Privacy Policy

Introduction

STERLING REAL ESTATE, SL is committed to protecting the privacy of its users and developing the technology that provides you with the safest experience on the website. This privacy statement applies to the website www.sterling.ad.

Our Privacy Policy has been designed in accordance with the legal framework established by Law 29/2021 of 28 October, on the Protection of Personal Data. (hereinafter, ‘LQDP’), and with the regulations that develop it, this is subject to possible changes in accordance with the legislation applicable at any given time or the interpretation of the Andorran Data Protection Agency (APDA).

By providing us with their data, the user declares that they have read and are aware of this Privacy Policy, giving their unequivocal and express consent to the processing of their personal data in accordance with the purposes and terms set out herein.

Who is the Data Controller?

Identity: STERLING REAL ESTATE, SL - hereinafter the entity.
NRT: L714922U
Address: 27 Avenue François Mitterrand, Ground Floor, AD200 Encamp, Principality of Andorra
Email: info@sterlingandorra.com
DPO Contact: Joel Rossell
Registered in the Companies Register of the Principality of Andorra: 19823

What data do we process, for what purpose and for how long?

Data processing	Purpose and Legitimacy	Conservation period
Contact form	To respond to requests and/or enquiries made by users, the legal basis for the processing being the user's explicit consent in accordance with Article 6(1)(a) of the GDPR.	The data will be retained until the request has been resolved. In any event, they may be retained to determine any potential liabilities that may arise from this purpose.
CV Management	The data will be processed for the purpose of handling your application and analysing your profile to participate in the recruitment selection processes. The basis legitimising the processing of personal data is your explicit consent, in accordance with Article 6(1)(a) of the GDPR. In the event that the entity publishes a job vacancy, the processing will be lawful when it is necessary for the taking of pre-contractual measures at the request of the data subject or for the purpose of entering into a contract, in accordance with Article 6(1)(b) of the GDPR.	The collected data will be retained for the time strictly necessary to fulfil the purpose for which they were collected, and in any event to determine any potential liabilities that may arise from that purpose, taking into account the periods established in the relevant legislation.
Transmission of informative communications	Subscription to the entity's news, promotions and offers, the legal basis for processing being express consent in accordance with Article 6(1)(a) of the GDPR.	The data will be retained for as long as the subscription to communications remains in effect, until the data subject exercises their right of objection or erasure. In any event, they may be retained to determine any potential liabilities that may arise from this purpose.
Email management	The purposes of the data processing are to respond to enquiries received and to manage the commercial and/or professional relationship, the legal basis being the contractual relationship between the Data Controller and the data subject, in accordance with Article 6(1)(b) of the GDPR.	The collected data will be retained for the time strictly necessary to fulfil the purpose for which they were collected, and in any event to determine any potential liabilities that may arise from that purpose, taking into account the periods established in the relevant regulations.

What data will be disclosed?

We do not intend to disclose your data, except as permitted by tax, commercial and telecommunications legislation, or where required to do so by a judicial authority.

International transfers

The entity does not carry out international transfers to a recipient located in a country or an international organisation that does not meet the requirements established by current data protection regulations.

Which cookies do we process?

The entity uses cookies for website users, primarily for the following purposes:

Ensuring the proper functioning of the entity's website.
Anonymised traffic analysis.
Collect statistical information in order to improve the website experience.

You can consult the cookies we process in detail via our Cookie Policy.

What rights do you have as a user and how can you exercise them?

Any data subject has the right to obtain confirmation as to whether or not we are processing personal data concerning them. Data subjects have the right to access their personal data, as well as to request the rectification of inaccurate data or, where applicable, request its erasure when, among other reasons, the data is no longer necessary for the purposes for which it was collected. In certain circumstances, data subjects may request the restriction of the processing of their data, in which case we will only keep it for the exercise or defence of claims. For reasons related to their particular situation, data subjects may object to the processing of their data. The data controller will stop processing the data, unless there are compelling legitimate grounds, or for the exercise or defence of possible claims.

In accordance with current legislation, the user may exercise their rights with the data controller at:

Right of access

As a user, you may ask the data controller to confirm whether your personal data is being processed by them.

Furthermore, the user may request from STERLING REAL ESTATE, SL information about the purpose of the processing of your personal data, how long your data will be retained, what rights you have as a user, whether your data has been transferred to a third country or an international organisation, the existence of automated decision-making, whether profiling is carried out on the website, among other things.

