Who is responsible for your data
Hanami Group Investments S.L. (trading as OTS & Partners)
CIF: B-67815688
Calle Nicaragua 95, Bloque 11, Bajo A, 29680 Estepona (Málaga), Spain
Email: info@ots-partners.com
What data we collect and why
We only collect the data you give us or that is needed to run the website:
| When | Data | Purpose | Legal basis |
|---|---|---|---|
| Contact form or email | Name, email, phone, your message | To answer your enquiry | Pre-contractual steps at your request (art. 6.1.b GDPR) |
| Property enquiry or viewing request | Name, email, phone, property of interest, message | To arrange viewings and send you information about the property | Pre-contractual steps at your request (art. 6.1.b) |
| Free valuation request | Name, email, phone, property address and details | To prepare and send you a valuation of your property | Pre-contractual steps at your request (art. 6.1.b) |
| Newsletter or market updates | Name, email | To send you market information and selected properties | Your consent (art. 6.1.a), which you can withdraw at any time |
| Browsing the website | IP address, device and browser data, pages visited | Security, performance and, with your consent, audience statistics | Legitimate interest (art. 6.1.f) for security; consent (art. 6.1.a) for analytics cookies |
We do not make automated decisions or profiling that produce legal effects on you. We do not ask for special categories of data.
Who we share your data with
We do not sell your data. We share it only when necessary to provide the service:
- Property owners and collaborating agencies, when you enquire about a listing and a viewing or offer needs to be arranged.
- Service providers that host our website, store our data and deliver our emails. They act on our instructions under data processing agreements: Vercel (hosting), Supabase (database and file storage), Resend (transactional email) and Google (analytics, subject to your cookie consent).
- Public authorities, when required by law (for example anti-money laundering obligations in a property transaction).
Some of these providers are established in the United States. Where data is transferred outside the European Economic Area, we rely on the EU–US Data Privacy Framework or on the European Commission's Standard Contractual Clauses.
How long we keep your data
- Enquiries and valuation requests: while we handle your request and for up to 2 years afterwards, unless a business relationship follows.
- Client and transaction records: for the period required by tax, commercial and anti-money laundering law (generally 5 to 10 years).
- Newsletter subscriptions: until you unsubscribe.
- Analytics data: as described in our cookie policy.
Your rights
You can at any time:
- Access the data we hold about you.
- Ask us to correct inaccurate data or complete incomplete data.
- Ask us to delete your data when it is no longer needed.
- Object to processing based on legitimate interest, or restrict it.
- Receive your data in a portable format.
- Withdraw consent you have given, without affecting prior processing.
To exercise these rights, write to info@ots-partners.com or to our postal address, stating which right you want to exercise. We may ask you to confirm your identity. We will reply within one month.
If you believe your rights have not been respected, you can lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, www.aepd.es).
Security
We apply technical and organisational measures appropriate to the risk: encrypted connections (HTTPS), access control to our systems, and providers that meet recognised security standards. No system is completely secure, but we work to protect your data against unauthorised access, loss or alteration.
Changes to this policy
We may update this policy to reflect changes in the law or in how we work. The date at the top shows the latest version. Significant changes will be highlighted on this page.