1940 & Victorio Book

Privacy policy

Last updated: 20 October 2026

This is a translation for information purposes. In case of discrepancy, the Spanish version prevails.

This policy explains which personal data we process, why, on what legal basis, for how long and what rights you have, under the General Data Protection Regulation (GDPR) and Spanish Organic Law 3/2018 on data protection (LOPDGDD).

1. Controller

We have not appointed a data protection officer because we are not required to. For any question about your data, write to reservas@luxuryrentalsmurcia.com.

2. What data we process and why

When you write to us or call us

If you contact us by email, WhatsApp or phone —including when you ask about services from an apartment page— we process your name, your contact details and whatever you tell us, such as dates, number of guests or the services you are interested in.

  • Purpose: to reply and deal with your request. If you decide to book an external service (parking, cleaning, laundry or breakfast), we share with the provider only the data needed to provide it.
  • Legal basis: taking steps at your request before a contract, or dealing with your request (art. 6.1.b GDPR).
  • How long: while we deal with your enquiry and for up to one year afterwards. If it leads to a booking, the next section applies.

When you consult me as a lawyer

If you contact me with a legal enquiry, from the legal advice page or by any other means, I process your name, your contact details and the information and documents you give me about your case.

  • Purpose: to answer your enquiry and, if you instruct me, to provide the legal service, which includes filing documents with public authorities, notaries or registries.
  • Legal basis: steps taken at your request before entering into a contract and the performance of the engagement (art. 6.1.b GDPR), and compliance with legal obligations (art. 6.1.c GDPR), such as anti-money laundering rules in the transactions to which they apply.
  • Specially protected data: some procedures, for example for residence, require medical certificates or criminal record certificates. I only process them if you instruct me on that procedure, to the extent it requires and with the safeguards set by law.
  • Professional secrecy: what you tell me is protected by lawyers' professional secrecy.
  • Who receives it: only the public authorities, notaries or registries with which I handle your matter, when the engagement requires it.
  • How long: if you do not instruct me, up to one year after the enquiry. If you do, for as long as the engagement lasts and then for the legal limitation periods; in transactions subject to anti-money laundering rules, ten years.

When you ask about a home

If you contact us about a home for sale or for rent, we process your name, your contact details and what you tell us about what you are looking for.

  • Purpose: to answer you, arrange viewings and put you in touch with the partner agency marketing the home, to which we only pass on the data needed for the transaction.
  • Legal basis: steps taken at your request before entering into a contract (art. 6.1.b GDPR) and, in sales, compliance with anti-money laundering rules, which require the parties to be identified (art. 6.1.c GDPR).
  • How long: up to one year after your last enquiry. If a transaction takes place, the legal periods; anti-money laundering records, ten years.

If you are an owner who wants to sell or rent out

If you contact us about your home, we process your contact details, the details of the home and the documents you give us.

  • Purpose: to study your case, advise you and place your home with the partner agency you choose, to which we pass on the data needed for the engagement.
  • Legal basis: pre-contractual steps at your request and the performance of the engagement (art. 6.1.b GDPR), and compliance with legal obligations, such as anti-money laundering rules in sales (art. 6.1.c GDPR).
  • How long: if there is no engagement, up to one year after your last enquiry. If there is, for as long as it lasts and then for the legal periods; anti-money laundering records, ten years.

If you recommend someone to us

We process your contact details to manage your recommendation and, if it succeeds, your tax details to pay you the commission.

  • Legal basis: the relationship established with you when you accept the terms of the «Recommend and earn» programme (art. 6.1.b GDPR) and tax obligations (art. 6.1.c GDPR).
  • How long: while your recommendation is valid and, if there is a payment, for the tax periods.

If someone has recommended you to us

If someone has given us your name and phone number because you want to sell or rent out a home, we only use them if they asked for your permission first, and when we call you we tell you who gave them to us. If you do not want us to contact you, we delete your details as soon as you tell us.

  • Legal basis: our legitimate interest in following up a recommendation made with your permission (art. 6.1.f GDPR) and, if you go ahead, pre-contractual steps (art. 6.1.b GDPR).
  • How long: if we do not go ahead, we delete them. If there is an engagement, the previous subsection on owners applies.

If you are a partner estate agency

We process the professional contact details of the agency's staff to manage the collaboration, based on our legitimate interest in maintaining that relationship (art. 6.1.f GDPR), for as long as it lasts and up to one year afterwards.

When you stay with us

If you book a stay, we process the data needed to manage it —contact details, dates, number of guests, communications and access to the apartment— and the data required by law for guest registration.

  • Purpose: to manage your stay and to comply with the legal obligation to record guests' details and report them to the Spanish Ministry of the Interior.
  • Legal basis: performance of the accommodation contract (art. 6.1.b GDPR) and compliance with legal obligations (art. 6.1.c GDPR; Organic Law 4/2015 and Royal Decree 933/2021).
  • How long: stay data, for the duration of the stay and afterwards for the applicable statutory limitation periods; guest registration data, three years, as required by Royal Decree 933/2021.

If you book through Airbnb, Airbnb processes your data as a controller under its own privacy policy and provides us with the data needed for your stay.

When you browse the website

We process technical data about your connection —IP address, browser, device and pages visited— so that the website works and is secure. We do not use analytics tools.

  • Legal basis: our legitimate interest in the website working properly and securely (art. 6.1.f GDPR).
  • More details in the Cookie policy.

3. Who receives your data

  • We do not sell your data or share it with third parties, except where required by law —for example, reporting guest registration to the Ministry of the Interior— or as described above for the external services you book.
  • We are helped by providers that process data on our behalf under contract (data processors): website hosting, email and guest registration platform.
  • If you ask about a home or entrust us with yours, the partner agency marketing it, with the data needed for the transaction.
  • If you write to us on WhatsApp, that service is provided by WhatsApp (Meta) under its own terms.

4. International transfers

Some providers, such as Google or Meta (WhatsApp), may process data outside the European Economic Area. When this happens, the transfer is covered by the EU-US Data Privacy Framework or by standard contractual clauses approved by the European Commission.

5. Your rights

You can ask to access, rectify or erase your data, restrict its processing, object to it or request its portability. You can also withdraw any consent you have given at any time, without affecting processing carried out before.

Write to reservas@luxuryrentalsmurcia.com with the subject «Data protection». If you feel we have not handled your request properly, you can complain to the Spanish Data Protection Agency (www.aepd.es).

6. Minors

This website is not aimed at children under 14 and we do not knowingly collect their data. Bookings must be made by an adult.

7. Security

We apply appropriate technical and organisational measures to protect your data against loss, unauthorised access or misuse.

8. Video surveillance in the buildings

The common areas of both buildings have video surveillance cameras. Each owners' association (comunidad de propietarios) is responsible for them, not this website. You can find their information in the activity records of the Victorio Building and the San Juan de Dios Building (links in the footer of the contact page).

9. Changes to this policy

We may update this policy to reflect legal or operational changes. The date of the last update appears at the top.