Privacy Policy


The Data Controller of your personal data and owner of the website  is PROPER ADVISOR, S.L with registered office at C/Santa Teresa 3, local 1º 08012 – Barcelona and NIF B67070490, corporation registered in the mercantile registry (hereinafter PROPER ADVISOR).

PROPER ADVISOR’s contact details in relation to data protection are:

Telephone number: +34 93 240 40 89



The data we collect, the way we obtain it, and the purpose of processing are as follows:

  1. Contact forms and/or information request:
    • Required data: name, last name, email, phone.
    • Purpose: to respond to inquiries and/or provide information requested by the User.
    • Legitimation: user’s consent
  2. If you make a transaction as a result of our services:
    • Required data: first name and last name, address, email, phone, and credit/debit card information.
    • Purpose: transaction management.
    • Legitimation: user’s consent
  3. Carry out the contractual relationship and related administrative, tax, and accounting tasks required by current legislation:
    • Required data: first name and last name, phone, address, ID number, email, signature.
    • Purpose: carry out internal commercial, fiscal, and administrative management.
    • Legitimation: Data subject’s consent and contractual relationship.

1-Types of personal data we process: 

For confidentiality reasons, we collect the minimum amount of data possible from the individuals we interact with, especially our clients, beyond what they voluntarily provide or what the law requires us to collect for any other reason.

We may collect and process the following categories of personal data: 

a. Regarding our clients: name, title, gender, ID number or passport, payment data. 

b. For our employees: identification data, social security data, bank details, and any data necessary for the employment relationship. 

c. Identification data of our suppliers’ contact persons in the case of companies. 

d. Information collected when you use our website and other digital media, if applicable. When you use our website, we might record your IP address, browser type, operating system, referring website, and web browsing behavior.

2-Your personal data will only be used for the following purposes:

a. To carry out the necessary commercial and administrative formalities with third parties and our customers.

b. To contact you for contractual negotiations and to process your inquiries.

c. In case of formalizing contracts, purchases, sales or rentals, the data is used to process the corresponding contracts. In this regard, your data may be shared with Notaries, Registry and, if necessary, share your payment data with the relevant financial institution.

d. Send commercial advertising communications by email, social networks or any other electronic or physical means, if you have expressly consented to the sending of such commercial communications by electronic means. In case you are a customer of PROPER ADVISOR, we may send you commercial information related to the properties purchased, sold or rented or the services you have contracted.

e. Communicate with you to respond to your inquiries and handle your complaints.

f. Communicate with you to obtain your opinion about the quality of our services, or the treatment received.

g. Likewise, the data collected during your navigation are treated with the aim of providing access to the online content of the web, as well as to meet the requests of web users, keep a statistical record of visits (IP addresses, browser data, country, page accessed, etc.) in order to enable us to develop better services and products, optimize our offer and provide a more effective customer service and improve the design and content of our websites.

h. The data of our customers and suppliers will be processed, within the contractual relationship that binds them to PROPER ADVISOR, in compliance with the administrative, tax, accounting and labor obligations that are necessary under current legislation.

i. Objection or Revocation. You may object or revoke your consent to receive marketing communications at any time by following the instructions in the relevant marketing communication or by contacting us at .

j. If you fill in any of the forms on our website, it will be necessary to provide certain personal data, which will be processed for the purpose for which they are requested.

k. The personal data of our employees will be used for the fulfillment of the corresponding labor and contractual obligations.

In accordance with the LSSICE, we inform you that PROPER ADVISOR does not carry out SPAM practices, therefore, it does not send commercial mail by e-mail if it does not have the necessary legitimacy. In any case, you will always have the possibility of withdrawing your consent to receive our communications.

We will not process your personal data for any purpose other than those described in this Policy, except by legal obligation or court order.

Your personal data will not be subject to decisions based on automated processing that produce effects on you.


The legal basis that legitimizes the processing of your personal data is your express consent given to carry out the purposes described above, which will be requested at the time you request information from us.

In the event of a commercial relationship between you, whether as a customer, supplier or employee and PROPER ADVISOR, the legal basis that legitimizes the processing of your personal data will be the execution of the contractual relationship that will have been generated, as well as, where appropriate, compliance with the corresponding legal obligations.

