Personal Data Policy

1. Request for information phase:

Information on the processing of customer personal data by Kronos

Party responsible for data processing

BB MONTEFORT RE HOLDINGS UNIPESSOAL, LIMITADA or any of the companies managed by MONTE FORTE depending on the Project (hereinafter referred to as “MONTE FORTE“).

Registered office: São Tomé and Príncipe

Data Protection Officer contact: geral@bbmontefort.st

What data processing is carried out by MONTE FORTE?

The processing of personal data by MONTE FORTE will depend on the status of the temporary relationship with the data subject. Below, we will detail purposes, legal bases associated with the processing, categories of data processed, as well as retention periods of the personal data processed.

MONTE FORTE will process the personal data collected directly from the interested parties or through the information request forms in order to be able to attend the request about the indicated promotion. In this sense and according to the request received, MONTE FORTE will send the interested party information about the development of the property they are interested in. If the interested party does not wish to continue receiving information about said promotion, they may request the cancellation of communications whenever they consider it appropriate through the following e-mail address: geral@bbmontefort.st

Finally, the application form requests the interested party’s consent to: (i) receive information about other developments marketed by MONTE FORTE and (ii) communicate their data to other companies in the real estate sector managed by Kronos so that they can send information about their products. This treatment is explained in section 5 of this document “Commercial information“. 

Legitimacy in the processing of personal data: MONTE FORTE processes the information provided on the basis of:

  • The processing necessary for the implementation at the request of the data subject requesting information on a property whose marketing and sale is by MONTE FORTE. (art.6.1.b) of the General Data Protection Regulation).
  • The express consent of the data subject through the boxes provided for this purpose in the information request form. (art.6.1.a) of the General Data Protection Regulation).

Categories of personal data: The personal data that MONTE FORTE will process at the time of the information request are: name and surname, address, e-mail address, details of the property of interest, as well as the contact details of the sales representative assigned to your information request. 

Data Retention: KRONOS will keep the personal data of the interested parties during the marketing period of such promotion. If the interested parties finally decide to proceed with the purchase of the property, MONTE FORTE will process the information related to the down payment or purchase in accordance with the data processing foreseen for those phases. If, in the end, the interested parties do not proceed with the purchase of the property, KRONOS will not process such information, except in the case foreseen in point 5 on commercial information. See point 5. Commercial Information. 

2. Choice of property phase:

MONTE FORTE will process your personal data in order to manage the choice of the property by the interested party. This choice can be made by means of a deposit document.

Legality in the processing of personal data: 

MONTE FORTE will process all information provided by the data subject for the purpose of managing the choice of a property for future purchase (art.6.1.b) of the General Data Protection Regulation). In this regard: 

  • MONTE FORTE will inform the commercial agents designated in this promotion of this choice in order to carry out the execution of the promotion.
  • MONTE FORTE may carry out the data processing derived from the implementation of this document or from any management derived from the guarantee deposit.

Likewise, from the moment the deposit is made, MONTE FORTE implements all the obligations arising from the regulations on the prevention of money laundering and terrorist financing with the processing of personal data derived from the identification obligations. (art.6.1.c) of the General Data Protection Regulation). In this case, the data subject is informed that MONTE FORTE may share this information with the other companies it manages in the real estate sector for the sole purpose of streamlining and managing the obligations that fall on these companies in this area. 

On the other hand, only in the event that the interested party has expressly consented to the option of financing the property (art.6.1.a) of the General Data Protection Regulation) the data of the interested party may be communicated to the financial institution with which MONTE FORTE maintains relations to facilitate the financing of this promotion, for the purpose of contacting them for the study and management of the possible financial transaction for the purchase of the aforementioned property. This consent will imply that the entity chosen for the possible financing will communicate your data to MONTE FORTE once the operation has been approved or denied in order to continue with the negotiations of the possible purchase of the property in the appropriate terms.