Right of Rectification

If the personal data you have provided to STERLING REAL ESTATE, SL is inaccurate or incomplete, you have the right to rectify or complete it with the data controller.

Right to restriction of processing

The user may request the restriction of the processing of their personal data when:

They dispute the accuracy of their personal data, for a period that allows us to verify its accuracy.
If the processing is unlawful and you object to the erasure of your personal data and, instead of erasing it, request that its use be restricted.
If we no longer need your data for the purposes of processing, but you need it to establish, exercise or defend legal claims.

Right to erasure

You can ask the data controller to delete your personal data immediately, and they are obliged to do so when the data is no longer necessary for the purposes for which it was collected. Furthermore, you may request the erasure of your data when you change your mind about consent, object and there are no overriding legitimate grounds for the processing, your data is being processed unlawfully, it must be erased to comply with a legal obligation, or your data was obtained in relation to a legal claim.

Right to information

If you have exercised your right to rectification, erasure or restriction of processing against the controller, they are obliged to inform all recipients to whom your personal data have been disclosed of this rectification, erasure or restriction of processing, unless this proves impossible or involves a disproportionate effort.

As a user, you have the right to be informed by the controller about who these recipients are.

Guarantees of digital rights

The user's right to internet neutrality, allowing them to access the internet regardless of their personal, social, economic or geographical circumstances. The user is guaranteed universal, affordable, high-quality and non-discriminatory access.

Right to data portability

You have the right to receive the personal data you have provided to the company in a structured, commonly used and machine-readable format. You also have the right to transmit that data to another controller without the controller preventing you.

Right to object

As a user, you have the right to object at any time, on grounds of your particular situation, to the processing of personal data provided to STERLING REAL ESTATE, SL.

The controller will stop processing your personal data unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or where the processing is for the purpose of establishing, exercising or defending legal claims.

Right to withdraw your data protection consent statement

As a user, you have the right to change your data protection consent statement at any time. This change of mind regarding your consent will not affect the lawfulness of processing that took place in accordance with the consent you provided before it was withdrawn.

Automated individual decisions, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on the user or similarly significantly affects them.

Right to lodge a complaint with the supervisory authority

In the event of any breach of your rights, particularly if you have not been satisfied with the exercise of those rights, you may lodge a complaint with the Andorran Data Protection Agency (APDA).

How to exercise my rights?

Likewise, the user may exercise their rights by means of a written communication addressed specifically to the person in charge and request the form for exercising the right in question. To submit this form, the following information must be provided:

First name and surname of the user and passport number (or other identification document). In cases where representations are supported, the person representing the user must also be identified by the same means, as well as documentary proof of the representation.
Reasons specific to the request or the information to be accessed.
Address for notification purposes.
Date and signature of the applicant.
Any document proving the request

This request and all other attached files may be sent to the following address and/or email address: Avenue François Mitterrand, 27, Lower Ground Floor – AD200 Encamp (Encamp). Email: info@sterlingandorra.com

Alternatively, you may contact the competent Supervisory Authority, in this case the Andorran Data Protection Agency (APDA), for further information about your rights.

Can I withdraw my consent?

Consent given for a specific purpose may be withdrawn at any time, without affecting the lawfulness of processing based on consent before its withdrawal. In such cases, STERLING REAL ESTATE, SL will stop processing the personal data or, where applicable, stop doing so for that specific purpose, except for compelling legitimate grounds, or the exercise or defence of possible claims.
How are data updated?

All information provided by the user via registration or by filling in the forms on this website must be accurate. Likewise, it shall be the user's responsibility to keep all information provided to STERLING REAL ESTATE, SL permanently updated so that it always corresponds to the user's actual situation.

What is our confidentiality?

STERLING REAL ESTATE, SL guarantees the confidentiality and security of your personal data when it is processed, insofar as it has implemented the processing policies and security measures referred to in privacy regulations. The processing policies and security measures implemented by STERLING REAL ESTATE, SL prevent the alteration, loss, processing or unauthorised use of your personal data.

What security measures do we have?

As part of our commitment to ensuring the security and confidentiality of personal data, we inform you that the necessary technical and organisational measures have been adopted to ensure the security of personal data and prevent its alteration, loss, processing or unauthorised access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed.