This website is provided by Sanabria & Associates. (“Sanabria,” “we” and “our”).
Sanabria is committed to ensuring that your privacy is protected. This Privacy Notice explains how we use the information we collect about you, how you can instruct us if you prefer to limit the use of that information and procedures that we have in place to safeguard your privacy. Any reference to “you” or “your” refers to anyone whose personal information we process.
Sanabria is a controller for the personal information that it collects and uses about you. We will treat your personal information as confidential and in accordance with applicable data protection legislation and your personal information will only be shared with others in accordance with this Privacy Notice.
1. What personal information do we collect and how do we use it?
Categories and Types of Personal Information We Collect
We collect the following categories and types of personal information:
- Contact Information: your first and last name, email address, and phone number;
- Other identifying information: IP address;
- Financial Information: wire, ACH and bank account information;
- Internet or other electronic activity: your browsing and click history, including information about how you navigate within our services and which elements of our services you use the most;
- Commercial information: services viewed on our website; and
- Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, behavior and attitude.
Categories of Use
- Transactional Purposes: We use your contact information, financial information, and commercial information to:
- Sign you up as a customer; and
- Process your request and provide you with the research reports and other information requested.
- Analytical Purposes: We use your internet activity and browsing history to analyze preferences, trends and statistics.
- Marketing Purposes: We use your contact information, commercial information, internet or other electronic activity, and inferences to:
- Inform you of our new products, services and offers;
Maintenance and Improvement of Services and Website: We use your contact information, commercial information, and internet activity and browsing history to:
- Provide and maintain functionality on our website;
- Handle your customer services requests; and
- Help us diagnose technical and service problems and administer our services.
2. What are our sources of personal information?
We collect information directly from you. We collect contact information directly from you. We also collect financial information from you.
We collect information from you passively. We collect Internet or other electronic activity passively using tools like browser cookies. This activity is further described in the Advertising and Online Tracking section below.
3. How do we protect your information?
The security of information is very important to us and we have measures in place which are designed to prevent unauthorized access to your personal information. We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through this website, we cannot and do not guarantee the security of any information you transmit on or through this website and you do so at your own risk.
4. Who do we share your personal information with?
Our Service Providers
We may contract with companies or persons to provide certain services including promotional services, etc. We call them our Service Providers. We provide our Service Providers with the information needed for them to perform these services. For example, we may use your personal information with Service Providers who help us with hosting and maintenance, data storage and management, and marketing and promotions. We also ask our Service Providers to confirm that their privacy practices are consistent with ours.
We may share personal information with businesses controlling, controlled by, or under common control with any of our affiliates. Additionally, If we sell any part of our business and/or integrate it with another business your details may be disclosed to our advisers and to any prospective purchaser or joint venture partners and their advisers and will be passed on to the new owners of the business. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this Privacy Notice.
Law Enforcement and Courts
In certain instances, we may disclose your contact information when we have reason to believe that it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Sanabria or to others. We may also disclose your contact information when we believe the law or legal process requires it.
5. Lawful basis for processing for EU residents
Under data protection legislation in the EU, we are only permitted to use the personal information of EU residents if we have a legal basis for doing so. We rely on the following legal bases to use your information:
- Where we need information to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where the processing is necessary for us to carry out activities for which it is in Sanabria’ legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:
- Processing that is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns. – this will include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.
- Processing that is necessary to improve our knowledge of the real estate sector – this will include undertaking market analysis and research so that we better understand trends in the property sector and provide better knowledge along with more tailored and relevant services for our customers in the future.
- Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively – this will include: verifying the accuracy of information that we hold about you and create a better understanding of you as a customer; processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are in such services; processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorized access or to comply with a request from you in connection with the exercise of any of your rights outlined below.
- In more limited circumstances we may also rely on the following legal bases:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
6. Your EU Rights
If you are a resident of the EU, you have a number of rights in relation to your personal information, these include the right to:
- Be informed about how we use your personal information
- Obtain access to your personal information that we hold
- Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate
- Request that we erase your personal information in the following circumstances:
- If Sanabria is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected
- If Sanabria is relying on consent as the legal basis for processing and you withdraw consent
- If Sanabria is relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us continue with the processing
- If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)If it is necessary to delete the personal information to comply with a legal obligation
- Under certain circumstances, have your personal data transferred to another company
- Ask us to restrict our data processing activities where you consider that:
- personal information is inaccurate
- our processing of your personal information is unlawful
- where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim
- where you have raised an objection to our use of your personal information
- Request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information
- Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and
- Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.
- Lodge a complaint with your relevant data protection authority.
If you would like to exercise any of your rights as an EU resident, please contact email@example.com. Please note that some requests may require you to verify your identity.
7. Advertising and Online Tracking
We may allow third-party companies to serve ads and collect certain information when you visit this website. These companies may use certain information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this website and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie to collect this information. Our systems do not recognize browser “Do Not Track” signals, but several of our Service Providers who utilize these cookies on this website enable you to opt out of targeted advertising practices. To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/. We also provide you with additional tools to opt out of marketing from us.
8. Notice to California Residents/Your California Privacy Rights
If you are a California resident, you have certain privacy rights under the California Consumer Privacy Act ( “CCPA Rights”). This section describes those rights and how you can exercise them with Sanabria.
Personal Information that We Sell
We do not currently sell (as sell is defined in CCPA) any personal information.
CCPA Rights Requests
Right to Know and Right to Deletion
You can request what personal information we have collected, used, disclosed, and sold in the preceding 12 months.
You can also request that we delete your personal information, but we may not delete all of your personal information if one of the following exceptions applies:
- Transactional: to complete a transaction for which the personal information was collected, provide a good or service requested by you, or perform a contract we have with you;
- Security: to detect data security incidents;
- Error Correction: to debug or repair any errors;
- Legal: to protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or
- Internal Use: to use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).
Please note that if we delete your personal information, many of our services will not work the same. For example, your previous opt out requests will not be saved, and you will not receive previously requested communications from us.
To submit a request to know or a request to delete, please email us at firstname.lastname@example.org detailing your request. In order to verify your identity, please include your first and last name, email address and phone number in your request. You can designate an agent to make a request by having them provide written proof of authorization to be your designated agent.
If you wish to make multiple requests under this section, we recommend sending the deletion request last, as we will not be able to fulfill your other requests once we have deleted your information.
We will not discriminate against you for exercising any of your CCPA Rights and we will not deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA Rights.
To opt out of sharing your personal information with third parties for their direct marketing purposes, please e-mail us at email@example.com and clearly state your request, including your name, mailing address, e-mail address and phone number.
9. Children’s Privacy
This website is intended for users who are 13 years old or older. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have inadvertently received personal information from a child under the age of 13, we will delete such information from our records.
10. Overseas transfers of your personal information
Because the Internet infrastructure is global the information you provide may be transferred to countries outside the United States that do not have similar data protection legislation during use as set out in this Privacy Notice. However, we will ensure that appropriate safeguards are put in place to protect the security of your information.
What is a cookie?
A cookie is a small text file that is downloaded onto your computer when you visit certain websites and allows a website to recognize a user’s computer. Cookies are used to help users navigate websites more efficiently and to perform certain functions, as well as to provide information to the owners of the website.
What cookies does Sanabria use?
We do not place cookies until you elect to continue using our website after our cookie banner displays.
We use the following types of cookies:
Required cookies: Cookies that are required to operate our website and to allow you to navigate the website and use certain features. These cookies are stored for the duration of your visit on our website.
Functional cookies: Cookies that allow us to measure how our website is accessed and used so we may improve performance. These cookies are stored for the duration of your visit on our website and we, or a third party on our behalf, may place these cookies.
Marketing cookies: Cookies that allow us to serve targeted advertising to you on our website and other websites. These cookies allow us to share your information (e.g. what products and services you like with our advertisers) so you will be presented with more catered advertisements. These cookies are stored for 30 days or less.
Interaction cookies: Cookies that allow you to interact with your social media accounts or to submit reviews and feedback. They may also be used to track your interaction on social media platforms. These cookies are stored for the duration of your visit on our website.
What information is processed?
Our cookies and other tracking technologies will collect persistent identification numbers to enable our website to recognize you as a repeat visitor and apply your settings, preferences you set on our website, actions you take on our website and your browsing history.
How does Sanabria deploy cookies?
Legal basis for processing
We use the following cookies on the website:
- Crimtan (marketing)
- Doubleclick (marketing)
- Facebook (marketing)
- Giosg Live Chat (functional)
- Google Adwords (marketing)
- Google Analytics (marketing)
- gpsCountryCode (functional)
- gpsId (functional)
- gpsLanguageCode (functional)
- Hotjar (marketing)
- iGo digital (marketing)
- LinkedIn Conversion Tracking and Insight Tag (marketing)
- TV Squared (marketing)
- Webtrends (marketing)
- Yandex (marketing)
How do I restrict or delete cookies?
Your web browser may allow you to restrict or delete cookies set by this website. The Help function within your browser should tell you how. Alternatively, you can visit www.allaboutcookies.org which provides general information about cookies and how you can manage cookies on your computer.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
13. Contact Us
If you have any questions about this Privacy Notice, please send an email to firstname.lastname@example.org.You may also email us if any of the information that you have provided to Sanabria changes (for example if you change your email address) or if you no longer wish to receive information from our group of companies about services or products which we think may be of interest to you. In your opt-out email request, please state that you would like to opt-out of receiving our products and services communications.
This Privacy Notice was last updated on January 1, 2020.