Privacy Policy

Last updated: October 2026

Commitment to your privacy: In compliance with the European General Data Protection Regulation (GDPR EU 2016/679) and Spanish Organic Law 3/2018 (LOPDGDD), we guarantee that your personal data will never be sold, rented, or commercialised to third parties. Your information is used exclusively to respond to your inquiries, for commercial communication related to the properties, products, and services of IMPAR CAPITAL or IMPAR PROPERTIES, and, should you explicitly grant consent, for web analytics and advertising campaign optimisation.

1. Data Controller

The entity responsible for processing personal data collected through this website is:

Entity: IMPAR CAPITAL ASSET MANAGEMENT, SGEIC, S.A. / IMPAR PROPERTIES
Tax ID (CIF): A-88484192
Registered Address: Calle de Serrano, 45, Floor 1, 28001 Madrid, Spain
Contact / Privacy Email: [email protected] / [email protected]
Corporate Website: www.imparcapital.com

2. Data Collected and Purpose of Processing

Depending on how you interact with our website and the consents you provide, we process the following categories of data:

Direct Contact and Identification Data (collected through contact forms or WhatsApp): Full name, email address, and telephone number.
Browsing and Telemetry Data (collected via cookies and similar technologies solely if you accept them): Pseudonymised IP address, cookie-generated client/device identifiers, session data, pages visited, traffic source, and user interaction patterns.

Legitimate Purposes:

To manage, process, and answer your inquiries regarding the Palacio Residencial Sagasta luxury development.
To arrange private visits, personalized appointments, and property presentations.
To maintain direct commercial contact and provide tailored information regarding high-end real estate projects and services offered by IMPAR CAPITAL or IMPAR PROPERTIES.
Web analytics and performance: To evaluate website usage, traffic patterns, and user experience in an aggregated manner using Google Analytics 4 (only with prior consent).
Advertising measurement and optimisation: To measure the effectiveness of our campaigns on Google Ads and Meta Ads (Facebook & Instagram), and to display relevant property information (only with prior consent).

3. Legal Basis for Processing

The legal basis legitimising each processing activity is:

Contact data (form and WhatsApp): Your explicit and unambiguous consent given when ticking the consent box prior to submitting the inquiry form or when voluntarily initiating contact via WhatsApp (Article 6.1.a GDPR).
Analytics and advertising cookies: Your express consent granted through the cookie banner upon your first visit or at any subsequent time (Article 6.1.a GDPR and Article 22.2 Spanish LSSI-CE).
Technical necessary cookies: Technical necessity to ensure website functionality and remember essential user preferences (exempt from consent under Article 22.2 LSSI-CE).
Anti-bot verification of forms (Cloudflare Turnstile): Our legitimate interest in protecting the website and its forms against spam and automated or abusive use (Article 6.1.f GDPR).

You have the right to withdraw or modify your consent at any time without affecting the lawfulness of processing based on consent prior to its withdrawal.

4. No-Sale Commitment, Data Recipients, and International Transfers

Strict Guarantee: IMPAR CAPITAL and IMPAR PROPERTIES DO NOT sell, rent, or transfer your personal data to external third parties for their own independent marketing purposes.

Your data will only be accessible or communicated to:

Necessary Data Processors: Service providers strictly required for the technical and operational support of the website (secure cloud hosting providers and CRM platforms), bound by data processing agreements in full compliance with Article 28 of the GDPR.
Measurement and Advertising Partners (solely when cookies are accepted): Google Ireland Limited (Google Tag Manager, Google Analytics 4, Google Ads) and Meta Platforms Ireland Limited (Meta Pixel). These providers may transfer data to their parent companies in the United States (Google LLC and Meta Platforms, Inc.), both certified under the EU-U.S. Data Privacy Framework adequacy decision.
Anti-bot Security Provider: Cloudflare, Inc., through its Cloudflare Turnstile service, which invisibly checks that the contact and WhatsApp forms are submitted by a person and not by an automated program. To do so it processes technical data from your browser and device (such as IP address, user agent and interaction signals), without setting tracking cookies or using the data for advertising. Cloudflare, Inc. is certified under the EU-U.S. Data Privacy Framework. You can read how this data is processed in the Cloudflare Turnstile Privacy Addendum.

5. Data Retention

Contact data will be retained for as long as a commercial relationship or mutual interest in IMPAR CAPITAL residential developments persists. Thereafter, data will be safely archived and blocked to meet legal obligations, and subsequently deleted securely.

Data collected via cookies is retained for the periods specified in our Cookie Policy table (up to 2 years for analytics, 3 months for advertising cookies). Your cookie consent preferences are stored for a maximum period of 13 months.

6. Your Rights (GDPR)

Under European regulations, you are entitled to exercise the following rights:

Access: Right to obtain confirmation as to whether your personal data is being processed.
Rectification: Right to obtain rectification of inaccurate or incomplete data.
Erasure (Right to be Forgotten): Right to request erasure of your data when it is no longer needed.
Objection: Right to object at any time to the processing of your data for commercial communications.
Restriction of Processing: Right to obtain restriction of processing under legally provided circumstances.
Data Portability: Right to receive your personal data in a structured, commonly used format.

To exercise any of these rights free of charge, please contact us by email at [email protected] or by postal mail at Calle de Serrano, 45, Floor 1, 28001 Madrid, Spain, indicating "Data Protection - Palacio Sagasta" in the subject line.

You also have the right to lodge a complaint with the competent supervisory authority, in Spain the Agencia Española de Protección de Datos (AEPD) via their website (www.aepd.es).

7. Data Security

We employ industry-leading technical and organizational security measures (SSL/TLS encryption, cloud perimeter firewalls, strict HTTPS enforcement, and segregated databases) to ensure the confidentiality, integrity, and availability of your personal data.

The contact and WhatsApp forms are protected against automated submissions by Cloudflare Turnstile, an invisible verification system that requires no action on your part. More information in the Cloudflare Turnstile Privacy Addendum.

8. Cookies and Tracking Technologies

This website uses first-party and third-party cookies (technical, analytical, and advertising). For complete details on the specific cookies used, their purpose, lifespan, and associated providers, please review our Cookie Policy.

You may at any time adjust or revoke your preferences regarding analytics and advertising cookies using our interactive settings panel: