Privacy Policy

Penrose Bay helps people looking for a home in Spain find a local professional who knows the relevant area. This policy explains how personal information is handled when you use www.penrosebay.com.

Owner and data controller

The controller is Advertia LLC, which operates Penrose Bay and the Fondaro systems used to run the website and manage enquiries.

Advertia LLC

8 The Green, Suite A

Dover, DE 19901

United States

Email: hello@penrosebay.com

Information you give us

When you use a contact form, the Find Your Expert questionnaire, a property enquiry or the swipe experience, you may provide your name, email address, phone number, preferred language, message and property-search preferences. A search brief can include areas, property types, budget, bedrooms, bathrooms, features and buying timeframe. You may also identify a property or saved home you want to discuss.

The site only submits a form after its required contact statement is accepted. We record the acceptance time and the privacy-policy version with the enquiry so the contact permission can be evidenced.

If you create or use an account, Clerk provides authentication and supplies the account identifier needed to connect your account to your saved property activity. Clerk handles authentication information under its own terms as our authentication provider.

Lead and enquiry records

Submitting a form creates a lead record in Fondaro, the customer relationship system operated by Advertia LLC. Depending on the form, that record can contain your contact details, preferred language, search brief, message, submission identifier, campaign attribution, submitting page, landing page, referrer, consent evidence and relevant public property context. Property context can include a listing reference, source, URL, price and town.

The campaign attribution can include a Meta click identifier, UTM campaign values, a lead-group hint, an advertising-language hint and the time of the first attributed visit. We use this information to understand which campaign and local area relate to the enquiry and to route it correctly. The lead-group and language hints are routing facts and are kept whatever you decide about advertising; the click identifiers and campaign values are kept only with advertising consent.

The form delivery process may also send the enquiry to the Penrose Bay inbox so it can be handled without losing the request if one delivery path is unavailable. Delivery email does not contain an email tracking pixel.

Swipe identity and property discovery

You can use property discovery without creating an account. The necessary ad_swiper cookie contains a random identifier. Against that identifier, our database stores preferences, passes, matches, enquiries and a taste profile used to order the homes shown to you. The identifier in the cookie does not itself contain that history or your contact details.

A match can retain a snapshot of the public listing, including its reference, price, town, photographs and property facts. This lets a saved home remain understandable if its live listing later changes or disappears. Other visitors cannot see your swipe history or taste profile.

When you send a property enquiry, we store the contact details and message you provide together with the public property reference and context. The enquiry can also include your selected preferences and up to ten recent matched-property references and towns so the recipient can understand your search.

If you create an account, we can link the property history from that device to your Clerk account so it appears on signed-in devices. Signing out starts a fresh anonymous session on the device and does not expose the signed-in account's saved history through the old cookie.

Information collected when the site is used

Our hosting and security providers process technical request information such as IP address, requested page, browser or device details, request time and diagnostic data. We use this to serve the site, prevent abuse, enforce request limits and investigate faults. Technical logs are separate from the Fondaro lead record unless information is needed to investigate a security incident.

Necessary cookies remember consent settings, language, account session and property discovery identity. Their contents and lifetimes are described in the cookie policy.

If you allow advertising, the first-party ad_attr cookie can remember campaign and landing-page attribution for up to 90 days. The Meta Pixel can then process advertising visit and enquiry information. We run no general analytics product. These advertising measurements are used for advertising measurement and delivery only and are not sent without recorded advertising consent.

Your advertising choice is recorded with each enquiry when you submit it. Turning advertising off stops future advertising collection and, while the setting remains off, stops future submissions on that browser from being eligible for these reports, but it does not change the consent evidence already attached to an enquiry you previously sent. A previously submitted enquiry can therefore still be reported if it is later assigned, but only while both its recorded advertising-consent decision and its assignment are no more than 60 days old. After either window, it is not eligible for upload. This limit bounds the age of earlier submission evidence; it does not make a later browser choice retroactive.

Why we use information and our lawful bases

We use the information you submit to answer your request, create and manage the enquiry, understand your property search and introduce you to the relevant local professional. The lawful bases are taking steps at your request and our legitimate interest in operating a responsive introduction service.

If you ask for the guide to a home, we use your first name, email address and phone number to send you that guide and up to three short notes about the home and its town over the following two weeks, and we share those details with one local professional for that area and language, who may contact you about the home and your search. Every message carries a one-click stop link, and the notes end as soon as you use it or once the home is no longer listed. The lawful basis is your consent, recorded with the request, together with our legitimate interest in operating a responsive introduction service, and you can withdraw the consent at any time without losing the guide you already have.

We keep consent evidence, submission identifiers and delivery records to demonstrate what was requested, prevent duplicate records and maintain an accurate enquiry history. The lawful bases are our legitimate interests in accountability, service continuity and record accuracy, and legal obligation where applicable.

We use account and swipe information to provide the saved-home, matching and personalised ordering features you request. The lawful bases are providing the requested service and our legitimate interest in making it useful and consistent across visits.

We process limited technical information to secure and operate the site. The lawful bases are our legitimate interests in availability, fraud prevention and security, and legal obligation where applicable.

We process advertising attribution and allow the Meta Pixel only under the recorded advertising choice described above. You can withdraw advertising consent at any time through cookie settings. Withdrawal stops future collection and submissions from carrying a grant on that browser, but does not alter evidence frozen on a previous submission or affect processing that was lawful before it.

We do not use your information to make a decision that produces legal or similarly significant effects solely by automated means.

Who receives information

When you send an enquiry or ask to be introduced, we share the details you provide with the local professional we match you with, so they can contact you about your search.

That professional is responsible for their own use of the information after receiving it and should explain any further processing they carry out.

Advertia LLC uses Fondaro as its own lead-management system. The Fondaro lead row remains under the same controller described above.

Service providers can process information on our instructions where needed to host the site and database, authenticate accounts, deliver email, protect the service and support its operation. They may use the information only to provide those services and meet applicable legal duties.

If advertising consent is on, Meta receives the advertising information described in the cookie policy and may act as an independent controller for parts of its processing.

We may disclose information to professional advisers, courts, regulators or law-enforcement authorities where necessary to establish or defend legal rights or comply with law.

We do not sell personal information.

Property listings

The property information shown on this site comes from listing providers and participating agencies. Browsing a listing does not by itself send your contact details to the listing agency. Contact details are shared only when you submit an enquiry or ask for an introduction as described above.

International processing

Advertia LLC is established in the United States. Our providers and the local professional may process information in the United States, Spain, elsewhere in the European Economic Area or another country relevant to the service.

Where European, United Kingdom or Swiss personal information is transferred to a country without an adequacy decision, we use an appropriate safeguard such as standard contractual clauses where required. You may contact us for information about the safeguard relevant to your data.

Retention

We keep lead, enquiry and correspondence records for as long as needed to handle the property search, maintain an accurate service record, resolve disputes and meet legal obligations. We delete or anonymise them when those purposes no longer require identifiable information. You can request earlier deletion, subject to records we must retain by law or for an overriding legal claim.

The ad_swiper browser cookie lasts for up to 400 days. Swipe and account records are retained while needed to provide saved property and enquiry features and are deleted or anonymised when the identity is removed or no longer needed. The first-party advertising attribution cookie lasts for up to 90 days. Other browser lifetimes are listed in the cookie policy.

Hosting and security logs are retained for the shorter periods needed for diagnostics, abuse prevention and incident investigation. Meta, Clerk and a matched professional apply their own retention rules to information they process for their purposes.

Your rights

Depending on where you live and the law that applies, you may ask us to give you a copy of your personal information, correct it, delete it, restrict its use, object where we rely on legitimate interests, or provide eligible information in a portable format. You may withdraw consent at any time and object to direct marketing without giving a reason.

Send a request to hello@penrosebay.com. We may ask for information needed to confirm your identity. We normally respond within one month where European or United Kingdom law applies.

You can complain to the data-protection authority where you live or work. Contacting us first is optional and does not limit that right.

Children

This site is intended for adults looking for property. We do not knowingly collect personal information from anyone under 18. Contact us if you believe a child has submitted information so we can review and delete it.

Changes and contact

We publish changes on this page and identify the current version and update date at the top. If a change materially affects information already collected, we provide any notice or new choice required by law.

Questions and privacy requests can be sent to hello@penrosebay.com or posted to Advertia LLC, 8 The Green, Suite A, Dover, DE 19901, United States.