Cookie Policy

1. What Are Cookies and Similar Technologies

Cookies are small text files that a website stores on your device when you visit it. They allow the Website to recognise your device on subsequent visits, remember your preferences and analyse how the Website is used. This Policy also covers similar technologies (such as local storage, pixels and SDKs) that perform an equivalent function to cookies.

2. Categories of Cookies We Use

a) Strictly necessary / technical cookies

Essential for the Website to function correctly (for example, remembering your cookie choices, security and protection against automated traffic). Under Article 22(2) LSSICE, these cookies do not require your prior consent, although we inform you of their use for transparency.

b) Analytical / measurement cookies

Used to measure the number of visitors and analyse browsing patterns so that we can improve the Website and our services. These cookies require your prior consent. They include Microsoft Clarity session recordings and heatmaps, which record clicks, scrolling and mouse movements on the pages. Microsoft, which provides this service, may also use Clarity data and the MUID cookie for its own advertising purposes (see Section 4 of the Privacy Policy); by accepting analytical cookies, you also accept this use.

c) Preference / functional cookies

The only preference we store is the light or dark theme you choose with the switch on the Website, and it is stored only when you click that switch. As this is personalisation you expressly request, it does not require your prior consent, in line with the AEPD Cookie Guide.

d) Marketing / behavioural advertising cookies

They allow us to measure the effectiveness of our adverts and to show you SFERO property adverts on other websites and apps (such as Facebook, Instagram or TikTok), based on your browsing on the Website. They require your explicit opt-in consent and are disabled by default. The Meta and TikTok pixels use automatic advanced matching, described in Section 4 of the Privacy Policy.

e) Third-party embedded content

The maps on property pages and on the cities and districts page are displayed using OpenStreetMap map tiles, which are loaded from tile.openstreetmap.org, a service of the OpenStreetMap Foundation delivered through the server network of Fastly, Inc. When the tiles load, your browser sends your IP address and technical browser data to those servers; no cookies are set. No other third-party content, such as virtual tours or videos, is currently embedded on the Website.

3. Cookies Used on This Website

The table below lists the cookies and similar technologies used on the Website. You can accept or reject each category at any time using the “Cookie settings” button (the cookie icon in the bottom left-hand corner of the screen).

4. Legal Basis and Consent

Strictly necessary cookies and similar technologies, and the storage of the theme preference you expressly request (Section 2(c)), are exempt from the consent requirement under Article 22(2) LSSICE; to the extent they involve personal data, the processing is based on our legitimate interest in ensuring the Website functions correctly and securely (Article 6(1)(f) GDPR). Analytical and marketing cookies are used only on the basis of your freely given, specific, informed and unambiguous consent (Article 6(1)(a) GDPR), obtained through the cookie consent banner described in Section 5.

5. Cookie Consent Management

On your first visit to the Website, a cookie consent banner will:

• Inform you which categories of cookies are in use and for what purposes.
• Allow you to accept all cookies, reject all non-essential cookies, or customise your preferences category by category, with equal prominence given to each option.
• Only activate non-essential cookies after you have given your consent.

Your preferences are stored and respected on subsequent visits. You may review or change them at any time using the “Cookie settings” button (the cookie icon in the bottom left-hand corner of the screen). Withdrawing consent is as easy as giving it, and does not affect the lawfulness of processing carried out before withdrawal. In the absence of any action on your part, consent preferences are, in line with AEPD guidance, considered renewable and will be requested again after a maximum of 24 months.

6. How to Control Cookies in Your Browser

In addition to our cookie consent panel, you can control or delete cookies directly through your browser settings:

• Google Chrome: support.google.com/chrome/answer/95647
• Mozilla Firefox: support.mozilla.org – cookies information
• Microsoft Edge: support.microsoft.com/microsoft-edge
• Apple Safari: support.apple.com/guide/safari

Please note that blocking or deleting cookies does not affect the basic functions of the Website (search, filters and maps), except when Cloudflare shows its security check, which needs the cf_clearance cookie. If you block browser storage, your cookie choice, the theme you selected and the WhatsApp button from posters with a QR code may not be remembered.

7. Third-Party Providers and International Transfers

Some necessary, analytical and marketing cookies are provided by third parties (for example, Cloudflare, Google Analytics 4, Microsoft Clarity, Meta and TikTok) which may process data outside the European Economic Area, in particular in the United States. Such transfers rely on the safeguards recognised under Chapter V GDPR, such as the EU-U.S. Data Privacy Framework or European Commission Standard Contractual Clauses, as applicable to each provider. Details of each provider's own privacy practices are available on their respective websites.

8. Retention Periods

Each cookie is retained for the period indicated in the table in Section 3. If you withdraw your consent, the corresponding tools stop loading; you can delete cookies already set through your browser settings (Section 6). Aggregated analytics data may be retained in anonymised form beyond these periods, in which case it no longer constitutes personal data.