Categories of personal data: The personal data that MONTE FORTE will process at the time of choosing the property will be your name and surname, address, e-mail address, details of the property of interest, the salesperson assigned to your request for information, guarantee deposit, account information from financial institutions, signed deposit documents, expected time of formalization of the purchase contract and identification documents required by MONTE FORTE in order to comply with obligations for the prevention of money laundering. MONTE FORTE may also obtain additional data, either from common information files for the prevention of money laundering, as well as from official public registries. 

Data retention: MONTE FORTE will keep your personal data during the period of choice of the property or it can be extended in the event that the purchase is formalized. In the event that the purchase of the property does not materialize, your data will be kept blocked for a period of ten years to comply with the obligations of conservation of documentation derived from the regulations on prevention of money laundering and terrorist financing.

3. Purchase and Sale Formalization Phase:

MONTE FORTE will process the buyers’ data in order to manage and formalize the purchase contract. 

Legality in the processing of personal data: MONTE FORTE processes the information provided on the basis of the processing necessary for the performance of a purchase contract between the data subject and MONTE FORTE. (art.6.1.b) of the General Data Protection Regulation). In this regard, this relationship will involve the following processing of personal data:

  • Necessary management for the formalization of the purchase contract.
  • Documentary/contractual, accounting, tax and administrative management.
  • Management and, if necessary, communication of data with public registries, agencies, insurance companies and notaries involved in the process.
  • Pre- and post-sale management. All the activities that are carried out according to the needs that may arise from the provision of the property.

Compliance with identification obligations derived from the applicable regulations (art.6.1.c) of the General Data Protection Regulation):

  • Prevention of money laundering and financing of terrorism. In this case, you are informed that MONTE FORTE may share such information with other companies that it manages and that have already been mentioned above for the sole purpose of streamlining and managing the obligations that fall on such companies in such matters.
  • Necessary data communications with public bodies that either may require information or such data communication derived from the regulations themselves, such as tax regulations.

Only in the event that the interested party has consented to the financing of the property, their data may be communicated to the financial institution with which MONTE FORTE maintains relations to carry out the economic operation of the purchase of the property. (art.6.1.a) of the General Data Protection Regulation).

Categories of personal data: The personal data that MONTE FORTE will process when you choose a property will be your name and surname, address, e-mail address, details of the property you are interested in, the salesperson assigned to your request for information, guarantee deposit, financial institution account information, professional information, family information, financial situation information, tax information, signed deposit documents, expected completion dates of the purchase contract and identification documents required by MONTE FORTE in order to comply with anti-money laundering obligations. Furthermore, MONTE FORTE may obtain additional data, either in common information files for the prevention of money laundering, as well as from official public registries. Likewise, MONTE FORTE may process personal data of third parties provided by the buyer, such as: legal representatives, collaborators, guarantors, relatives or other related persons in case of presenting personal and material guarantees. 

With respect to the above-mentioned processing of third-party data, the purchaser confirms that such data are genuine and that the subjects concerned have been informed and have consented to the processing of their personal data by MONTE FORTE. 

Data retention: MONTE FORTE will keep your personal data during the entire process of formalization of the purchase. Once the period of one year and a half has elapsed (the period provided for possible post-sale management) your data will be kept blocked for a period of ten years to comply with the obligations of conservation of documentation derived from the regulations on the prevention of money laundering and terrorist financing. 

4. Quality surveys:

Also, MONTE FORTE will send you, based on its legitimate interest (art.6.1.f) of the General Data Protection Regulation), quality surveys on the service offered, the properties offered in order to learn from customer feedback, improve the information and quality of the processes and therefore the experience of all stakeholders in MONTE FORTE promotions. MONTE FORTE has carried out a weighting test of the aforementioned legitimate interest in order to verify that the sending of these satisfaction surveys to those interested in MONTE FORTE promotions does not undermine their data protection rights. After such analysis, MONTE FORTE understands that these rights are not violated given the clear information contained in this information document, as well as the possibility of the interested party to oppose the sending of such surveys either (i) via email at the time of the request and (ii) in the unsubscribe procedure that exists in such communication. Likewise, MONTE FORTE will not send such surveys to those who have not consented to receive information about other MONTE FORTE Group promotions. If you would like to know more about the details of this weighting test, you can request this at the following email address: geral@bbmontefort.st

