1. Introduction

Protecting your personal data is a priority for Horizon Admin.

This Privacy Policy explains how we collect, use, retain and protect your personal information when you visit our website, contact us or use our services.

We process personal data in accordance with the General Data Protection Regulation (GDPR — Regulation (EU) 2016/679), applicable Spanish legislation, including Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD), and other relevant legal provisions.

2. Data Controller

The data controller is:

Horizon Global Services, S.L.

Horizon Admin is a trading name of Horizon Global Services, S.L., which has also operated under the Horizon Immobilier Espagne brand.

This change of trading name does not, in itself, constitute a change of data controller where the personal data was collected by the same company.

3. Personal Data We Collect

Depending on your relationship with Horizon Admin and the services requested, we may process the following categories of personal data:

Identification and contact details: first and last name, postal address, email address, telephone number, nationality and, where necessary, identity documents and NIE/NIF numbers.

Property information: property address, cadastral references, ownership documents and details, ownership percentages, occupancy or rental periods, and other property-related documentation.

Tax and financial information: tax residency, rental income, information required for tax returns, expense records, invoices, bank account details and payment information.

Administrative and contractual information: contracts, authorisations, powers of attorney, correspondence, invoices and documents provided in connection with our services.

Insurance enquiry information: identification details and information required to obtain insurance quotations, depending on the type of insurance requested.

Technical information: data necessary for the operation and security of our website and digital services, as well as information collected through cookies where their use is authorised.

We aim to collect only the information necessary for the relevant purposes.

4. Purposes and Legal Bases for Processing

4.1. Responding to Enquiries

When you contact us, we use your contact details and the information you provide to answer your questions, explain our services or prepare a proposal.

Depending on the circumstances, this processing is based on steps taken at your request before entering into a contract or on our legitimate interest in responding to enquiries.

4.2. Tax and Administrative Services

We process the personal data necessary to provide the services entrusted to us, including:

  • Preparing and submitting tax returns, particularly those relating to Spanish Non-Resident Income Tax (IRNR).

  • Assisting with administrative procedures relating to properties in Spain.

  • Preparing, submitting and following up on documents and procedures with the relevant authorities.

  • Managing and monitoring client files.

This processing is primarily based on the performance of a service contract and, where applicable, compliance with legal obligations.

Certain procedures may also require specific authorisation or a power of attorney.

4.3. Insurance Quotations

Horizon Admin acts as an external collaborator of an independent insurance broker.

In this capacity, we primarily collect identification details, contact information and general information required to request insurance quotations. This information is forwarded to the partner broker, who is responsible for preparing quotations and managing insurance policies.

For certain products, particularly health insurance, medical questionnaires may be requested directly by the broker or the relevant insurance company.

Horizon Admin does not routinely collect medical information and does not provide medical questionnaires through its website.

However, at the request of certain clients, we may occasionally receive documents containing health information solely to facilitate their transmission to the intended recipient.

Horizon Admin does not use this information to assess medical risks or determine insurance conditions.

Any processing of health-related information is subject to the specific requirements of Article 9 of the GDPR and appropriate confidentiality safeguards.

4.4. Client Relationship Management and Invoicing

We use the information necessary to manage contracts, client communications, invoices, payments and administrative documents.

This processing is based on contractual performance, applicable legal obligations and, in certain circumstances, our legitimate interests in managing and securing our business activities.

4.5. Information and Marketing Communications

We may send clients and contacts information about our services, tax and administrative developments, or other services that may be of interest to them.

Electronic marketing communications are sent only where permitted by applicable legislation, including on the basis of consent or, where the legal requirements are met, an existing contractual relationship involving similar services.

Each electronic marketing communication provides a means of opting out of future messages.

You may also request to stop receiving these communications by contacting contact@horizonadmin.com.

4.6. Security and Operation of Digital Services

We process certain technical information to maintain the operation, security and reliability of our website, systems and client portal.

Depending on the nature of the processing, the legal basis may be our legitimate interest in protecting our services or compliance with applicable legal obligations.

The use of cookies is explained in our Cookie Policy.

5. Continuity with Horizon Immobilier Espagne

Horizon Global Services, S.L. has also operated under the Horizon Immobilier Espagne brand.

As part of this continuity, personal data previously collected by the same company may continue to be processed to maintain client relationships, fulfil agreed services, comply with legal obligations and pursue purposes compatible with those for which the data was originally collected.

Personal data is not automatically reused for new purposes that are incompatible with its original collection.

In particular, marketing communications sent to former clients or contacts remain subject to the requirements of applicable legislation.

