“HOMLI” as a data processor on behalf of “Kelisto Iberia, SL.”

“HOMLI REAL ESTATE S. L.”, within the framework of a cooperation agreement concluded with “Kelisto Iberia, SL.”, transfers to the latter the personal data entered by you in the electronic form available on the website https://thehomli.com/, so that you can be fully informed by “Kelisto Iberia, SL.” about the possibility of granting a mortgage loan for the purchase/construction/repair of real estate. This processing is carried out by “HOMLI REAL ESTATE S.L.” on behalf of “Kelisto Iberia, S.L.” under its instructions and directives. Therefore, “Kelisto Iberia, S.L.” is the Controller of your personal data [hereinafter referred to as the “Controller”], and “HOMLI REAL ESTATE S. L.” is the Processor [hereinafter referred to as the “Processor”].

Below is detailed information regarding the processing of personal data, which is subject to the relevant provisions of applicable European legislation (primarily the General Data Protection Regulation 2016/679) [hereinafter referred to as the “GDPR”] and the related Spanish laws on protecting individuals against the processing of personal data, as supplemented by the decisions of the competent supervisory authorities:

• What personal data do we process?

  When you fill out the electronic interest form available on our website to request a loan pre-approval offer from the Controller, we process the following personal data:

  *Basic information: your first and last name,
  *Contact information: your mobile phone number and email.
  *Financial data: gross annual income, loan amount.

  The collection of the aforementioned personal data has been instructed by the Controller and is necessary for its communication with you to meet your request concerning receiving the aforementioned offer.

• Purpose and legal basis for processing

  The Controller processes your personal data to contact you, following your expression of interest, to provide detailed information regarding the possibility of granting a mortgage loan for the purchase/construction/repair of real estate.

  The legal basis for processing your personal data by the Controller for this purpose is Article 6(1)(b) of the GDPR, which allows the Controller to process personal data when processing is necessary to take steps at the request of the data subject prior to entering into a contract.

  We, on our part, as Processors, following the instructions we receive from the Controller, collect your aforementioned personal data and transmit them via email to the Controller to satisfy your request.

• How long do we keep your personal data?

  The Controller will retain your personal data for 6 months after their transmission by the Processor, after which your personal data will be deleted. For the same period, the Processor also retains your personal data, following the Controller’s instructions to fulfill its contractual obligations unless there is another legal basis, such as your explicit consent, for retaining your personal data for a longer period. Please note that upon your request [see your rights below under the GDPR], the Controller will delete your personal data earlier. Requests can be made via email at dpo@kelisto.es.

• To whom are your data disclosed?

  The Controller does not transfer or disclose your personal data to any third party. The Processor transfers your personal data to the Controller to inform you about the possibility of granting a mortgage loan for the purchase/construction/repair of real estate, following your expression of interest.

• What are your rights?

  According to data protection legislation, when we process your personal data, you have certain rights that we need to inform you about. These are:

  • The right of access [Article 15 GDPR]

    You have the right to request information about your data processing from the Controller or copies of your personal data at any time.

  • The right to rectification [Article 16 GDPR]

    You have the right to request that the Controller correct any information you consider inaccurate or complete any information you consider incomplete at any time.

  • The right to erasure (“right to be forgotten”) [Article 17 GDPR]

    You have the right to request the deletion of your personal data under certain conditions, such as when the data is no longer necessary.

  • The right to restriction of processing [Article 18 GDPR]

    You have the right to request the restriction of your data processing under certain circumstances, such as disputing their accuracy.

  • The right to object [Article 21 GDPR]

    You have the right to object to the processing of your personal data by the Controller unless public interest is affected.

  • The right to data portability [Article 20 GDPR]

    This applies only to the data you have provided. You have the right to request that your data be transferred to another organization or directly to you.

  Requests will be addressed within one month or up to two additional months due to the complexity or volume of requests. Requests made to us will be forwarded to the Controller immediately.

• Contact

  To exercise your rights regarding your data processing by the Controller, email dpo@kelisto.es or write to Paseo de la Castellana 81, Planta 15 (28046 – Madrid). For data protection issues regarding the Processor, contact data@thehomli.com.

  If you believe your personal data protection has been violated, you can file a complaint with the Spanish Data Protection Agency www.aepd.es.