Privacy Policy

1. Data controller

The controller of the personal data collected through the site realdream.finance is:

Realdream Finance is the trading name of Roberta Navigli Severini, self-employed in Spain. The data controller is therefore Roberta Navigli Severini as a natural person, registered as Intermediario de Crédito Inmobiliario (ICI) in the Banco de España register under number E773 (registered 15/07/2026).

NIF: Y4686291-D

2. Personal data collected

We collect the following personal data when you interact with the site:

• Identification and contact data: first name, surname, email address, telephone number, preferred language, country of residence, region of interest in Spain. Provided voluntarily through the contact and pre-qualification forms.
• Data relating to your commercial interest: the stage you are at in buying in Spain, the service requested (mortgage, due diligence, tax, NIE, refinance, wealth tax), indicative property price, and any free-text notes you provide.
• Browsing data (with explicit consent through the cookie banner): IP address, browser type, operating system, pages visited, time on site, traffic source (UTM parameters).
• Subsequent communications: the content of emails, calls or WhatsApp messages you send us after the first contact.

We do not collect special categories of personal data (ethnic origin, political opinions, health, etc. under Art. 9 GDPR) or biometric data.

3. Purposes of processing and legal bases

Your data is processed for the following purposes:

• Responding to your enquiry and qualifying the lead. Legal basis: pre-contractual measures at the request of the data subject (Art. 6.1.b GDPR).
• Performance of the service contract (mortgage, due diligence, tax, etc.) if you decide to proceed. Legal basis: performance of a contract (Art. 6.1.b GDPR).
• Compliance with legal and regulatory obligations (AML/KYC, Banco de España rules for credit intermediaries, tax obligations, record retention). Legal basis: legal obligation (Art. 6.1.c GDPR).
• Statistical analysis of site traffic (analytics cookies). Legal basis: explicit consent through the cookie banner (Art. 6.1.a GDPR).
• Marketing and commercial communications (newsletter, commercial follow-up, advertising retargeting). Legal basis: explicit consent (Art. 6.1.a GDPR), which can be withdrawn at any time.

4. Recipients of the data

Your data may be shared with:

• Realdream Finance internal staff authorised to process it (advisors, operational support).
• External suppliers acting as processors under Art. 28 GDPR:
  • Vercel Inc. (USA) — website hosting
  • Airtable Inc. (USA) — lead CRM database
  • Google LLC (USA) — Google Workspace for company email where applicable, and Google Analytics (only if you have consented to analytics cookies)
  • Meta Platforms Inc. (USA) — Meta Pixel for campaign measurement where applicable (only if you have consented to marketing cookies)
• Professional partners (partner banks for the mortgage application, partner lawyers for due diligence, partner gestoría for tax, notaries) — only after you have given an explicit service mandate by signing the service contract.
• Competent authorities in compliance with legal obligations (Banco de España, Agencia Tributaria, judicial authorities).

We do not sell your data to third parties, under any circumstances and for any purpose.

5. Transfers of data outside the EU/EEA

Some of our suppliers (Vercel, Airtable, Google, Meta) are based in the United States. Transfers of your personal data to the USA take place on the basis of the Standard Contractual Clauses (SCC) approved by the European Commission (Decision 2021/914) and, where applicable, of the EU-US Data Privacy Framework (DPF) for suppliers that have signed up to it.

You can request a copy of the appropriate safeguards by writing to info[at]realdream.finance.

6. Retention period

• Leads not converted into clients: 24 months from the last meaningful contact, after which the data is deleted or anonymised.
• Clients who have signed a service contract: for the duration of the contract and for 10 years after it ends, under the record-retention obligations set out in anti-money-laundering legislation (Ley 10/2010) and Spanish sector rules.
• Data collected for marketing purposes: until consent is withdrawn or, in the absence of any interaction, for 24 months.
• Analytics and marketing cookies: a maximum of 13 months (for first-party cookies) or for the duration specified by the third-party provider (see Cookie Policy).

7. Your rights

As a data subject, under Arts. 15-22 GDPR, you have the right to:

• Access your personal data (Art. 15)
• Rectification of inaccurate or incomplete data (Art. 16)
• Erasure of your data (the "right to be forgotten", Art. 17)
• Restriction of processing (Art. 18)
• Portability of your data in a structured format (Art. 20)
• Objection to processing for direct marketing purposes, at any time and free of charge (Art. 21)
• Withdrawal of consent, at any time, without affecting the lawfulness of processing based on consent before its withdrawal
• Complaint to the supervisory authority: Agencia Española de Protección de Datos (AEPD), C/ Jorge Juan, 6, 28001 Madrid, Spain — www.aepd.es

To exercise your rights, write to info[at]realdream.finance. We will respond within 30 days of receiving the request (extendable by a further 60 days for complex requests, with a reasoned notification).

8. Security measures

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction or disclosure: TLS/HTTPS transmission, role-based access control, staff training, periodic risk assessments.

9. Cookies

The use of cookies on the site is governed by our Cookie Policy, which forms an integral part of this Privacy Policy. You can manage your cookie preferences at any time by clicking here.

10. Changes to this notice

This Privacy Policy may be updated from time to time to reflect legislative changes or developments in the service. The date of the last change is shown at the top. We encourage you to check it regularly. In the event of substantial changes, we will inform you by email or through a notice on the site.

11. Contact

For any question or request relating to the processing of your personal data: