Internal Information System Policies

The Internal Information System of LIVINGPALMA REAL ESTATE SERVICES, S.L.U. is the channel to confidentially and effectively communicate any information about irregularities committed by LIVINGPALMA REAL ESTATE SERVICES, S.L.U. or its personnel, which have been known within the framework of an employment or professional relationship maintained with our organization in accordance with the provisions of Law 2/2023, of February 20.

The organization has configured the internal information system through the following channels:

• In writing:
  • Through email: This email address is being protected from spambots. You need JavaScript enabled to view it.
  • By postal mail, addressed to the Responsible for the internal information system of the organization LIVINGPALMA REAL ESTATE SERVICES, S.L.U. at C/ Josep d´ Oleza 4, local 15, 07010, PALMA, BALEARES.
• Verbally:
  • At the request of the informant, information may also be provided through a face-to-face meeting with the Responsible for the System within a maximum period of seven days from the submission of the request.

-In addition to these channels, communications can be made to external information channels of competent authorities.

-Once the complaint is received, the person responsible for the internal information system will acknowledge receipt of the complaint to the complainant within a period of less than 7 days, in cases of nominal complaints. In any case, the complainant will be informed of the rights and obligations established by the personal data protection regulations.

-The person responsible for the internal information system will issue a reasoned report that will either uphold or dismiss the communication filed, justifying, in any case, the decision taken. The report will be notified to the informant and the affected person within a maximum period of 3 months from the expiration of the seven-day period after the communication is made, except in cases of special complexity that require an extension of the period, in which case, it may be extended for up to an additional three months.

-During the processing of the complaint, communication and contact with the informant/complainant may be maintained, and if deemed necessary, additional information may be requested from the informant.

-It is ensured that the person affected by the information or complaint is informed of it, as well as of the facts reported briefly. Additionally, they will be informed of their right to submit written allegations and the processing of their personal data. However, this information may be provided during the hearing procedure if it is considered that their contribution beforehand could facilitate the concealment, destruction, or alteration of evidence.

-The person responsible for the internal information system/channel of complaints guarantees confidentiality to all those who use the internal information system/channel of complaints. Furthermore, confidentiality will be guaranteed when the communication is sent through complaint channels other than those established or to personnel members not responsible for their processing.

-During the processing of the file, the persons affected by the communication will have the right to the presumption of innocence, the right to defense, and the right to access the file, as well as the same protection established for informants, preserving their identity and guaranteeing the confidentiality of the facts and data of the procedure.

-The processing of personal data derived from the application of this procedure will be governed by the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, Organic Law 7/2021, of May 26, on the protection of personal data processed for the purposes of prevention, detection, investigation, and prosecution of criminal offenses and the execution of criminal penalties.

-The person responsible for the internal information system/channel of complaints will immediately forward the information to the Public Prosecutor when the facts could be indiciarily constitutive of a crime or to the European Public Prosecutor's Office, in the event that the facts affect the financial interests of the European Union.

-The organization guarantees the absence of reprisals against anyone who informs it of a possible illicit conduct or has reported a regulatory breach or collaborates in its investigation or helps to resolve it.

-Persons who report or disclose infractions covered in Article 2 of Law 2/2023, of February 20, and actions or omissions that may constitute a serious or very serious criminal or administrative offense, shall be entitled to protection measures provided that the conditions set out in Article 35 of the aforementioned regulation are met. Protection measures are set out in Article 38 of Law 2/2023, of February 20.

-The complaint or information will be kept in the organization's premises in accordance with its document filing and retention policy.

-The organization maintains a register of all complaints received. Complaints will be kept only for the period necessary and proportionate to comply with the requirements imposed by Law 2/2023, of February 20, regulating the protection of persons reporting regulatory infringements and combating corruption, and in accordance with the provisions of Article 24 and other applicable articles of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights.