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PRIVACY POLICY OF LARHOMES.ES

Last updated: 1 October 2026

1. Data controller

The controller of personal data collected through LarHomes.es is:

INMOBILIARIA PEÑA, S.L.

Trading name: LarHomes

Spanish Tax Identification Number (CIF): B39742952

Address: Bº Piedrahita 13, Local, 39740 Santoña, Cantabria, Spain

Privacy contact email: leads@larhomes.es

Telephone: +34 685 786 559

Hereinafter, “LarHomes”.

2. Personal data we may process

Depending on the user's relationship and the information supplied, LarHomes may process:

first and last name;

telephone number and email address;

language and country of contact;

information voluntarily provided through forms, emails, calls or messages;

properties about which enquiries have been made;

enquiry, communication and interaction history;

information required to identify the same individual correctly and avoid duplicate records;

information relating to partners, agencies, developers, suppliers or professionals;

technical and security information required to detect abuse, fraud or abnormal access.

LarHomes limits processing to personal data reasonably necessary for the relevant purpose.

Users should avoid submitting sensitive personal information in free-text fields when it is not necessary for their property enquiry.

3. Purposes of processing

Personal data may be processed for the following purposes:

a) Responding to property enquiries.

To answer requests concerning properties, developments, prices, availability, characteristics and related matters.

b) Taking pre-contractual steps.

To take measures requested by the individual before a possible reservation, purchase, lease, brokerage arrangement or other property transaction.

c) Providing requested documentation.

To send property details, plans, specifications, development information or other documents specifically requested.

d) Correctly identifying each contact.

To avoid duplicate records and correctly link enquiries submitted by the same person.

e) Maintaining a property enquiry history.

To retain information concerning properties previously enquired about and previous communications so that LarHomes can provide continuity of service.

f) Managing developers, partners and property suppliers.

To handle enquiries and transactions concerning properties marketed directly or in cooperation with third parties.

g) Preventing abuse and protecting systems.

To detect fraud, misuse, unauthorised access attempts, automated form abuse and similar activities.

h) Complying with legal obligations.

i) Sending marketing communications when specifically authorised.

Marketing information about properties, developments, opportunities or LarHomes services will only be sent where the individual has separately agreed to receive such communications.

Submitting a property enquiry does not, by itself, constitute consent to future marketing communications.

4. Legal bases

Depending on the purpose, processing may be based on:

Pre-contractual steps taken at the individual's request, particularly for responding to property enquiries and providing requested information.

Consent, where the individual expressly agrees to a specific form of processing, including marketing communications where consent is relied upon.

Consent may be withdrawn at any time without affecting processing lawfully carried out before withdrawal.

Legitimate interests, where necessary and proportionate to correctly identify individual contacts, prevent duplicate records, maintain reasonable continuity of communications, protect systems and prevent fraud or abuse, taking into account the rights and interests of the individuals concerned.

Compliance with legal obligations, where LarHomes is required by applicable law to process, retain or disclose information.

5. Disclosure to developers and property providers

Where an enquiry concerns a property whose information, availability, marketing or management depends on a developer, property owner, marketing company, partner agency or other property provider, LarHomes may disclose the personal data strictly necessary to process that enquiry.

Such disclosure will only take place where necessary to respond to the enquiry or carry out measures requested by the individual.

Depending on the circumstances, the recipient may act as an independent data controller and will be responsible for providing any privacy information required in relation to its own processing.

LarHomes does not disclose personal data to third parties for unrelated independent marketing campaigns unless there is a valid legal basis to do so.

6. Processors

LarHomes may use technology and professional service providers for services such as:

hosting and servers;

email;

CRM systems;

software development and maintenance;

storage and backups;

cybersecurity;

forms and communications.

Where those providers process personal data on behalf of INMOBILIARIA PEÑA, S.L., the relationship will be subject to applicable data protection requirements and, where required, a data processing agreement.

7. Marketing communications

Electronic marketing communications from LarHomes will only be sent where the individual has specifically requested or authorised them.

Consent to marketing is separate from requesting information about a property.

Consent may be withdrawn at any time by using the mechanisms provided in the communications or by writing to:

leads@larhomes.es

8. Retention

Contact details and property enquiry history will generally be retained for at least twelve months following the last interaction, in order to maintain continuity of service, correctly identify the individual and retain a reasonable history of properties previously enquired about.

After that period, data may continue to be retained where the relationship remains active, a valid purpose continues to apply or retention is necessary in connection with potential legal liabilities.

Where deletion applies, data may remain appropriately blocked for the applicable statutory limitation periods and may only be made available for the purpose of dealing with legal liabilities or requests from competent authorities.

Data processed solely for marketing purposes will cease to be used for that purpose when consent is withdrawn or the individual objects, without prejudice to retaining the minimum information necessary to record and respect the opt-out.

9. Individual rights

Where applicable, individuals may exercise their rights of:

access;

rectification;

erasure;

objection;

restriction of processing;

data portability;

withdrawal of consent where consent is the applicable legal basis.

Requests may be sent to:

leads@larhomes.es

Where there are reasonable doubts concerning the identity of the person making the request, LarHomes may ask for additional information strictly necessary to verify identity.

10. Complaints

Individuals who believe their personal data are being processed contrary to applicable data protection law may lodge a complaint with the:

Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD).

11. Security and data minimisation

LarHomes applies technical and organisational controls intended to protect personal data against unauthorised access, loss, alteration, disclosure or misuse.

These measures may include access controls, permission management, activity logging and auditing, backups, system maintenance and data minimisation.

12. Artificial intelligence

LarHomes may use AI-assisted tools for internal tasks involving the generation, translation, review, classification or improvement of content.

As an internal data-protection rule, content submitted to AI tools for these purposes must not contain personal data relating to contacts, customers or prospective customers, unless the proposed processing has first been assessed and found to have an appropriate legal basis and safeguards.

The use of AI tools does not in itself authorise personal data collected through LarHomes to be reused for purposes other than those for which they were obtained.

If LarHomes later introduces automated decision-making or profiling producing legal or similarly significant effects for individuals, this Policy will be reviewed before such processing is implemented where required by applicable law.

13. International data transfers

Certain technology providers may be established outside the European Economic Area or provide services involving access from third countries.

Before using services involving international transfers, LarHomes will assess the relevant processing and apply the safeguards required by the GDPR, which may include an adequacy decision by the European Commission, Standard Contractual Clauses or another legally recognised transfer mechanism.

Where legally required, this Policy will be updated to identify the relevant transfer and applicable safeguards.

14. Third-party personal data

Users providing personal data relating to another person should only do so where they have an appropriate legal basis and should avoid supplying unnecessary information.

15. Accuracy

Users are responsible for ensuring that the information they provide is accurate and reasonably up to date.

16. Changes to this Policy

LarHomes may update this Privacy Policy to reflect changes to its processing activities, providers or applicable law.

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