Privacy Policy

This Privacy Policy explains how Grupo Nordic Spirit, S.L., trading as Choice Direct, collects, uses, stores, and shares personal data when you use our website, platform, and related services.

Co Owner and operational contact

Antonio Lucas da Silva Ribeiro

Antonio Lucas da Silva Ribeiro is responsible for the day to day running, development, and growth of the business. He has built the Choice Direct platform and leads its ongoing improvement, website infrastructure, service coordination, partner communication, and business relationships with collaborating companies. He also plays a key role in establishing partnerships and shaping the future direction of the platform.

Co Owner and strategic leadership

Odd Harald Sørhaug

Odd Harald Sørhaug is Co Owner of Choice Direct and provides the broader strategic direction of the business. With more than 20 years of experience in the international real estate market, he brings long term vision, commercial insight, and a strong focus on trust, clarity, and reliability. His work helps shape the company’s strategic foundation, professional network, and long term growth in Spain.

For privacy related questions or to exercise your data protection rights, you can contact us at: [email protected]

This Policy applies to personal data processed through our website and services, including when you:

• visit our website
• contact us
• create an account
• submit a seller request
• apply to collaborate as an agency or business partner
• sign or accept agreements electronically
• interact with matched parties through our platform or service communications

Depending on how you use our website or services, we may collect and process the following categories of personal data:

Identity and contact data
Name, company name, role, email address, telephone number, billing details, office address, and related contact details.

Account and profile data
Login details, account preferences, language preferences, service areas, business profile information, company description, logo, website, and other information submitted as part of an agency or partner profile.

Seller and property related data
Information submitted by sellers or property owners, such as contact details, preferred language, property location, property details, and information relevant to a sale request.

Matching and transaction data
Information needed to match sellers with agencies or partners, records of introductions, match history, contract status, fee related events, communications, and transaction progress where relevant to the service.

Technical and usage data
IP address, browser type, device information, login events, session data, pages visited, and basic website analytics or security logs.

Communications data
Messages sent to us, support requests, emails, forms, and records of business communications with users, agencies, and prospective partners.

We collect personal data:

• directly from you when you complete forms, register, contact us, sign agreements, or use the platform
• from your use of the website through cookies and similar technologies
• from agencies, sellers, or business partners as part of the matching and transaction process
• from publicly available business sources, directories, websites, or referrals where relevant to building or operating our partner network and where permitted by applicable law

We process personal data for the following purposes:

To operate the website and platform
To provide and maintain our website, accounts, forms, and related digital services.
Legal basis: legitimate interests in operating and securing our website and services, and where applicable, performance of a contract.

To create and manage user accounts
To register users, allow log in, manage profiles, and provide access to relevant platform features.
Legal basis: performance of a contract or taking steps at the request of the data subject before entering into a contract.

To process seller requests and partner applications
To review submitted information, assess suitability, and operate our matching process.
Legal basis: performance of a contract, pre contractual steps, and legitimate interests in running and improving our service.

To match sellers with agencies or other suitable partners
To identify and present relevant agencies or business partners based on factors such as location, service area, language, and the needs of the seller.
Legal basis: performance of a contract, pre contractual steps, and legitimate interests in facilitating relevant matches and operating the service.

To display agency or partner profile information to matched sellers
Where an agency or partner joins our network or accepts our collaboration terms, we may display and communicate business profile information to matched sellers to facilitate the match and contact process. This may include business name, logo, website, office address, service areas, languages, profile description, business email address, and business telephone number.
Legal basis: performance of a contract, pre contractual steps, and legitimate interests in delivering the matching service.

To communicate with users, agencies, and partners
To respond to questions, send service messages, provide updates, manage onboarding, and support the relationship.
Legal basis: performance of a contract, pre contractual steps, legitimate interests, and where required by law, consent.

To manage agreements, referrals, fees, and compliance
To record acceptance of terms, manage introductions, verify referral events, issue invoices, prevent circumvention, and comply with applicable legal obligations.
Legal basis: performance of a contract, legal obligation, and legitimate interests in protecting our business and enforcing our contractual rights.