 In case that you do not provide us with your personal data, or you do not accept our privacy policy, PROPER ADVISOR will not carry out the treatment of your personal data, but it could also mean the impossibility to send you information, give you our services or formalize our contractual relationship with you.

4. DATA RETENTION. ¿How long shall we keep your personal data?

The personal data you provide us shall be kept for the time necessary to manage the information you request, or as long as there are contractual obligations deriving from services or transactions with our clients and subsequently until the expiration of legal, contractual or professional responsibilities that require its retention.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide the Services to you.
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them).
  • Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations).

Once the data has met the needs for which it was collected, we will delete it permanently. However, we will keep your data longer, if necessary, to comply with legal obligations. Likewise, it may be necessary to keep it for the time necessary until the prescription of the legal responsibilities that are generated.

If we have your e mail in our database for the sending of commercial information, it will be kept if the necessary legal basis that legitimizes its conservation and use is maintained. You have the right to erasure of personal data concerning to you at any time in order not to receive commercial information.


Within our organisation, your personal data will be processed by duly authorised personnel and, if necessary or practical to fulfil the purposes indicated above, may be processed by third parties.

The categories of recipients to whom your personal data may be communicated from PROPER ADVISOR are as follows:

a.         Named third party processors, such as IT providers, consultants and advisors and other companies providing ancillary services. 

b.         Public entities and bodies, exclusively for the purpose of complying with the corresponding legal obligations.

c.          Other providers to whom, where appropriate, your personal data may be transferred to financial institutions, fraud detection service providers, where appropriate, etc.

In any case, all of the aforementioned third parties will have previously signed the corresponding confidentiality commitment following our instructions in accordance with the current personal data protection regulations, will be subject to the duty of professional secrecy or will be acting in compliance with a legal obligation.

We may communicate your data to CLAVERMON, SL    (COLDWELL BANKER Master franchise) only if we consider that it could be beneficial for the realization of the service or transaction wanted. 

No international transfer of data to countries outside the EU is foreseen.

6.  RIGHTS ¿what are your rights when you provide us with your data?

If you wish to exercise the rights that the data protection regulations grant you, please send us an e-mail to the following address putting in the subject the right you want to exercise and attaching a copy of your national identity document or passport. 

The Rights that the current regulations recognize and that, where appropriate, may be exercised are:

Right of access to data:

You have the right to be informed by the Data Controller if your personal data is being processed or not, and if the process is confirmed, you shall be able to access it by providing the following information:

-The purposes of processing.

-The categories of data.

-The term or criteria for data retention.

Right to rectification:

You will have the right to request the Data Controller to rectify your data when they are inaccurate or incomplete by means of an additional rectifying statement.

Right to Erasure:

The data subject shall have the right to request the Data Controller to erase its data, when:

-The processing is illegal.

-The data subject has withdrawn its consent.

-They are no longer necessary in relation to the purposes for which they were collected or processed.

-The data subject has exercised the right of opposition and other legitimate reasons for the processing do not prevail.

-The data must be erased to fulfill a legal obligation of the Data Controller.

The data subject shall not have the right to request the Data Controller to erase their data when the processing is necessary:

-To exercise the right to freedom of expression and information.

-To fulfill a legal obligation of the Data Controller.

-For the preparation, exercise or defense of claims.

-For public interest based on current legislation for public health reasons or for historical, statistical or scientific research purposes.

Right to data portability:

You have the right to request the Data Controller to transfer your data to another Data Controller or to the same data subject, through a structured format of usual use and mechanical reading, when the processing is carried out by automated means and is based on:

-The consent of the data subject for specific purposes.

-The execution of a contract or pre-contract with the data subject.

The right to data portability will not apply when:

-The transmission is technically impossible.

-It can negatively affect the rights and freedoms of third parties.

-The processing has a public interest mission based on current legislation.