9. Your Rights

Where cookies involve the processing of personal data (for example, an analytics identifier associated with your browsing activity), you may exercise your rights of access, rectification, erasure, objection, restriction and portability as described in our Privacy Policy. The specific procedure for requesting deletion of your data is set out in Section 10 below.

10. Procedure for Deletion of Client Data Upon Request

SFERO has implemented the following clear, documented procedure to handle requests for the deletion (“right to erasure”, Article 17 GDPR) of personal data, whether collected through cookies, the Website, or in the context of a brokerage, sale, purchase or lease relationship. This procedure applies equally to clients, property owners, tenants, buyers, sellers and general Website users.

10.1 How to submit a deletion request

• By email to info@sfero.es, with the subject line “Data Deletion Request”, or
• By post to Calle Guillem d'Anglesola, 6, escalera B, piso 2, puerta 6, 46022 Valencia, Spain, for the attention of Data Protection.

The request must identify the data subject, specify the data or relationship concerned, and be accompanied by a copy of a valid identity document (DNI, NIE or passport) so that SFERO can verify the identity of the requester. Requests made on behalf of a third party (for example, by an heir or legal representative) must also include proof of that representation.

10.2 Acknowledgement and identity verification

SFERO will acknowledge receipt of the request within five (5) business days. If the identity of the requester cannot be verified, or the request is incomplete, SFERO will contact the requester to ask for the additional information reasonably necessary, and the response period described below will be suspended until that information is received.

10.3 Assessment of the request

SFERO will assess the request against its data retention obligations, and will proceed in one of the following ways depending on the type of data involved:

• Cookies, analytics and marketing preferences: where no active contractual or legal retention obligation applies, this data will be deleted or anonymised in full, normally within ten (10) business days of verification.
• Contact and enquiry data with no ongoing relationship: deleted in full, save for a minimal record of the request itself, kept only for accountability purposes.
• Contractual, transactional or anti-money-laundering data: where SFERO is subject to a legal retention obligation (for example, under Law 10/2010 on the prevention of money laundering, the Commercial Code, or tax legislation), full erasure is not legally possible while that obligation subsists. In these cases, and in accordance with Article 32 LOPDGDD, SFERO will block (“bloqueo”) the data: it will be retained in a restricted, access-controlled manner, made available only to competent judges, courts, and public authorities for the purpose of addressing potential liabilities arising from the processing, for the applicable statutory period, and will not otherwise be used for any operational purpose.

Applicable statutory retention periods that may justify blocking rather than immediate erasure include, depending on the nature of the data: up to ten (10) years for documentation subject to anti-money-laundering obligations (Law 10/2010); six (6) years for accounting and commercial records (Article 30, Commercial Code); and the general five (5) year limitation period for civil actions (Article 1964 Civil Code), or the specific period applicable to the type of legal claim concerned.

10.4 Response and confirmation

SFERO will respond to the request within one (1) month of receipt (or of identity verification, if later). Where the request is complex or numerous requests have been received, this period may be extended by a further two (2) months; SFERO will inform the requester of any such extension, and the reasons for it, within the first month. The response will confirm, in clear terms:

• which data has been deleted or anonymised in full;
• which data has instead been blocked, the legal basis for that retention, and the date on which it is scheduled to be permanently destroyed;
• where the request is refused in whole or in part, the reasons for the refusal and the right to lodge a complaint with the AEPD.

10.5 Notification to third parties

Where the data subject's personal data has been shared with data processors or other recipients (Section 4 of the Privacy Policy), SFERO will notify those recipients of the erasure or blocking, so that they can act accordingly, unless this proves impossible or involves disproportionate effort.

10.6 Destruction of blocked data

Once the applicable statutory retention period has elapsed, blocked data will be securely and permanently destroyed by SFERO as part of its routine data lifecycle management, without further action being required from the data subject.

10.7 Cost and manifestly unfounded or excessive requests

Deletion requests are processed free of charge. Where a request is manifestly unfounded or excessive, in particular because of its repetitive character, SFERO may charge a reasonable administrative fee taking into account the costs involved, or may refuse to act on the request; in either case, SFERO will explain its reasoning to the requester.

10.8 Right to lodge a complaint

If you are not satisfied with SFERO's handling of your deletion request, you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) – www.aepd.es – Calle Jorge Juan 6, 28001 Madrid. We would, however, appreciate the opportunity to resolve any concerns directly beforehand.

11. Modifications

SFERO may amend this Cookie Policy at any time to reflect changes in the cookies used, applicable law, or AEPD guidance. The version published on the Website at the time of each visit shall apply.

12. Applicable Law and Jurisdiction

This Cookie Policy is governed by Spanish law. Any dispute arising from its interpretation or application shall be submitted, with an express waiver of any other jurisdiction, to the Courts of Valencia, unless mandatory applicable law establishes a different competent forum, in particular for consumer disputes.