To improve website performance and security
To monitor performance, protect against fraud, abuse, unauthorised access, and misuse of the platform.
Legal basis: legitimate interests and, where required for non essential cookies or technologies, consent.

To send business communications about potential collaboration
Where permitted by applicable law, we may process professional or business contact details to assess or initiate potential collaborations with agencies or other property related businesses.
Legal basis: legitimate interests and, where required by applicable law, consent or another valid legal basis.

A core part of our service is introducing sellers to relevant agencies or other property related businesses.

If an agency or partner joins our network or accepts our collaboration terms, we may make certain business profile information visible to matched sellers through our website, platform, email, dashboard, or other service communications.

This may include:

• business name
• brand name
• logo
• website
• office location or business address
• service areas
• languages
• business description
• business contact email
• business contact telephone number

We aim to display business contact details rather than personal private contact details unless personal contact details have been provided for that purpose and may lawfully be used.

We may share personal data with:

• matched sellers, agencies, or partners where necessary to provide the service
• service providers who help us operate the website, hosting, email, analytics, CRM, support tools, forms, contracts, or security systems
• professional advisers, accountants, legal advisers, auditors, or insurers where necessary
• public authorities, regulators, courts, or law enforcement where required by law
• business partners or counterparties where necessary for the operation of the service or the performance of agreements

We do not sell personal data.

If we use service providers located outside the European Economic Area, or if personal data is accessed from outside the EEA, we will take appropriate safeguards as required by applicable data protection law. This may include adequacy decisions, Standard Contractual Clauses, or other lawful transfer mechanisms.

We keep personal data only for as long as necessary for the purposes described in this Policy, including for legal, accounting, compliance, dispute, and evidential purposes.

Retention periods may vary depending on the type of data. In general:

• website enquiry and contact data are kept for as long as necessary to handle the enquiry and any follow up
• account and profile data are kept while the account or collaboration remains active and for a reasonable period afterwards
• seller, agency, partner, matching, contract, and transaction related records may be kept for as long as needed to operate the service, enforce agreements, manage disputes, and comply with legal obligations
• technical logs and security records are kept for as long as reasonably necessary for security, troubleshooting, and audit purposes

Where no longer needed, data will be deleted, anonymised, or securely archived as appropriate.

We use cookies and similar technologies to operate the website, remember preferences, support login functionality, analyse website traffic, and improve performance.

Some cookies may be strictly necessary for the website to function. Other cookies, such as analytics, measurement, advertising, or personalisation cookies, may require consent depending on how they are configured and used.

You can manage cookies through our cookie banner, settings tools, or your browser settings. For more detailed information, please see our Cookie Policy.

Depending on the circumstances and the applicable law, you may have the right to:

• request access to your personal data
• request rectification of inaccurate personal data
• request erasure of your personal data
• request restriction of processing
• object to certain processing
• request data portability where applicable
• withdraw consent where processing is based on consent
• lodge a complaint with the Spanish Data Protection Authority, Agencia Española de Protección de Datos, if you believe your rights have been violated

To exercise your rights, contact us at: [email protected]. We may need to verify your identity before processing your request.

In some cases, especially in relation to agencies, business contacts, or collaboration opportunities, we may obtain professional or business related contact data from publicly available sources, referrals, business directories, company websites, or other lawful sources.

Where required by law, we will provide the information required when data has not been obtained directly from the data subject.

We take appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure. However, no internet based service can be completely secure, so we cannot guarantee absolute security.

Our website and services are not intended for children, and we do not knowingly collect personal data from children in connection with our business services.

Our website may include content, plugins, forms, maps, videos, analytics tools, or links provided by third parties. These third parties may process personal data in accordance with their own privacy policies. We encourage you to review the privacy notices of those third parties where relevant.

We may update this Privacy Policy from time to time to reflect changes in our services, legal obligations, or operational practices. The latest version will always be published on this page with the updated effective date.

If you have questions about this Privacy Policy or our handling of personal data, please contact: