Privacy policy

1. Data controller

SMILO REAL ESTATE SL (trading name: Smilo Prime), CIF B76775352, with its address at Calle La Enramada, 17, C.C. San Sebastián, Local 214, 38679 La Caleta, Adeje, Santa Cruz de Tenerife. Email: manager@smiloproperties.com. Telephone: +34 661 357 611.

2. What data we process

Only the data you provide to us: your name, email address, telephone number and the information you enter in the contact form or in your conversation with the virtual assistant (for example, your search preferences or details of the property you wish to sell). We do not request identity documents, bank details or health data, and we ask you not to include them in your messages.

3. Purposes and legal bases

• Responding to your enquiries received via the form, email, telephone or WhatsApp. Legal basis: your consent and taking steps at your request prior to entering into a contract (Art. 6.1.a and 6.1.b GDPR).
• Virtual assistant: an artificial intelligence system answers your questions and creates a commercial profile (budget, areas, timeframe, purpose) so that the team can assist you better. No automated decisions are made that produce legal effects or significantly affect you; all decisions are made by a person. You can ask to speak to a person at any time. Legal basis: consent and steps prior to entering into a contract.
• Managing viewings and valuations that you request. Legal basis: steps prior to entering into a contract (Art. 6.1.b GDPR).
• Marketing communications about new properties, only if you have expressly authorised them by ticking the relevant box (Art. 6.1.a GDPR and Art. 21 LSSI-CE).

4. Retention period

We retain your data for 24 months from the last contact, unless you request its erasure or withdraw your consent before then. After that period, it is automatically erased. Where there is a contractual relationship, the data will be retained in a blocked state for the statutory limitation periods.

5. Recipients and data processors

We do not disclose your data to third parties unless legally required to do so. To provide the service, we use providers acting as data processors under contract:

• Lovable (Lovable Cloud): website and database hosting.
• The virtual assistant's artificial intelligence provider (OpenAI models via the Lovable AI gateway), which processes the content of the conversation to generate responses.
• Meta Platforms (Instagram, Facebook and WhatsApp), only when you contact us via WhatsApp or when we publish property advertisements on our social media.

6. International transfers

Some of these providers may process data outside the European Economic Area, particularly in the United States. In such cases, transfers are covered by the EU-US Data Privacy Framework for certified entities and/or the Standard Contractual Clauses approved by the European Commission, together with any appropriate supplementary measures.

7. Your rights

You may exercise your rights of access, rectification, erasure, objection, restriction of processing and portability, as well as withdraw your consent at any time, without affecting the lawfulness of prior processing. To do so, write to manager@smiloproperties.com or by post to Calle La Enramada, 17, C.C. San Sebastián, Local 214, 38679 La Caleta, Adeje, Santa Cruz de Tenerife, specifying the right you wish to exercise.

If you consider that we have not handled your request properly, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

8. Security

We apply appropriate technical and organisational measures to protect your data against unauthorised access, loss or alteration.