Privacy & Data Protection Policy

1. Data Controller

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

2. Purpose of this Policy

The purpose of this Privacy and Data Protection Policy is to clearly explain how TEMRA collects, uses, stores, and safeguards personal data provided by users through this website.

Personal data will be processed in strict accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR), Spanish Organic Law 3/2018 on the Protection of Personal Data and guarantee of digital rights (LOPDGDD), and other applicable European and Spanish privacy legislation.

3. Personal Data We Collect

Depending on how you interact with our website, communication channels, and enquiry portals, we may collect the following categories of personal data:

• First name and surname.
• Email address.
• Telephone or WhatsApp contact number.
• Country or place of residence.
• Information regarding your division of interest (Real Estate & Communities, Commodities & Resources, Health & Longevity, Finance & Investment).
• Any information voluntarily included in the message, enquiry, or documentation submitted through the contact form.

We only request the information strictly necessary for the purposes described in this policy. Providing your name and email address is necessary for us to respond to your enquiry; without this information we will not be able to process your request. Providing other information requested in the contact form is optional.

4. How We Collect Your Data

Personal data may be collected when you:

• Complete and submit an enquiry or contact form on our website;
• Contact our corporate teams directly by email, telephone, or digital messaging;
• Otherwise voluntarily provide personal information through our digital channels.

5. Purposes of Processing

Personal data submitted through the website may be processed for the following purposes:

• To respond promptly to enquiries, requests for commercial details, and corporate information;
• To contact you regarding your specific request;
• To provide accurate details regarding our developments, luxury properties, commodities procurement pipelines, or investment strategies where directly related to your enquiry;
• To manage and follow up on communications initiated by you;
• To comply with applicable fiscal, accounting, and statutory legal obligations;
• To ensure the technical security and optimal functioning of the website.

Personal data will never be utilized for purposes incompatible with those described above without providing relevant prior notice and obtaining the required legal basis or consent.

6. Legal Basis for Processing

Depending on the specific context of the processing, our legal basis rests upon:

6.1. Consent

Where consent is required by applicable law, personal data will be processed on the basis of your freely given consent. Consent may be withdrawn at any time without retroactive impact on prior lawful processing.

6.2. Pre-Contractual Measures

Where necessary, personal data is processed to respond to your request or take preliminary steps at your request prior to entering into a prospective commercial or real estate contract.

6.3. Legal Obligations

Personal data may be processed where necessary to fulfill legal obligations applicable to TEMRA under European Union or Spanish law.

6.4. Legitimate Interests

Where applicable, processing is founded upon TEMRA’s legitimate interests (such as ensuring technical web security and preventing fraudulent misuse), provided such interests do not override your fundamental rights and freedoms.

7. Data Recipients

Personal data submitted through the website is received and processed primarily by TEMRA INTERNATIONAL LTD and Temra Gestion Integral, S.L. TEMRA does not sell, rent, or lease personal data to third parties under any circumstances.

Where third-party service providers process personal data on behalf of TEMRA, this currently includes providers of CRM and contact form management (HubSpot), website analytics (Google Analytics), marketing (Google Ads, Meta, LinkedIn), and embedded third-party content or functionality (Google Maps, YouTube, WhatsApp Business). Appropriate contractual and organisational measures are applied in accordance with applicable data protection legislation.

8. International Data Transfers

Some of TEMRA’s third-party service providers, including HubSpot, may process personal data outside the European Economic Area (EEA). Where this occurs, TEMRA ensures that appropriate safeguards are in place in accordance with the GDPR, such as Standard Contractual Clauses approved by the European Commission. Users may request further information about these safeguards by contacting admin@temra.net.

9. Data Retention

Personal data will be retained only for as long as necessary to fulfil the purposes for which it was collected and, where applicable, for the period required to comply with statutory legal obligations or to establish, exercise, or defend legal claims. As a general rule, personal data submitted through the contact form is retained for up to 12 months from the last interaction with the user, unless a longer period is required to comply with legal, tax or accounting obligations. Once the applicable retention period has expired, personal data will be deleted or irreversibly anonymised in accordance with applicable legislation.

10. Data Subject Rights

Under the GDPR and the Spanish LOPDGDD, you hold the following rights regarding your personal data:

• Right of Access: Obtain confirmation of whether your data is being processed and receive a copy thereof;
• Right to Rectification: Request correction of inaccurate or incomplete personal data;
• Right to Erasure ("Right to be Forgotten"): Request deletion of your data when no longer needed or when consent is revoked;
• Right to Restriction of Processing: Request temporary restriction of data processing in legally specified circumstances;
• Right to Object: Object to processing founded upon legitimate interests or direct communications;
• Right to Data Portability: Receive your data in a structured, commonly used, machine-readable format;
• Right to Withdraw Consent: Revoke granted consent at any time without affecting past lawful processing.

To exercise any of these rights, you may address a written communication specifying your request to:

You also maintain the right to lodge a complaint with the competent supervisory authority: the Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD) via www.aepd.es, or your national supervisory authority within the EU/EEA (EDPB Member Directory).

11. Confidentiality and Security

TEMRA treats all personal data with the highest degree of confidentiality and enforces appropriate technical and organisational security measures (including SSL/TLS cryptographic encryption, firewalls, and restricted administrative credentials) designed to prevent accidental destruction, loss, alteration, or unauthorised disclosure.

12. Data Provided by Third Parties

If you submit personal data concerning any third-party individual, you warrant that you possess the requisite legal mandate to supply such information and that the affected individual has received prior notice of the terms outlined in this policy.

13. Children’s Data

This website is not directed towards minors. TEMRA does not knowingly solicit or collect personal information from individuals under the age of 16 (or under 18 where stipulated by local laws) without verified parental or legal guardian consent.

14. Automated Decision-Making and Profiling

TEMRA does not engage in automated decision-making processes or algorithmic profiling that produce legal or similarly significant effects concerning users.

15. Links to Third-Party Websites

Our website may provide hyperlinks to affiliated or external websites. TEMRA is not responsible for the privacy practices, content, or policies of third-party platforms. We advise visitors to review the privacy notices of external websites upon navigation.

16. Changes to this Privacy Policy

TEMRA reserves the right to amend this Privacy Policy to accommodate legislative revisions, regulatory changes, or updates to digital processing workflows. The latest revised version will always be accessible via this portal.

Last updated: October 2026