6. Client Portal and Document Management

Horizon Admin provides certain clients with access to a digital portal through which they can view, upload and store documents relating to the services provided.

This portal may contain tax, administrative, contractual or identification documents.

Access is restricted to authorised users and requires individual login credentials.

The technical operation of the portal involves specialised service providers, which are subject to the applicable data protection obligations.

7. Recipients of Personal Data

Depending on the services requested, personal data may be disclosed to the following categories of recipients:

  • Spanish public authorities and administrative bodies, including tax authorities and other organisations responsible for the relevant procedures.

  • Our independent insurance broker partner, for handling insurance enquiries.

  • Technology service providers, including hosting, email, customer relationship management, invoicing and document portal providers.

  • Professionals or service providers involved in client matters, where their involvement is necessary to provide the requested service.

  • Competent authorities, where disclosure is required by law.

We use digital business management services provided by Zoho and the SuiteDash platform for certain client portal functions.

Service providers processing personal data on our behalf are subject to the contractual obligations applicable to data processors under the GDPR.

Organisations that independently determine the purposes and means of processing may act as separate data controllers.

We do not sell your personal data.

8. International Data Transfers

In the course of our activities, certain technology providers may process or host personal data outside the European Economic Area or allow access from third countries.

We use services provided by Zoho, whose CRM environment for our business is associated with the European region, and SuiteDash, a provider established in the United States.

Where international transfers take place, they are subject to the mechanisms established under the GDPR, including applicable adequacy decisions or the European Commission’s Standard Contractual Clauses, together with additional safeguards where necessary.

A Data Processing Agreement has been concluded with SuiteDash, including provisions governing international data transfers.

You may contact us for further information about the safeguards applicable to transfers involving your personal data.

9. Data Retention

Personal data is retained for as long as necessary to fulfil the purposes for which it was collected.

Where required, it may subsequently be retained for periods established by applicable tax, accounting, contractual or other legal obligations.

The main retention criteria are as follows:

  • Enquiries: for the period necessary to respond to and follow up on the enquiry, in accordance with applicable internal retention criteria.

  • Client records: throughout the contractual relationship and subsequently for applicable statutory retention periods or as necessary to establish, exercise or defend legal claims.

  • Tax and accounting documents: for the retention periods required by applicable legislation.

  • Marketing information: until the individual objects to the processing, withdraws consent where consent is the legal basis, or the applicable retention period expires.

  • Technical information: for a period proportionate to operational and security requirements.

When personal data is no longer required, it is deleted or anonymised, subject to applicable legal retention obligations.

10. Data Security

Horizon Global Services, S.L. implements technical and organisational measures appropriate to the nature of the personal data processed and the associated risks.

These measures are intended to prevent unauthorised access, protect the confidentiality of documents and reduce the risk of loss, alteration or disclosure.

Access to personal information is limited to individuals and service providers who require it to perform their duties.

The platforms we use may implement additional security measures, including encryption, authentication mechanisms and backup systems.

11. Your Data Protection Rights

Under the GDPR, and subject to the conditions established by applicable legislation, you have the following rights:

  • Right of access: to obtain information about the personal data we process concerning you.

  • Right to rectification: to request the correction of inaccurate or incomplete information.

  • Right to erasure: to request the deletion of personal data where the legal requirements are met.

  • Right to restriction: to request restrictions on certain processing activities.

  • Right to object: to object to certain processing activities, particularly direct marketing.

  • Right to data portability: to receive or transfer your data where this right applies.

  • Right to withdraw consent: to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.

To exercise your rights, please contact us:

Email: contact@horizonadmin.com

Postal address: Horizon Global Services, S.L., C/ Edimburgo, 27 – 29650 Mijas (Málaga), Spain.

We may request additional information strictly necessary to verify your identity where justified.

You also have the right to lodge a complaint with the Spanish Data Protection Authority:

Agencia Española de Protección de Datos (AEPD)
https://www.aepd.es

12. Personal Data Provided by Third Parties

In certain circumstances, we may receive personal data from a representative, co-owner or another person involved in an administrative procedure.

We process this information only to the extent necessary for the legitimate purposes of the relevant matter.

Where personal data is not obtained directly from the individual concerned, we comply with the applicable information obligations, subject to any exceptions provided by law.

13. Cookies and Third-Party Websites

Our website may use cookies and similar technologies.

Information about their purposes, use and available consent management options is provided in our Cookie Policy.

Our website may also contain links to third-party websites, which operate under their own privacy policies.

14. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our business activities, the technology we use or applicable legislation.

The updated version will be published on this page, together with its revision date.

Where required by law, affected individuals will be informed of relevant changes.