082 LZ Amsterdam
T. +31 20 820 3900
E. clubespacio@clubforum.eu
15. When was the last modification made to this Privacy
Statement?
This Privacy Statement applies since 28.11.2023. The last
modifications to this Privacy Statement were made on
28.11.2023