Effective Date: 23 June 2024

Company Name: BETWEEN LIGHT & SHADOW S.L.

Tax Identification: B19448240

Company Address: Volubilis-Coworking, Urb. La Coneja, Edifico Centro Expo, Local 46-48, 29602, Marbella, Malaga

Contact Number: +34610139380

Company Email: info@entreluzysombra.com

Introduction
BETWEEN LIGHT & SHADOW S.L. ("we", "our", or "us") is committed to protecting and respecting your privacy.
This Privacy Policy explains how we collect, use, and protect the personal data you provide to us in compliance
with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and other applicable laws in Spain.

This policy applies to our services related to real estate and concierge operations, whether you access them
through our website, via email, over the phone, or in person at our office in Marbella, Spain.

1. Data Controller
The data controller for your personal data is:
Company Name: BETWEEN LIGHT & SHADOW S.L.
Address: Volubilis-Coworking, Urb. La Coneja, Edifico Centro Expo, Local 46-48, 29602, Marbella, Malaga
Phone Number: +34610139380
Email: info@entreluzysombra.com

2. Personal Data We Collect
We may collect and process the following personal data:
- Identity Data: Name, surname, date of birth, passport or ID number.
- Contact Data: Email address, phone number, postal address.
- Financial Data: Payment details, bank account information.
- Transaction Data: Details of services you have purchased or inquiries made.
- Technical Data: IP address, browser type, time zone settings, and cookie data when using our website.
- Marketing and Communication Data: Your preferences in receiving marketing from us and your communication preferences.
- Special Categories of Personal Data: Health data, if necessary for personalized concierge services (e.g., dietary preferences or medical requirements).

3. How We Collect Your Data
We collect personal data directly from you through:
- Contact forms on our website.
- Phone calls, emails, or in-person meetings at our office.
- Online property search queries or concierge service requests.
- Booking forms for our real estate or concierge services.

4. Legal Basis for Processing
We process your personal data in accordance with the GDPR, and we rely on the following legal bases:
- Contractual Necessity: To provide services you request (e.g., booking real estate visits or concierge services).
- Legal Obligation: To comply with legal requirements, such as tax laws or anti-money laundering regulations.
- Legitimate Interests: For our business purposes, such as improving our services and maintaining communication with you, unless these interests are overridden by your privacy rights.
- Consent: For sending marketing communications or sharing your data with third parties, we will ask for your explicit consent.

5. How We Use Your Data
We use your personal data for the following purposes:
- To provide real estate and concierge services as requested.
- To respond to your inquiries or booking requests.
- To carry out obligations arising from any contracts between you and us.
- To process payments and invoices.
- To send you marketing communications (with your consent).
- To comply with legal obligations, such as tax or financial reporting.
- To improve our website and customer experience.

6. Data Sharing
We may share your personal data with third parties, but only when necessary for the delivery of our services or when legally required:
- Service Providers: Such as payment processors, IT support, and other third-party contractors that assist us in providing services to you.
- Legal Authorities: When required by law or in response to a legal request.
- Business Partners: For services related to your property transactions or concierge needs (e.g., property managers, legal advisors, contractors).
We ensure that any third-party service providers comply with GDPR and that adequate safeguards are in place for data protection.

7. International Data Transfers
As our operations are based in Marbella, Spain, your personal data will primarily be processed within the European Economic Area (EEA). However, if we need to transfer your data outside the EEA (e.g., if a service provider is located outside the EEA), we will ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or another approved mechanism.

8. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for legal or accounting purposes.
- Real estate transaction data: Retained for 6-20 years (depending on type of document and legal context) after the completion of a transaction.
- Marketing data: Retained until you withdraw your consent.
- Financial data: Retained for 6 years to comply with tax regulations.

9. Your Data Protection Rights
Under the GDPR, you have the following rights regarding your personal data:
- Right to Access: You can request a copy of the personal data we hold about you.
- Right to Rectification: You can ask us to correct any inaccuracies or incomplete data.
- Right to Erasure ("Right to be Forgotten"): You can request deletion of your data where there is no legitimate reason for us to retain it.
- Right to Restriction of Processing: You can request us to limit processing of your data.
- Right to Data Portability: You can request that we transfer your data to another service provider.
- Right to Object: You can object to us processing your personal data based on legitimate interests or for direct marketing purposes.
- Right to Withdraw Consent: If we rely on your consent for processing, you have the right to withdraw it at any time.

You may exercise these rights by contacting us at info@entreluzysombra.com.

10. Security of Your Data
We take appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These include encryption, secure servers, and access control systems.

11. Cookies
Our website uses cookies to improve user experience. For more information on how we use cookies, please refer to our Cookie Policy.

12. Changes to This Privacy Policy
We may update this policy from time to time to reflect changes in legal or regulatory requirements. We will notify you of any significant updates by posting the new Privacy Policy on our website.

13. Contact Us
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:

Company Name: BETWEEN LIGHT & SHADOW S.L.
Address: Volubilis-Coworking, Urb. La Coneja, Edifico Centro Expo, Local 46-48, 29602, Marbella, Malaga
Phone Number: +34610139380
Email: info@entreluzysombra.com

You also have the right to lodge a complaint with the Spanish Data Protection Authority (AEPD) at www.aepd.es if you believe your data has been mishandled.

This Privacy Policy was last updated on 22 January 2025.