The controller responsible for the processing of personal data collected through this website is:

FGM [full legal name]
Tax Identification Number: [CIF/NIF]
Registered address: [full address]
Email: [general email address]
Privacy contact: [privacy email address]
Telephone: [telephone number]

Where legal services are provided personally by a registered lawyer, the relevant engagement documentation will identify the lawyer or legal entity acting as the data controller for that specific matter.

FGM is committed to protecting the privacy, confidentiality and personal information of its clients, prospective clients, website users and professional contacts.

Personal data is processed in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), Spanish Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights, and other applicable Spanish and European legislation.

Given the nature of our legal, Asset Management and Property Management services, we apply particular care to the confidentiality, security and appropriate use of information entrusted to us.

Depending on your relationship with FGM, we may collect and process:

• Identification information, including your name, identification document and nationality
• Contact information, including your address, email address and telephone number
• Professional, corporate and employment information
• Property ownership and real estate information
• Financial, banking and transaction-related information
• Tax residency and taxation-related information
• Information required for customer identification, due diligence, AML and compliance procedures
• Information contained in contracts, deeds, powers of attorney and legal documentation
• Information concerning tenants, owners, investors, representatives and counterparties
• Communications sent through our website, email, telephone or other channels
• Technical information relating to website use, including IP address, device and browser information
• Any other information necessary for providing the requested legal, Asset Management or Property Management services

Where necessary for legal representation or the establishment, exercise or defence of legal claims, we may also process special categories of personal data in accordance with applicable law.

FGM may process personal data for the following purposes:

• Responding to enquiries and requests submitted through the website
• Assessing whether we can provide the requested services
• Preparing proposals, engagement letters and service agreements
• Providing legal advice and legal representation
• Managing real estate acquisitions, disposals and ownership structures
• Providing Asset Management and Property Management services
• Preparing, reviewing and maintaining legal and contractual documentation
• Conducting legal, financial, tax, compliance and property-related due diligence
• Completing client identification, conflict-of-interest and AML/KYC checks
• Communicating with clients, tenants, property owners, investors and professional advisers
• Coordinating with courts, notaries, registries, public authorities and other parties
• Managing payments, invoicing, accounting and taxation
• Protecting our legal rights and responding to complaints or claims
• Maintaining the security and functionality of our website and information systems
• Sending professional updates or marketing communications where legally permitted

We will not use personal data for purposes incompatible with those described above.

Depending on the circumstances, personal data is processed on one or more of the following legal bases:

Processing may be necessary to provide services requested by a client or to take steps before entering into a legal or service relationship.

FGM may process personal data to comply with legal, regulatory, tax, accounting, professional, anti-money laundering and court-related obligations.

Processing may be necessary for legitimate interests such as:

• Managing and developing professional relationships
• Responding to enquiries
• Protecting our clients’ and FGM’s legal interests
• Preventing fraud and misuse
• Maintaining network and information security
• Managing administrative and operational matters

Legitimate interests are assessed against the rights and freedoms of the individuals concerned.

Where required, we may request consent for specific processing activities, including certain marketing communications or the use of non-essential cookies.

Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

Where special categories of personal data are involved, processing may be necessary for the establishment, exercise or defence of legal claims or for the provision of legal representation.

Information received in connection with legal services may be protected by professional secrecy and legal professional confidentiality.

FGM applies confidentiality obligations to its lawyers, employees, consultants, contractors and service providers in accordance with applicable law and professional standards.

Personal information will only be accessed by persons who require it for a legitimate professional or operational purpose.

Where necessary for the provision of services or compliance with legal obligations, personal data may be disclosed to:

• Courts, tribunals and judicial authorities
• Notaries and property, commercial or civil registries
• Tax authorities and other public bodies
• Banks, financial institutions and payment providers
• Accountants, auditors and tax advisers
• Lawyers, procuradores and other professional advisers
• Architects, engineers, surveyors and technical consultants
• Property agents, property managers and authorised service providers
• Insurance companies
• Contractors, maintenance providers and suppliers
• Compliance and identity-verification providers
• IT, hosting, cloud, cybersecurity and communications providers
• Other parties involved in a transaction, legal matter or property-management assignment

Personal data will only be disclosed where there is a valid legal basis and where the disclosure is necessary and proportionate.

Service providers acting on our behalf are required to process personal data under appropriate contractual, confidentiality and security obligations.

As FGM serves international clients and may work with service providers located outside Spain, personal data may in certain circumstances be transferred outside the European Economic Area.

Where such transfers occur, FGM will apply an appropriate legal transfer mechanism, such as:

• A European Commission adequacy decision
• European Commission Standard Contractual Clauses
• Another safeguard recognised under applicable data protection legislation

International transfers are governed by Chapter V of the GDPR. 

Personal data will be retained only for as long as necessary for the purposes for which it was collected.

Retention periods may depend on:

• The duration of the client or contractual relationship
• The nature of the legal or property-related assignment
• Applicable limitation periods
• Tax and accounting obligations
• Anti-money laundering requirements
• Professional record-keeping obligations
• The establishment, exercise or defence of legal claims

Enquiries that do not lead to a professional relationship will be retained only for a reasonable period unless longer retention is required for conflict checks, legal protection or compliance purposes.

Marketing information will be retained until consent is withdrawn or the individual objects to receiving communications.

After the applicable retention period, personal data will be securely deleted, anonymised or restricted from further use.

FGM applies appropriate technical and organisational measures designed to protect personal data against:

• Unauthorised access
• Unlawful disclosure
• Accidental loss
• Alteration
• Destruction
• Misuse

Measures may include access controls, secure communications, confidentiality procedures, system monitoring, backups and appropriate arrangements with external service providers.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

Subject to the requirements and limitations of applicable law, you may exercise the following rights:

• Right of access: to obtain information about whether and how your personal data is processed
• Right to rectification: to correct inaccurate or incomplete personal data
• Right to erasure: to request deletion of personal data where there is no lawful reason to retain it
• Right to restriction: to request limitations on the processing of personal data
• Right to object: to object to processing based on legitimate interests or direct marketing
• Right to data portability: to receive certain personal data in a structured, commonly used and machine-readable format
• Right to withdraw consent: where processing is based on consent
• Right not to be subject to certain automated decisions: where applicable

These rights are recognised under Chapter III of the GDPR. 

Requests may be submitted to:

[privacy email address]

or by post to:

FGM [full legal name]
[full postal address]

The request should clearly identify the right being exercised. FGM may request reasonable proof of identity where necessary to prevent unauthorised access to personal data.

Individuals who believe that their personal data has been processed unlawfully may contact FGM directly so that the matter can be investigated.

They also have the right to lodge a complaint with the competent supervisory authority:

Agencia Española de Protección de Datos — AEPD

FGM does not ordinarily make decisions producing legal or similarly significant effects solely through automated processing.

Should this change, the affected individual will receive the information and protections required under applicable data protection law.

This website may contain links to third-party websites.

FGM is not responsible for the privacy practices, security or content of external websites. Users should review the privacy policies of those websites before submitting personal information.

This website may use technical cookies and, subject to the user’s preferences, analytical or other non-essential cookies.

Detailed information about cookies, their purposes, duration and the available consent controls is provided in our separate Cookie Policy.

Spanish rules concerning non-essential cookies require appropriate information and consent arrangements under the GDPR and Article 22.2 of the Spanish Information Society Services Act. 

FGM may update this Privacy Policy to reflect changes in its services, data-processing activities or applicable legislation.

The current version will always be published on this website.