Last updated: July 23, 2026
1. Data Controller
Pursuant to Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on Personal Data Protection (LOPDGDD), the following details identify the data controller:
- Legal name: René Bescós Propiedades
- Tax ID (NIF/CIF): 09081434E
- Address: Calle Gibraltar 41, Estepona (Málaga), 29680
- Phone: +34 692 55 80 18
- Email: rene.bescos@gmail.com
- Website: https://rene-bescos-propiedades.inmoly.es
2. The Inmoly platform as data processor
René Bescós Propiedades acts as data controller for the personal data collected through this website (contacts, information requests, buyer demands, seller listings, etc.).
To deliver the service, René Bescós Propiedades uses the Inmoly SaaS platform operated by NICHOWEB, S.L. (Spanish tax ID B88673991, registered office at C/ Vasco de Gama 2, 1º 1, 29014 Málaga, Spain; www.inmoly.es), which acts as a data processor under Art. 28 GDPR. The relationship is governed by the Data Processing Agreement (DPA) published at www.inmoly.es/legal/dpa.
3. Applicable law
This policy complies with current Spanish and European law:
- Regulation (EU) 2016/679 (GDPR)
- Spanish Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD)
- Spanish Law 34/2002 on Information Society Services and E-Commerce (LSSI-CE)
4. Information we collect
Information provided directly by the data subject:
- Contact details: first name, last name, email, phone
- Request details: type of operation (purchase, rental, sale), property preferences, budget, free-form message
- Property data (in seller listings): address, characteristics, documentation provided
- Communications with our team
Information collected automatically:
- Technical information: browser, operating system, IP address, device type
- Site-usage data: pages visited, properties consulted (only with cookie consent)
- Cookies and similar technologies (see the Cookie Policy)
5. Purposes and legal bases (Art. 6 GDPR)
| Purpose | Legal basis |
|---|---|
| Handling the information request and commercial contact | Art. 6(1)(a) — explicit consent; Art. 6(1)(b) — pre-contractual measures at the data subject's request |
| Handling seller listings (sale or rental) | Art. 6(1)(b) — contract performance or pre-contractual measures |
| Processing purchases, rentals and contract signing | Art. 6(1)(b) — contract performance; Art. 6(1)(c) — legal and tax obligations |
| Commercial communications about similar properties of interest | Art. 6(1)(a) — explicit consent (opt-in checkbox) |
| Security, fraud prevention and audit log | Art. 6(1)(f) — legitimate interest |
| Compliance with tax and accounting obligations | Art. 6(1)(c) — legal obligation |
6. Recipients and processors
René Bescós Propiedades does not sell personal data. For the provision of the service, personal data is processed by the following processors:
- NICHOWEB, S.L. — provider of the Inmoly SaaS platform that hosts the CRM and the website. NICHOWEB's sub-processors (Neon, Vercel, Cloudflare, OVH, Stripe, Resend, Sentry, Google Analytics) are listed in the up-to-date Annex II of the Inmoly DPA.
When René Bescós Propiedades publishes properties on real-estate portals (Idealista, Fotocasa, etc.), property data and contact details of the listing agent are transmitted to the corresponding portal, which acts as an independent data controller under its own privacy policy.
We may also share data with competent authorities when required by law or judicial order.
