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Legal/Record of processing

Record of processing

Version 2026-10-01·Courtesy translation

Legal noticePrivacyCookiesTerms of serviceRecord of processing

On this page

  1. 01Controller
  2. 02Cross-cutting processor
  3. 03Processing activities
  4. 04Retention periods
  5. 05International transfers
  6. 06Security measures
  7. 07Special categories of data
  8. 08Automated decision-making

Questions about this text?

daly@icam.es
On this page
  1. 01Controller
  2. 02Cross-cutting processor
  3. 03Processing activities
  4. 04Retention periods
  5. 05International transfers
  6. 06Security measures
  7. 07Special categories of data
  8. 08Automated decision-making

Courtesy translation. The binding text is the Spanish original, which prevails in the event of any discrepancy. Read the original in Spanish

This is an extract from the record of processing activities under art. 30 GDPR, not the complete record: the full version, with the security measures and the technical detail, is made available to the Agencia Española de Protección de Datos (AEPD, the Spanish Data Protection Authority) upon request.

It is not one of the four policies of the site and no consent is given to it: it is published for the sake of transparency, and it accompanies the privacy policy, which is the document that informs data subjects.

01

Controller

Dalyko Partners, S.L. — NIF B21833264 (Spanish tax ID) · Calle Navel 10 · 03189 Orihuela (Alicante) · daly@icam.es

No Data Protection Officer: none of the cases in art. 37.1 GDPR applies.

02

Cross-cutting processor

Google Ireland Ltd. provides the infrastructure for all the digital processing activities listed below (servers, database, document storage, authentication for the private area and email delivery), as processor and under a contract pursuant to art. 28 GDPR. To avoid repeating this in every row, the recipients column lists only the additional recipients.

Twilio Ireland Ltd. (SendGrid) is a processor solely as an alternative email delivery route.

03

Processing activities

Processing activityPurposeCategories of dataLegal basisData subjectsRecipients in addition to Google
Web analyticsMeasuring use of the siteRandom identifier, IP, browser, operating system, device, language, referrer, pages and interactionConsent — art. 6.1.a GDPR and 22.2 LSSI (Spanish Information Society Services Act)VisitorsNo one
Quote requestCalculating and recording a simulationService, property value, amountPre-contractual steps — 6.1.bRequestersNo one
Opening a file from the websiteReceiving the engagement and opening the fileName, email, telephone, transaction, quotePre-contractual steps — 6.1.bAnyone who confirms an engagementNo one
Protection against automated submissionsPreventing a program from filling in the formsResult of the calculation, trap field, IPLegitimate interest — 6.1.fAnyone who fills in a formNo one
Email confirmationVerifying that the address belongs to the person who declares itEmail, single-use token, datePre-contractual steps — 6.1.b · Legitimate interest — 6.1.fRequestersNo one
Client private areaGiving access to the file and its documentsEmail, session identifier, access dateContract — 6.1.b · Legitimate interest — 6.1.fClientsNo one
WhatsApp contactAnswering enquiries, outside the engagement processNumber, message content, metadataPre-contractual steps — 6.1.b · Legitimate interest — 6.1.fAnyone who writes to usMeta Platforms Ireland, as independent controller
Client fileProviding the legal serviceIdentification data, contact details, property, transaction, documentsContract — 6.1.b · Legal obligation — 6.1.cClients and other parties to the transactionAEAT (Spanish State Tax Administration Agency), Registro de la Propiedad (Spanish Land Registry), notary's office, regional administration
Prevention of money launderingComplying with Ley 10/2010 (Spanish Act on the prevention of money laundering and terrorist financing)Identity document, beneficial ownership, source of fundsLegal obligation — 6.1.cClients within its scopeSEPBLAC (Spanish anti-money laundering financial intelligence unit), where applicable
Document signingProving who signed and whenName, email, date and time, IP, browser, document hash, signature strokeContract — 6.1.b · Legitimate interest — 6.1.fSignatoriesNo one
Mobile and email verificationChecking that the channel belongs to the data subjectTelephone, email, single-use codeContract or prior steps — 6.1.b · Legitimate interest — 6.1.fClients and requestersMeta Platforms Ireland, if the check is done via WhatsApp
Document custodyKeeping the fileDocuments of the matterContract — 6.1.b · Legal obligation — 6.1.cClientsNo one
Invoicing and taxationComplying with tax and accounting obligationsIdentification data, NIF, amounts, invoicesLegal obligation — 6.1.cClientsAEAT
Payment handling with money on accountPaying on the client's behalf what they instruct us to pay, and accounting to them for itIdentification data, source account, amounts, receiptsContract — 6.1.b · Legal obligation — 6.1.cClients who ask for itBank, AEAT, town hall or SUMA, seller; water and electricity companies if the change of holder is instructed
Outgoing emailSending confirmations, quotes and notifications about the fileEmail, name, message contentContract or prior steps — 6.1.bRequesters and clientsTwilio Ireland (SendGrid), only as an alternative route
Commercial communicationsSending news, guides and offers from QuickConvey by email to those who ask for them and verify their address, and choosing who each mailing is of interest toEmail, name, language, country, nationality, type and relationship with us, activity with us, data from their files with QuickConvey; sign-ups and unsubscriptions with the version and hash of the policy; copy and outcome of each mailingConsent — art. 6.1.a GDPR and 21 LSSIThose who ask for themTwilio Ireland (SendGrid), only if used as a sending route
Advertising suppression listNot writing again to anyone who has unsubscribed or whose address bouncesEmail, reason, dateArt. 23.1 LOPDGDD (Spanish Data Protection and Digital Rights Act) · Legitimate interest — 6.1.fThose who unsubscribe and holders of addresses that bounceNo one
Security of the serviceMaintaining the service, detecting abuse and limiting submissionsIP, address requested, browser, date and resultLegitimate interest — 6.1.f and recital 49Any visitorNo one
04

Retention periods

As set out in the table in the privacy policy: 10 years for anti-money laundering documentation (with blocking from the fifth year, art. 25.1 Ley 10/2010), 6 for accounting records, 4 for tax records, 5 for the file, 1 year for enquiries that do not lead to an engagement, 6 months for requests submitted and not confirmed, 14 months for web analytics, 90 days for technical security logs and 3 years after unsubscribing, blocked, for the proof of consent to commercial communications; the suppression list, for as long as needed to respect the unsubscription.

05

International transfers

Our systems and their database are in the European Union (Belgium and Madrid). The processors are Irish companies belonging to groups whose parent company is in the United States, which may involve transfers to that country, covered by the EU-US adequacy framework and, in the alternative, by the European Commission's standard contractual clauses.

If a data subject chooses to write to us on WhatsApp, Meta Platforms Ireland Ltd. processes their data on its own account and under its own terms.

06

Security measures

Encryption in transit and at rest, access control per person and per project, access logging, backups, separation of environments and periodic review. The technical detail is not published, for the same reason that the configuration of a lock is not published; it is made available to the supervisory authority when it so requires.

07

Special categories of data

We do not currently process data in the categories of art. 9 GDPR in our property purchase and sale services.

When we provide family law services we will process data that do fall into those categories (family situation, health and psychosocial reports, including those concerning minors), on the basis of art. 9.2.f GDPR: the establishment, exercise or defence of legal claims. This extract will be updated before that happens, not after.

08

Automated decision-making

We do not take automated decisions producing legal effects concerning any person, or similarly affecting them. The price calculator works out a price from the data you enter and decides nothing about you.

The only profiling we carry out is for commercial communications, and only of those who ask for them: rules written by us choose who each mailing is of interest to, without artificial intelligence and with no effect whatsoever on the file, the price or the service. It is described in the privacy policy.

Nor do we use artificial intelligence on the files. If it were ever activated, that would be a new purpose: the version of the policies would change and information would be provided beforehand, not afterwards.

Version2026-10-01

The four policies on this site share the same version, and this extract accompanies them with the same date. The version changes only when the substance changes (a new purpose, a new recipient, a different retention period or a different legal basis); correcting a typo does not create a new version.

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QuickConveyABOGADO COLEGIADO · ICAM 108020

Dalyko Partners SL · NIF B21833264
03189 Orihuela (Alicante), Spain
Eloy Becerra Daly, registered practising abogado (Spanish lawyer), ICAM 108020
Collective professional indemnity policy held by ICAM with CASER, €330,000 per claim

daly@icam.es

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