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Privacy Policy

How Lunvera Realty collects, uses, and protects your personal data — in line with the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), as amended by the CPRA.

Last updated: 1 October 2026

1. Scope of this policy

This Privacy Policy explains how Lunvera Realty ("we", "us", "our") collects, uses, discloses, and protects the personal data of visitors, prospective clients, and clients of the lunverarealty.com website and our advisory services. It applies to all personal data processed in connection with our activities on the Costa del Sol, Spain. It is designed to meet our obligations under the EU General Data Protection Regulation (Regulation 2016/679, "GDPR"), the Spanish Organic Law 3/2018 on Data Protection (LOPDGDD), and — for residents of the United States — the California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq., "CCPA") as amended by the California Privacy Rights Act (CPRA).

2. Data controller

Lunvera Realty is the data controller responsible for the personal data you share with us through this website. You can contact us at the details shown at the end of this policy. Where we help you complete a property transaction, we act as a data controller for the personal data we process to provide our advisory service; other parties involved (banks, notaries, lawyers) are independent controllers for the data they process.

3. Personal data we collect

We collect only the personal data we need to provide our services and to respond to you: your name, email address, phone number, country of residence, and the details you choose to share in messages, viewing requests, or the contact form (such as your budget range, areas of interest, and property requirements). If you book a viewing through Luna, our AI concierge, we also collect the viewing details you provide. If you create an advisor account, we collect your email address and an authentication password. We do not collect special categories of personal data, and we ask that you not send us any.

4. How we collect it

Most of the personal data we hold you give us directly — through the contact form, the Luna chat, a viewing request, or when you sign up or sign in. We also receive limited technical data automatically when you visit the site: your IP address, browser type, device, and broad location (country/region), which your browser sends to every website you visit. We may also receive data from our service providers, such as the platform that hosts our website and delivers our email.

5. Why we use it

We use your personal data to: respond to your enquiries and provide the information you ask for; arrange and confirm property viewings; provide our property advisory and introduction services; keep a record of our correspondence and the properties we have shown you; send you information about properties or the market only where you have asked us to; operate and secure our website; and meet our legal, tax, and regulatory obligations as a Spanish real estate intermediary.

6. Lawful basis (GDPR)

Under the GDPR, we rely on the following lawful bases: (a) your consent, when you ask us to contact you or send you property information — you may withdraw this at any time; (b) the performance of a contract or steps taken at your request before a contract, when we arrange viewings and advise you on a purchase; (c) our legitimate interests as a business in responding to your enquiry and showing you suitable properties; and (d) compliance with our legal obligations under Spanish law, including anti-money-laundering and record-keeping requirements.

7. How long we keep it

We keep your personal data only for as long as we need it for the purposes set out above. Enquiry and viewing data is retained while your matter is active and for a reasonable period afterwards (typically up to the end of the relationship plus the statutory limitation period under Spanish law, where applicable). Account data is retained for the life of your account. You may ask us to delete your data earlier, subject to our legal record-keeping obligations.

8. Who we share it with

We share your personal data only with parties who help us operate or who need it to progress your enquiry: our website and email hosting providers; the third-party AI provider that powers Luna's responses; trusted partners — such as lawyers, banks, and notaries — only where you ask us to introduce you and only to the extent needed for that introduction; and public authorities where required by law. We never sell your personal data.

9. International transfers

Your personal data is primarily processed in Spain and the European Economic Area. Some of our service providers (for example, our website hosting and the AI service behind Luna) may process data in the United States or other countries outside the EEA.

Where that happens, we rely on the European Commission's adequacy decision for the country, the EU–US Data Privacy Framework (where the provider is certified), or standard contractual clauses and additional safeguards to ensure your data is protected to EU standards. You may request a copy of the relevant safeguards by contacting us.

10. Your rights — EU/EEA/UK residents (GDPR)

You have the right to access the personal data we hold about you, correct it if it is inaccurate, and ask us to delete it in certain circumstances. You may also restrict or object to our processing, receive a copy of your data in a portable format, and — where we rely on consent — withdraw it at any time without affecting the lawfulness of processing already carried out.

To exercise any of these rights, contact us using the details at the end of this policy. If you are not satisfied with our response, you have the right to lodge a complaint with the Spanish data protection authority (Agencia Española de Protección de Datos, aepd.es) or the supervisory authority of your habitual residence.

10. Your rights — California / US residents (CCPA/CPRA)

If you are a California resident, the CCPA gives you the right to know what personal information we collect about you, the categories of sources, the business purpose for collecting it, and the categories of third parties with whom we share it; to request deletion of your personal information; and to opt out of the "sale" or "sharing" of your personal information. We do not sell personal information, and we do not share it for cross-context behavioural advertising.

You also have the right not to be discriminated against for exercising these rights, and — if we maintain your personal information in a way that creates a risk of identity theft — to limit the use of your sensitive personal information. Requests can be made by you or an authorised agent and may be submitted by email to the address at the end of this policy; we will verify your identity before responding.

To the extent the CCPA requires a "notice at collection," this policy serves as that notice. These rights apply to California consumers as defined by the CCPA; residents of other US states may also have rights under their state's privacy laws, which we honour where applicable.

11. Children's privacy

Our website and services are not directed at children, and we do not knowingly collect personal data from anyone under 16. If you believe a child has provided us with personal data, please contact us and we will delete it.

12. Security

We take reasonable technical and organisational measures to protect your personal data — including encrypted connections (HTTPS), access controls, and limiting the personal data we collect to what we need. No method of transmission or storage is completely secure, so we cannot guarantee absolute security, but we work to keep the risk as low as is practicable.

13. Cookies and similar technologies

We use a small number of cookies to remember your language and theme preference and to understand, in aggregate, how visitors use the site. We do not use cookies for cross-site advertising. Your browser settings let you block or delete cookies; see our Cookie Policy for details.

14. Changes to this policy

We may update this Privacy Policy as our services or the law changes. We will post any new version on this page and update the "last updated" date. Where a change materially affects how we use your data, we will notify you by prominent notice on the site or by email where we hold your address.

15. Contact us

If you have any questions about this Privacy Policy or your personal data, or wish to exercise any of your rights, please contact Lunvera Realty by email at info@lunvera.online or by post at C. Pio Baroja 5, 29692 Manilva, Spain. We aim to respond within one working day.