Right to restriction of processing:

1.  The data subject shall have the right to obtain from the Data Controller restriction of    processing where one of the following applies:

the accuracy of the personal data is contested by the data subject, for a period enabling the Data Controller to verify the accuracy of the personal data;
the processing is unlawful, and the data subject opposes the erase of the personal data and requests the restriction of their use instead;
the Data Controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims;
the data subject has objected to processing, pending the verification whether the legitimate grounds of the Data Controller override those of the data subject.

2.   Where processing has been restricted under paragraph 1, such personal data shall, except for storage, only be processed with the data subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

3.   A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the Data Controller before the restriction of processing is lifted.

Right of opposition:

The data subject shall have the right to object to processing of personal data, on grounds relating to his or her situation, at any time. The Data Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims. 

Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Right not to be subject to profiling:

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, mainly when is referred to the following personal aspects:

-Professional performance.

-Economic situation.


-Preferences or personal interests.



-Location or movements of the person.

When profiling is based solely on automated processing:

-The data subject will have the right to be informed if the decision that can be taken could have legal effects that significantly affect him.

-The data subject will have the right to obtain human intervention from the Data Controller to express their point of view and to challenge the decision, if the processing has been authorized by:

-The explicit consent of the data subject.

-A contract between the Responsible and the data subject.

This right shall not apply if the decision:

is necessary for entering, or for the performance of, a contract between the data subject and the Data Controller;
is authorized by European Union or Member State law to which the Data Controller is subject, and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
is based on the data subject’s explicit consent.


If you consider that PROPEPR ADVISOR has violated any of your rights protected by the personal data protection regulations or that it has violated any obligation regarding the protection of Personal Data, you have the right to submit a claim to the competent Supervisory Authority which in Spain is the Spanish Agency for Data Protection located at Calle Jorge Juan, 6. 28001 – Madrid. Tel. 901 100 099 – 912 663 517

You can also submit an electronic claim through the electronic address that is available on their website


This privacy policy is governed in each and every one of its aspects by Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons in regard to the processing of personal data and the free circulation of this data. 

It is also governed by Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights. Likewise, our website is governed by Law 34/2002, of July 11, on Information Society and Electronic Commerce Services.

Any dispute arising from matters relating to our Website shall be exclusively subject to the jurisdiction of the courts of the city of Barcelona.



The data you provide will be treated confidentially. PROPER ADVISOR has adopted all the technical and organizational measures and all the necessary levels of protection to guarantee the security in the treatment of the data and avoid its alteration, loss, theft, processing or unauthorized access, according to the state of technology and nature of the stored data. Likewise, it is also guaranteed that the processing and registration in files, programs, systems or equipment, premises and centers comply with the requirements and conditions of integrity and security established in current regulations. 


We inform you that PROPER ADVISOR may have a presence on social networks. The processing of the data of the people who become followers on the social networks (and/or carry out any link or action of connection through the social networks) of the official pages of PROPER ADVISOR will be governed by this section, as well as by those conditions of use, privacy policies and access regulations that belong to the social network applicable in each case and previously accepted by the user.

PROPER ADVISOR will process your data for the purposes of correctly administering its presence on the social network, informing of activities, products or services of the provider, as well as for any other purpose that the regulations of the Social Networks allow.

The publication of content is prohibited: 

            – That are allegedly unlawful by national, community or international regulations or that carry out allegedly unlawful activities or contravene the principles of good faith.

            -That infringe on the fundamental rights of persons, lacking in courtesy on the network, that annoy or could generate negative opinions in our users or third parties and in general any content that PROPER ADVISOR considers inappropriate.

            – And in general, that contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of private life, consumer protection and intellectual and industrial property rights.

Likewise, PROPER ADVISOR reserves the right to remove, without prior notice, from the website or the corporate social network any content that is considered inappropriate.

In any case, if you send personal information through the social network, PROPER ADVISOR shall be exempt from liability in relation to the security measures applicable to the present platform and the user, should he/she wish to know them, should consult the corresponding particular conditions of the network in question.


The language applicable to this Privacy Policy is Spanish. Therefore, in case there is any contradiction in any of the versions we could provide in other languages, the Spanish version will prevail.


This Privacy Policy was last updated in January 2024 but may be updated at any time. We recommend that you check it every time you access our website in case it has suffered alterations.

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