7. Retention periods
| Data | Period | Basis |
|---|---|---|
| Unconverted lead data (no operation) | 2 years from the last active contact | Controller's legitimate interest; periodic review |
| Client data with contractual operation | Duration of the contract + 5 years | Statute of limitations for contractual liability (Art. 1964 Spanish Civil Code) |
| Accounting and tax documentation | 10 years | Spanish General Tax Law 58/2003; Commercial Code |
| Consent records | As long as consent is active + 3 years from withdrawal | Art. 7(1) GDPR (burden of proof of consent) |
| Analytics data (if active) | 26 months (GA4 default) | Legitimate interest; user consent |
8. Your rights
Under the GDPR and LOPDGDD, the data subject has the right to:
- Access (Art. 15 GDPR): obtain confirmation and a copy of the personal data we process
- Rectification (Art. 16 GDPR): correct inaccurate or incomplete data
- Erasure / right to be forgotten (Art. 17 GDPR): request deletion when data is no longer necessary
- Restriction of processing (Art. 18 GDPR): restrict processing under certain circumstances
- Portability (Art. 20 GDPR): receive data in a structured, commonly-used format
- Objection (Art. 21 GDPR): object to processing based on legitimate interest
- Not be subject to automated decisions (Art. 22 GDPR)
- Withdrawal of consent: at any time, without retroactive effect
To exercise any of these rights, send an email to rene.bescos@gmail.com stating which right you wish to exercise and attaching a copy of your identification document. We will respond within one month (Art. 12 GDPR).
8.1. Withdrawal of marketing consent (Art. 7(3) GDPR)
Under Art. 7(3) GDPR, withdrawing consent must be as easy as giving it. If you have agreed to receive commercial communications and wish to stop receiving them, you have three equivalent options:
- Click the "unsubscribe" link at the bottom of every commercial email. The link leads to https://rene-bescos-propiedades.inmoly.es/unsubscribe with a unique token that confirms your identity without requiring login.
- Write to rene.bescos@gmail.com stating "unsubscribe from commercial communications" and the email to be unsubscribed.
- If you have a customer account, disable the option in your communications settings.
Withdrawal is processed immediately. Commercial emails already scheduled may take up to 48 hours to stop; after that, no further marketing communications will be sent.
8.2. Right to lodge a complaint with the AEPD
If you believe the processing does not comply with applicable law, you may lodge a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.
9. Security
We apply appropriate technical and organisational measures pursuant to Art. 32 GDPR, at two levels:
- At the platform level (managed by NICHOWEB, S.L. as data processor): SSL/TLS encryption in all communications, encryption at rest, logical multi-tenant isolation per agency, role-based access control, audit log of all state changes, and no publicly exposed TCP ports. The concrete guarantees are detailed in Annex III of the Inmoly DPA.
- At the organisational level (managed by René Bescós Propiedades): staff access control, data-protection training, strong-password policy and revocation of access when employees leave.
9.1. Breach notification
We strictly comply with GDPR timelines for incidents affecting personal data:
- Notification to the AEPD (Art. 33 GDPR): within a maximum of 72 hours of becoming aware of the breach, unless it is unlikely to pose a risk to the rights and freedoms of those affected.
- Notification to data subjects (Art. 34 GDPR): when the breach poses a high risk to their rights and freedoms, we will inform them without undue delay by email to the address on file, including: nature of the incident, categories of data affected, estimated number of data subjects, likely consequences and measures taken.
- Chain with the platform: NICHOWEB, S.L. is contractually obliged to notify René Bescós Propiedades of any breach affecting data processed through Inmoly within the same 72-hour period, pursuant to §3.9 of the DPA. René Bescós Propiedades is responsible for the downstream notification to the AEPD and to data subjects.
- Internal record: we document all breaches per Art. 33(5) GDPR even when not notifiable, including facts, effects and corrective measures.
10. Minors
The services are aimed at persons over 18 years of age with the legal capacity to enter into real-estate transactions. We do not intentionally collect data from minors. If you become aware that a minor has provided us with data, contact us to delete it.
11. Changes to this Policy
We may update this policy to reflect regulatory or practice changes. Material changes (new legal basis, new processor, changes in retention) will be notified at least 30 days in advance when there is an active contact channel. Non-material changes will be published without prior notice.
12. Contact
René Bescós Propiedades
Tax ID: 09081434E
Calle Gibraltar 41, Estepona (Málaga), 29680
Phone: +34 692 55 80 18
Email: rene.bescos@gmail.com
© 2026 René Bescós Propiedades. All rights reserved.