1. Who Is Responsible for Your Personal Data
The data controller for personal data collected through this website, forms, private pages, bookings, emails and operational processes associated with Digital Landing is TOMÁS OMAR RAMÍREZ MEJÍA.
Digital Landing processes personal data prudently, on a limited basis and in proportion to the service requested.
2. Processing Principles
Digital Landing applies the following principles:
- data minimisation;
- clearly defined purposes;
- restricted access;
- limited retention;
- transparency;
- no invasive analytics;
- no marketing pixels;
- no sale of personal data;
- responsible handling of documents.
We do not request documents “just in case”. Only the personal data or documents expressly requested at each stage of the process should be uploaded.
3. Personal Data We May Process
Depending on how you use the website or service, we may process the following personal data:
Contact and Enquiry Data
- name;
- email address;
- telephone number;
- country of origin;
- message submitted;
- date and time of contact;
- information necessary to respond to your enquiry.
Booking Data
- name;
- email address;
- selected time slot;
- information entered when making the booking;
- communications relating to the appointment.
Data Relating to Prospective or Contracting Residents
- full name;
- email address;
- telephone number;
- country of origin;
- estimated arrival date;
- intended length of stay;
- budget;
- university, school, programme or reason for the stay;
- basic cohabitation information;
- documents requested at later stages;
- electronic acceptance of Digital Landing documents.
Verified Resident Data
- identification data;
- contact details;
- operational profile information;
- acceptance of the Commitment to Cohabitation and Good Practice;
- documents necessary to provide the service;
- relevant communications;
- proportionate records of incidents, where any arise.
Data Relating to Persons Responsible for Accommodation
- full name;
- email address;
- telephone or WhatsApp number;
- approximate location or address, where necessary;
- room details;
- price, additional costs, availability and terms;
- basic cohabitation rules;
- stated availability of municipal registration (empadronamiento);
- images and videos of the room or accommodation;
- additional documents requested at later stages.
Financial Sponsor Data
Where applicable, we may process only the minimum personal data necessary about a person who provides financial support for the resident, provided that person has been informed and participates voluntarily in the process.
Image and Video Data
We may process images and videos of rooms or common areas for operational review, internal records, private presentation to persons with compatible profiles and, only where specific authorisation has been given, for commercial use or publication.
Images or videos must not be uploaded if they include people, visible documents, family photographs, vehicle registration plates, screens, keys, codes, exact addresses or identifiable private belongings that are unnecessary.
4. Purposes of Processing
We process personal data to:
- respond to requests for information;
- manage bookings for conversations;
- prepare for calls or meetings;
- assess initial compatibility between a resident and an accommodation option;
- provide contracted services;
- record operational information about rooms;
- prepare operational profiles of residents or accommodation options;
- manage uploads of images and videos;
- retain accepted or signed documents;
- facilitate initial follow-up where included in the service;
- manage relevant incidents on a proportionate basis;
- maintain the minimum records necessary to trace the process;
- comply with legal obligations;
- address potential claims.
5. Lawful Basis for Processing
Depending on the circumstances, processing may be based on:
- steps taken at the user's request before entering into a contract;
- performance of a contract or a contracted service;
- the user's consent;
- Digital Landing's legitimate interests in managing, documenting and safeguarding the process;
- compliance with legal obligations;
- the establishment, exercise or defence of legal claims.
Where consent is requested, it must be given through a clear, specific and informed affirmative action. Checkboxes will not be pre-ticked.
6. Higher-Risk Data and Documents
Some documents may present a higher level of risk, including identity documents, passports, NIE/TIE documentation, proof of financial means, accommodation contracts, proof of address, academic records or signed documents.
Digital Landing will avoid requesting sensitive documents unless they are necessary for the specific stage of the process.
Health data, intimate information, third-party data, documents that have not been requested or excessive information must not be uploaded.
7. Google Calendar, Google Workspace, Google Drive and Google Apps Script
Digital Landing may use Google tools to manage bookings, scheduling, operational forms, document storage, internal organisation and communications.
This may include Google Calendar, Google Workspace, Google Drive, Google Sheets, Gmail and Google Apps Script.
Digital Landing determines the purposes and means of processing the personal data it manages within these systems. Google acts as a technology provider in accordance with its own applicable terms, policies and agreements.
Personal data stored in Google Drive or equivalent tools will be organised with restricted access and in accordance with data-minimisation principles.
8. Room Images and Videos
Images and videos provided by persons responsible for accommodation will be used solely for the purposes communicated and authorised.
Uploading images or videos for internal review does not automatically authorise their public dissemination on the website, social media or in commercial materials.
Specific authorisation will be requested for any commercial, public-facing or promotional use.
The person uploading images or videos represents that they have sufficient permission to share them and have taken reasonable steps to exclude personal data, people, visible documents, exact addresses, private belongings or unnecessary sensitive information.
9. Electronic Signatures and Acceptance of Documents
When a resident electronically accepts or signs documents such as the Commitment to Cohabitation and Good Practice, Digital Landing will retain a copy for its internal records, as evidence that the document was read and accepted, and to maintain a record of the process.
The resident may receive a copy of the accepted or signed document by email or secure link.
Acceptance of these documents does not replace any lease or rental agreement, financial arrangement or other legal document, and does not constitute professional advice.
10. Data Retention
Personal data will be retained only for as long as necessary for the relevant purpose.
The initial retention criteria are as follows:
- enquiries that do not lead to a service purchase: up to 12 months after the last contact;
- appointments that do not lead to a service purchase: up to 12 months;
- rooms not approved: 6–12 months, except where limited retention is justified;
- higher-risk documents relating to persons who are not accepted: deletion or review within a shorter period;
- residents who purchase a service or are verified: for the duration of the relationship and for a reasonable period thereafter where necessary to evidence the provision of the service or address claims;
- signed documents: for the duration of the relationship and for as long thereafter as necessary to maintain records or defend legal claims;
- images and videos of rooms withdrawn from availability: periodic review and deletion when no longer necessary;
- incident records: only what is necessary and subject to restricted access.
These periods may be adjusted to reflect legal or contractual obligations or claims.
11. Recipients
Digital Landing does not sell personal data.
Personal data may be accessed by:
- necessary technology service providers;
- Google Workspace and associated tools;
- the hosting provider;
- the email service provider;
- legal, tax or administrative advisers where necessary;
- competent authorities where disclosure is required by law.
Personal data will not be disclosed to third parties for marketing purposes.
12. Your Data Protection Rights
Where applicable, you may exercise your rights of access, rectification, erasure, objection, restriction of processing, data portability and withdrawal of consent.
To exercise any of these rights, email:
atencionaclientes@dlanding.com
The request must contain sufficient information to allow the person making it to be reasonably identified.
You may also lodge a complaint with the Spanish Agency for Data Protection (Agencia Española de Protección de Datos, AEPD) if you believe that the processing of your personal data does not comply with applicable law.
13. Security
Digital Landing will implement reasonable security measures, including restricted access, minimum necessary permissions, organisation of documents into folders, permission reviews, deletion of unnecessary documents and prudent use of technology tools.
However, no system is entirely infallible. In the event of a material security incident, Digital Landing will act in accordance with applicable law.
14. Changes to This Policy
Digital Landing may update this Privacy Policy to reflect legal, technical or operational changes.
Where changes are material, Digital Landing will take reasonable steps to provide appropriate notice.
You may contact Digital Landing using the email address specified in the Legal Notice and this Privacy Policy.