XOJAY — Privacy Policy

Last updated on 5 February 2019

Privacy Policy


  • Introduction :

    The website at xo-jay.com (“Website”) is made available to you by XOJAY management Sl. (“us”, “we”), a Spanish limited liability company. We have a strong commitment to privacy and XOJAY management Sl. is under obligation to follow the provisions of the EU General Data Protection Regulation (“GDPR”) and Spanish Data Protection Act (Organic Law 3/2018). Visitors of our Website (“you”) are encouraged to read this Privacy Policy which provides an overview of our privacy practices. Your access, viewing, or use of the Website constitutes acceptance of this Privacy Policy.

  • Collection of personal data :

    How we collect personal data
    We collect your personal data at various places and through various mechanisms of our Website. Generally, we collect personal data from you directly when you voluntarily register on the Website and/or post a comment, question, or message to us. We may also collect your personal data when we deal with you in person over the phone or when you send us correspondence (including via email), when you use our social media sites or when you register an interest with our listings on third-party websites. By directly providing us with this information you give us consent to the processing of your personal data. When you visit our Website we may also collect personal data that is necessary for us to enable you to move around our Website and use its features, including performance and functionality cookies, and analytics tools that are required to provide services requested by you. 

    What legal grounds do we use to collect personal data
    According to the GDPR we are required to have a legal ground for processing your personal data and inform you about these legal grounds. To process your personal data, we will rely on one of the following legal grounds:

    • Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract.
    • Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency.
    • Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests.
    • Consent: in some cases, we will ask you for a specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting us at: palma@xo-jay.com.
  • Use and Sharing of your Information :

    We may, and reserve the right to use and share your Information among our affiliates, partnerships, ventures, limited partners, vendors, service providers, and consultants, to respond to your request and follow up with you, send you e-mail notifications, news updates, and event invites, to gage support for our XO Residences Palma real estate project, help administer and diagnose problems with the Website, for marketing or advertising purposes, including contacting you about goods and services, to provide building management services and to analyse user analytics, which include, without limitation, what areas users visit most frequently, what web sites they come from, what computer platform or device they use, which city or building they are connecting from, and what services on the third party’s website are being accessed most frequently, and in connection with a potential or actual sale or transfer all or part of our assets or related transaction. We may also use a third-party vendor to provide a platform for hosting the Website. Third parties are or will be contractually limited to only use your Information to the extent necessary to provide contractually requested goods or services and take reasonable steps to secure Information. We reserve the right to share any information collected through the Website with legal authorities if, in our sole opinion, it is necessary to investigate, prevent or otherwise necessary to take action regarding suspected fraud, situations involving threats or potential harm, if otherwise required by law or governmental order or other legal means), or if such disclosure is necessary to protect or enforce the rights, interests, or safety of the Website, its users or other third parties, or to limit our legal liability.

  • Types of personal data we collect :
    • Contact details: names, contact and address details.
    • Online identifiers: IP addresses, cookies, browser type and version, time zone setting, geolocation information, operating system and version etc.

    Website use: aggregated and anonymous information on users’ demographics, interests and behaviours on our Website, what areas users visit most frequently, what websites they come from, what computer platform or device they use, which city or building they are connecting from and other anonymous statistical data involving the use of our Website.

    If you would like to receive our marketing materials, we may request your contact details depending on the type of marketing materials you are interested in. This may include your name, physical address, email address, and telephone number. If you are interested in our services, we will request contact details including your name, email address and telephone number to discuss further our offerings with you.

    Sensitive data and children
    We don’t request any sensitive personal data through our Website. We understand the importance of protecting children’s privacy, especially in an online environment. Our Website is not intentionally designed for or directed at children, and the conditions of use require all users to be above the age of majority in their local country. We adhere to laws regarding marketing to children. We never knowingly collect or maintain personal information about individuals under the age of 18 for marketing purposes.


  • Purposes of collecting personal data :

    We undertake to process your personal data only for the purposes listed below unless we get your specific and explicit consent for other purposes.

    We collect, store and use personal data for the following purposes:
    to provide building management services.

