Our privacy statement

Acacia Point was established in 2014 and is an independently owned, European-focussed, real estate investment and asset management company

  1. Our commitment

    The protection of privacy and personal data is a fundamental commitment of ACACIA POINT CAPITAL ADVISORS to the holders of personal data that use our products and our services. In this policy we explain what categories of personal data we collect for what purposes and how we treat them, with whom we share them, how long we retain them, the principles we respect, how we contact and exercise their rights.

  2. General Regulation on Data Protection

    The GDPR lays down the principles and rules concerning the processing by a person, company or organization of personal data relating to persons in the European Union.


    GDPR protects personal data irrespective of the technology used for processing such data, protection is technologically neutral, and applies to both automated and manual processing, provided the data is organized according to predefined criteria (for example, in alphabetical order). Also irrelevant is the way data is stored, in a computer system, via video surveillance, or on paper; in all these cases, personal data are subject to the protection requirements of the GDPR.


  3. What is personal data?

    Personal Data is any information of any nature and in any medium relating to an identified or identifiable natural person. Any identifiable person, directly or indirectly, identified by reference to a name, identification number, location data, identifiers by electronic means or one or more specific elements of his or her physical, physiological, genetic, mental, economic, cultural or social.

  4. Who owns the personal data?

    The owners of personal data are the natural persons to whom the data relates and who intend to use or have used the products and services of ACACIA POINT CAPITAL ADVISORS, or who collaborate directly or indirectly with ACACIA POINT CAPITAL ADVISORS in the scope of our activity, are users of our websites, are buyers of our properties, are clients and their companions who use our tourist accommodations, are clients or interlocutors of our partners, employees or service providers and job seekers.


    ACACIA POINT CAPITAL ADVISORS may collect data from minors and other accompanying persons holding reservation of tourist accommodation in compliance with the legislation in force regarding the control of foreign citizens in the national territory.

  5. Categories of personal data

    ACACIA POINT CAPITAL ADVISORS addresses a number of categories of data necessary for the purposes and ensuring compliance with the Data Minimization Principle, including contact details, identification data, address, tax data, bank and credit card data and also the professional data of its employees, service providers and job seekers, images of people and goods that are in our oces for security purposes (video surveillance).

  6. What is the processing of personal data?

    The processing of personal data consists of an operation or set of operations carried out on personal data or personal data sets, by automated means or not, namely collection, registration, organization, structuring, preservation, adaptation, retrieval, consultation, use, disclosure, dissemination, comparison, interconnection, limitation, erasure or destruction

  7. The Principles of Data Protection

    All personal data processing at ACACIA POINT CAPITAL ADVISORS is conducted in accordance with the principles of data protection as established by the RGPD. ACACIA POINT CAPITAL ADVISORS’s policies, processes, procedures and records are designed to ensure compliance with the principles.

  8. Principle of Legality, Loyalty and Transparency

    We always identify a legal basis, pre-contractual at the request of the data subject, contractual in which the data subject is a party, legitimate interest or when not applicable, consent of the data subject and when the data subject is a child below 16 years or unenforceable, the holder of the parental responsibility or of the guardianship will be asked to sign the consent;


    We provide Privacy Notices to data holders who will provide more detailed information on ACACIA POINT CAPITAL ADVISORS data processing.

  9. Principle of Limitation of Purposes

    Data are collected for specific, explicit and legitimate purposes and are not subsequently processed in a manner incompatible with those purposes.

  10. Principle of Data Minimization

    The data collected and processed are adequate, relevant and limited to what is necessary having regard to the purposes.

  11. Principle of Accuracy

    Appropriate measures have been taken to ensure that inaccurate data, considering the purposes for which they are processed, are erased or rectified without delay, and the data subject can exercise his right to rectification at any time.

  12. Principle of Conservation Limitation

    The data are stored in a way that allows the data subjects to be identified only for the period necessary for the purposes for which they are processed and in compliance with the regulations and legislation in force.

  13. Principle of Responsibility

    ACACIA POINT CAPITAL ADVISORS is able to demonstrate in a responsible manner its commitment to the principles of the RGPD. ACACIA POINT CAPITAL ADVISORS implemented policies, processes and procedures for data protection, inventory personal data and treatments performed on them, took measures to raise awareness of its employees and service providers, obtained the commitment of these and its subcontractors to privacy , is prepared to respond to data subjects’ concerns in the exercise of their rights, takes into account privacy in the design of new services, assesses the risk of potentially resulting treatments, and has data breach notification procedures and response plans to incidents.

  14. Who is responsible for the treatment?

    The person responsible for the collection and processing of your personal data will be ACACIA POINT CAPITAL ADVISORS who provides you with the service or provides the product and in that scope decides what data collected, means of processing and purposes for which the data is used.

  15. Legal basis for the treatment

    Consent: Your consent must be expressed in writing or through the validation of an option – and prior, provided in a free, informed, specific and unambiguous manner.


    Examples of your consent to ACACIA POINT CAPITAL ADVISORS are to register applications through our websites, customer loyalty actions and corporate events, or to make recommendations or send marketing messages.


    Execution of contract or pre-contractual procedures: when the processing of personal data is necessary to propose our products or services and to fulfil the obligations assumed by ACACIA POINT CAPITAL ADVISORS in contracting the supply of these products or services. Compliance with a legal obligation: when the processing of personal data is necessary to fulfil a legal obligation to which ACACIA POINT CAPITAL ADVISORS is subject, such as the Commercial Code, the Tax Code, the Labour Code or the Civil Code. Legitimate interests: the processing of personal data by ACACIA POINT CAPITAL ADVISORS may be justified on grounds of legitimate interest related to the execution of its activities as a company, such as the geolocation of the fleet of vehicles in a labour context, the monitoring of the computer media and the Internet, the control of assiduity of its employees by biometric system, the video surveillance of our office for the security of people and goods.

  16. Purposes of treatment

    ACACIA POINT CAPITAL ADVISORS treats personal data for the purposes of promotion, commercialization and contracting of its properties, the management of projects for the rehabilitation of these properties, the management of the necessary means to achieve such the management of partnerships, human resources, its employees and service providers and the necessary infrastructures.

  17. Duration of treatment

    Your personal data are treated by ACACIA POINT CAPITAL ADVISORS only for the period of time necessary to achieve the defined purpose or, depending on the applicable, until you exercise your right of opposition, right to be forgotten or withdraw consent.


    ACACIA POINT CAPITAL ADVISORS will, after the expiration of its period of validity, eliminate or anonymize the data whenever they are not to be kept for a purpose other than that which may last.

  18. Transmission of your personal data

    Personal data may be transmitted to subcontractors for processing in the name and on behalf of ACACIA POINT CAPITAL ADVISORS. In this case, ACACIA POINT CAPITAL ADVISORS takes the necessary contractual measures to ensure that subcontractors respect and protect the personal data of the holder.


    Data may also be transmitted to third parties – entities other than ACACIA POINT CAPITAL ADVISORS or subcontractors – such as companies with which ACACIA POINT CAPITAL ADVISORS develops partnerships, if the holder has consented – or entities to whom the data must be communicated by law, such as the Tax Authority, the Aliens and Borders Service, judicial authorities, criminal police agencies, among others.