5. Commercial information:

In the information request forms, MONTE FORTE will enable a mechanism for those who are interested to expressly consent to the subsequent processing (art.6.1.a) of the General Data Protection Regulation):

  • A specific consent so that MONTE FORTE, either through calls from its managers or through e-mail, can send commercial information about events or other promotions marketed by MONTE FORTE or other products in the real estate sector to which MONTE FORTE is a party. For the preparation of such communications, MONTE FORTE will personalize them based on profiles based on the preferences of promotions that have been expressed, or, if they are customers, based on personal data that MONTE FORTE has regarding their preferences and operating history.
  • Another specific consent allows MONTE FORTE to send the contact details of the interested parties to other companies managed by MONTE FORTE so that they can send them commercial information about their products in the real estate sector.

Only if the interested party has consented to such processing, MONTE FORTE will process such information in any of its phases in order to keep them informed of other promotions or that other companies may know their data to send associated information. The interested party may always revoke the consent given. MONTE FORTE, in the rest of the documentation associated with the sale of the property, includes mechanisms for revocation of consent, but, in any event, you can always revoke such consent, through a written communication, together with a copy of your ID card, at the address Calle Serrano 3, 28001 Madrid or via email to: protecciondedatos@kronosig.com. 

6. Processing of Web data:

If the interested party wishes to know about the processing of personal data carried out by MONTE FORTE through www.bbmontefort.st, they may refer to the following informative texts:

If the interested party wishes to know about the processing of personal data carried out by MONTE FORTE, through https://bbmontefort.st/ they can refer to the following informative texts: 

To whom are your personal data communicated? 

  • Only if the interested party has given their express consent, through the mechanism provided for this purpose, MONTE FORTE may forward contact information to the other companies managed by MONTE FORTE so that they can send the interested party commercial information.
  • Depending on the time phase of the relationship with the interested party:
  • During the information request phase, MONTE FORTE will not communicate your data to any third party, apart from MONTE FORTE’s suppliers, as stated in the last paragraph of this section.
  • In the phase of choosing the property, MONTE FORTE may communicate data of the data subject to:
  • Kronos Group companies for purposes related to the prevention of money laundering and terrorist financing.
  • In the event that the interested party is interested in financing the property, its data may be communicated to financial institutions.
  • In the purchase and sale phase:
  • Financial entity for the management of the financing and possible subrogation of real rights.
  • Entities insuring the contract.
  • Public bodies and institutions of the General State Administration, Regional and Local Administrations.
  • Security Forces and Bodies in case MONTE FORTE is required to provide certain information.
  • Courts and Tribunals in the event of any proceedings or dispute arising from the purchase contract.
  • Entities that participate in the process of preparing the property, either supply or assembly companies both in a phase prior to the delivery of the property, as well as in a later phase in the event that any repairs, modifications or additional materials are necessary.
  • Finally, KRONOS has third party service providers that may have access to personal data of interested parties in connection with the provision of its services, such as suppliers, materials, maintenance, control and monitoring of works, architects, site technicians, auditors, experts, lawyers, managers, IT maintenance, financing services, potential investors, administrative services and destruction of documentation, among others. KRONOS pre-selects these suppliers based on data protection compliance criteria, has signed data protection contracts with all of them and monitors their compliance with their data protection obligations.

International Data Transfers

The interested party is informed that MONTE FORTE does not carry out international transfers of its data.

Possible Claims or Exercise of Data Protection Rights

The interested party may exercise the rights of access, rectification, deletion, limitation, opposition, and portability with respect to their personal data, as well as the right to withdraw the consent given, requesting this in writing by email to geral@bbmontefort.st

or letter addressed to the registered office of KRONOS indicated above, attaching a copy of your ID card. You can also file any type of data protection claim to the address indicated above or the interested party can go to the Spanish Data Protection Agency, the supervisory authority on data protection:  http://www.agpd.es.  

Terms and Conditions

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