    • to respond to your requests or queries and to verify your identity.
    • to maintain contact with our clients and other contacts and keep them informed of our services, send email notifications, news, updates and event invites.
    • to engage support for our XO Residences Palma real estate project.
    • for marketing or advertising purposes, including contacting you about goods and services.
    • for the performance, functionality, and security of our Website.
    • to meet any regulatory or contractual obligations to which we are subject.
    • to perform internal statistical analysis, including of our marketing and sales databases and Website.
    • to profile Website users based on their consent.
    • to target customers with personalised marketing messages based on their usage of our Website.
    • for any other business-related purposes.
  • Sharing with third parties and transfer outside the EU/EEA :

    We do not share personal data with third parties except as required for our legitimate professional and business needs, to perform your requests, and as required or permitted by law or professional standards.

    However, your personal data may be transferred to and processed by our business partners and third-party service providers to enable these companies to perform the services requested by us. Only personal data that is necessary to fulfill the purposes stated above will be provided to these companies. All third-party providers and business partners must follow our instructions and applicable written data processing agreements and any other agreements that are in place between us. We use only third-party providers that are bound to maintain appropriate levels of security and confidentiality of your personal data. The third-party providers may engage their own sub-contractors that may have access to personal data (“Sub-processors”), in this case, third-party providers are under obligation to ensure that Sub-processors have the same obligations with respect to the personal data.

    We do not transfer your personal data outside the EU/EEA. If we do this your personal data will continue to be protected by means of contracts we have in place with those organizations outside the EU/EEA, containing standard data protection clauses which are in a form approved by the European Commission.

  • Your rights in relation to your personal data :

    You have the following rights with respect to the personal data we process:

    • request a copy of the personal information that you have provided to us in electronic form or ask us to transfer (where technically feasible) the personal information to the recipient of your choice.
    • request us to correct any incorrect or incomplete information about you. We may ask your proof of identity and other information that will allow us to locate your personal information.
    • ask us to delete your personal information or restrict the way in which we process it.
    • object to us processing your personal data.
    • withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).
    • object at any time to processing of your personal data for profiling and direct marketing purposes.

    If you would like to exercise the above-mentioned rights, please contact us at palma@xo-jay.com. You also have the right to lodge a complaint with the Spanish Data Protection Authority (AEPD).


  • Marketing automation :

    We use a marketing automation tool that interacts with our CRM (Customer Relationship Management) database. Data used for marketing automation purposes is enriched by data on the user-specific usage of our Website (profiling). We use CRM to develop our relationship with current and prospective clients and our marketing automation is used to assist with our marketing campaigns. To track the efficiency of our marketing campaigns we also track recipients’ engagement with our marketing emails.

    You have the right object at any time to processing of your personal data for profiling and direct marketing purposes by contacting us via email at palma@xo-jay.com. If you wish to unsubscribe from future emails, you can do so by following a link at the bottom of the email. Once unsubscribed, you will not receive emails from us in the future unless you subsequently re-enter your information on the Website.

  • Cookies, Web beacons and Analytics Tools :

    We use cookies, web beacons, and analytics tools in connection with the Website for the purpose of collecting information about you in an aggregated form. This means that the information is combined and looked at in a summary and anonymised form, rather than on an individual basis. For instance, we may gather certain information such as the number of unique visitors to the Website, the frequency with which they visit, and the pages they viewed. We gather this information so we can learn how many people visit the Website, see which pages are the most viewed, and identify which websites are referring visitors to the Website.

    A cookie is a small removable data file that is stored by a computer’s web browser. We use cookies to, among other things, identify computers during a particular visit to the Website and analyze behaviour while browsing. Advertising cookies may be placed on your computer so that we and/or our display advertising partners can understand what you are interested in and use this to present you with retargeting advertising on other sites based on your previous interaction with the Website. When you access our Website, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing related activities. Cookies required for necessary functionality of the Website will not be blocked by this notification.

    Web browsers may provide you with the ability to accept or decline cookies and to be warned each time a cookie is being sent. You can generally express your privacy preferences regarding the use of most cookies and similar technologies through your web browser settings. In many instances, you can set your web browser to turn off cookies or to notify you before you receive a cookie, giving you the chance to decide whether to accept it. Since cookies allow you to take advantage of some of our Websites’ features, we recommend that you leave them turned on. If you block, turn off, or otherwise reject our cookies, some web pages on our Website may not display properly. Further information about managing cookies can be found in your browser’s help file or through sites such as https://cookiepedia.co.uk/how-to-manage-cookies

    What cookies do we use and why?
    Some of the cookies we use are necessary to enable you to move around the Website and use its features. We also use functional cookies to record information to allow us to tailor the Website to our users; for example, to remember your language or region or that you have already completed a survey. This information is used to a very limited purpose, stored for a limited period of time. All information is completely anonymised and is not used for any other purpose.

    We or our service providers also use analytics tools to help us understand how effective our content is, what interests our users have, and to improve how this Website works. In addition, we use web beacons or tracking pixels to count visitor numbers and performance cookies to track how many individual users access this Website and how often. This information is used for statistical purposes only and it is not our intention to use such information to personally identify any user.

    Web beacons
    Web beacon is an electronic file that is placed on a website, allowing the party that set the web beacon to monitor and collect certain information about the visitor, including, the type of browser downloading the web beacon, the IP address of the computer that the web beacon is sent to, the time the web beacon was viewed, and the URL of the page the web beacon originated from. We use web beacons on our Website to count visitors to the Website, to monitor how visitors use the Website, to access certain cookies, and for other related reasons.

    You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address, but cookie information will not be recorded.

    Analytics Tools
    We use Google Analytics on the Website to collect information about how often visitors use the Website, what pages they have viewed, their use of other websites prior to coming to the Website, and to otherwise analyse Website traffic. We encourage you to read Google Analytics’ Privacy Policy, which contains additional information about this software. To provide website visitors with more choice on how their data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the Website itself or to other web analytics services.

    We also use Facebook Pixel to measure, optimize and build audiences for Facebook advertising campaigns, to measure the effectiveness of our ads and to analyze the effectiveness of our Website’s conversion funnels. You can familiarise yourself with Facebook’s Privacy Policy and Cookies Policy for details about the cookies used, the data received and how you can change your ad preferences.

    Third-party websites
    Our Website may include links and connections to third-party websites, products and services as well as so-called community plug-ins of third parties. The third-party plug-ins integrated into the Website are loaded from third-party servers and thus the third-party may install their own cookies on the user’s device. These third-party services and applications offered on the Website are subject to the privacy policies or notices of such third parties. We recommend you to familiarise yourself with such third-party privacy policies or notices.

  • Security of personal data :

    We take reasonable steps to secure personal data you provide to us. We have appropriate technical and organisational security policies and procedures in place to protect personal data and information from loss, misuse, alteration, or destruction. Our Website uses SSL certificates. SSL stands for Secure Sockets Layer, a global standard security technology that enables encryption of information between a web browser and a web server. Many online businesses and individuals utilize SSL to decrease the risk of information being stolen or tampered with. We also use firewalls and other industry-based, commercially reasonable security measures to ensure your personal data is maintained in a secure environment. Additionally, we aim to ensure that access to your personal data is limited to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information.

  • Retention of personal data :

    We will retain your personal data for as long as we need it for the purposes for which it was collected or as required by our legal or professional obligations. We will keep your contact information and mailing list information until you unsubscribe from the mailing list or request that we delete that information. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honour your request.

  • Contacting us with questions or concerns :

    If you have any questions, concerns, or requests about this Privacy Policy, please feel free to contact us by writing to us at Joan Maragall 17-g, 07007 Palma de Mallorca or by emailing us at palma@xo-jay.com. We will try to respond to you within a reasonable time.

  • Changes to this Privacy Policy :

    We may change this Privacy Policy from time to time to reflect our current privacy practices. If we do, we will post an updated copy on the Website and revise the “Last updated” date on the top of this page. So please periodically check the Website to determine if we have made any changes to this Privacy Policy since your last visit.

Find out more

Register your interest and we'll be in touch

Our dedicated sales team is ready to discuss your interest further.

Alternatively, you can view The XO Residences Palma model and explore the materials at XOJAY showroom.

XOJAY Showroom
Joan Maragall 17-G, 07007
Palma De Mallorca

Opening Hours
09:00 – 18:00

All information you provide us with with be stored securely and processed in accordance with our privacy policy which can be found here. Any personal data you submit to us on this form will be submitted to our sales team who will handle your request.