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Privacy Policy

POLICY ON DATA PROCESSING THROUGH THE WEBSITE WWW.EMINESCU65.RO

 

  1. INTRODUCTION AND CONTACT

THE USE OF THIS SITE MAY INVOLVE THE PROCESSING OF YOUR DATA UNDER THE CONDITIONS DESCRIBED IN THIS POLICY.

The purpose of this document is to inform you about how we process your personal data as a result of using the website www.eminescu65.ro (the “Website”) or interacting with us through the means indicated on the Website, as well as to inform you of your rights.

The personal data controller for the data collected through this Website is RB BLUE INVESTMENTS REAL ESTATE S.R.L. – CUI 30891909 (“the Controller” or “we”), a company with its main office at Strada Ermil Pangratti, no. 10, attic, Sector 1, Bucharest and with the office in Strada Mihai Eminescu, no. 65 – 67, 1st floor, Sector 2, Bucharest. Personal data that may be processed through this website are managed in the common information management system, based on our legitimate interest in optimizing administrative processes.

Before sending us any personal data, please read this Privacy Policy carefully to find out how we process your personal data and what your rights are.

For us, the security of personal data is very important and we make every effort to ensure a confidential and secure framework for their processing.

For any questions/requests about the protection of personal data, please write to our Data Protection Officer (“DPO”) at the following contact address: office@eminescu65.ro. He can also be contacted at Strada Ermil Pangratti, no. 10, 1st floor, Sector 1, Bucharest, 011883, Romania.


  1. HOW WE COLLECT PERSONAL DATA

The personal data processed through our website are collected:

  • Directly from you (for example when you subscribe to the newsletter, when you contact us through a form provided on the Site or through other channels such as social networks (Facebook, Instagram, etc.) or through the contact details that we indicate to you – this category also includes correspondence with you, such as notifications, requests, questions, etc.).
  • Observed by us when you browse the Site. When accessing the Site, we process a series of personal data, transmitted by your browser automatically, such as:

 

  • IP addresses (internet protocol);
  • Browser type and version;
  • Type of device used and operating system;
  • Date and time of accessing the Site;
  • User location (according to IP address).

We use this information to help us design the Site to best meet the needs of our users. We may also use your IP address to help us diagnose problems with our server and to administer the Site, to analyze trends, track visitor fluctuations, and gather general demographic information to help us identify visitor preferences. This data is retained for a period of 2 years.

Data provided by you directly:

  1. When you contact us through the form provided for our representatives to contact you and send you information about the residential project, the products and services offered by us.

You can contact us through the form provided on the Site or through other channels such as social networks (Facebook, Instagram, etc.), and our representatives will get back to you by email or phone (using the data you indicated in the form) to provide you with more information based on the preferences you disclosed when completing the form.

In order to contact us in this way, we will process personal data such as: name and surname, email address, phone number and your preferences related to the project of interest (whether we are talking about purchasing or renting), the type of property desired or other services offered by us (interior design, etc.). This involves the use of your contact details (name, surname, telephone number, e-mail address) by our representatives to contact you in order to provide information on the services you can benefit from.

The basis for the processing is to take steps at your request for the execution of a contract (i.e. request for an offer/contracting a service). The data is processed for the purpose of sending the offer and communicating about the residential project, the products and services offered by us, taking into account the interest shown by you.

When you contact us by phone through the call center, we will keep the recordings of telephone conversations for 1 year from the date of the call, and the call log will be kept for 3 years from the date of the call.

We will keep your contact details in our sales and prospecting data management database for a maximum of 3 years from the date you requested information from us (the period is calculated taking into account the duration of the project’s marketing) or until you expressly request us to remove you from our prospecting list.

  1. Subscription to the newsletter and other communications promoting the residential project, our products and services

This processing is optional and depends on your freely expressed consent when you want us to keep you informed, through the newsletter, about the residential project, as well as the products and services offered by us.

Please note that for sending commercial communications and managing the customer database we use at least one software program (CRM). Through it we collect data using a tracking technology called web beacons, included in the e-mail messages sent to you, with the aim of collecting and transmitting to us information regarding the opening rate of the e-mail messages and the content with which you interact (date of access, links accessed, etc.). The purpose of this processing based on the information obtained is to adapt the marketing strategy, the recipients being not individually targeted and no individual decisions being made regarding them as a result of this processing. For more details on this processing, please contact us at office@eminescu65.ro.

Subscription to the newsletter, including the use of the tracking technology mentioned above, takes place on the basis of the consent given by you by checking the subscription box provided in the offer request form on the Site or through the specific individual subscription form. This consent can be withdrawn at any time using the instructions sent by us on the occasion of each commercial communication (for example, through the unsubscribe link included at the end of the messages or by sending a written request to office@eminescu65.ro).

Your data will be kept in our records for the purpose of sending commercial communications about our project for 8 years from the date of subscription or until you withdraw your consent by the methods indicated in the previous paragraph. However, we reserve the right to maintain a suppression list to ensure that we do not send you commercial communications in the future.

Please note – subscribing to the newsletter is different and does not depend on requesting information about a specific property or residential project. If you unsubscribe from the newsletter, you will still be contacted by our representatives, as long as you have expressed interest in our residential project and / or our products and services.

We ask customers and potential customers interested in our projects to respond to certain surveys. The response is completely voluntary, and in order to respond, the identity of the respondent does not need to be revealed. We will not seek to identify you in any way or attribute individual responses to any respondent. The answers provided are used only for statistical purposes, to conduct market research in order to improve communication and customer service, business and marketing strategy. We keep this information for a period of 3 years.

Our website also uses cookies and similar technologies, which you can read more about in our cookie policy.

 

  1. TRANSFER OF PERSONAL INFORMATION OUTSIDE THE EEA

We generally process your personal data within the EEA and do not transfer or disclose your personal data to third parties outside the EEA. However, it is possible that the information you provide to us may be disclosed to our group companies in countries outside the European Economic Area. In such cases, we will take appropriate measures to ensure that your information is used in accordance with this Policy and that the necessary security measures are taken. Such measures include, where applicable, the guarantee represented by the adequacy decision issued by the European Commission or the conclusion of standard contractual agreements approved by the European Commission.

  1. DISCLOSURE OF PERSONAL DATA

We will disclose your personal data only for the purposes and to the persons described below. We will take appropriate measures to ensure that your data is processed, secured and transferred in accordance with applicable law.

4.1 Transfer of data to affiliated entities

Your personal data may be shared with any other company that is a member of the group of companies to which we belong, if we consider this to be in our legitimate interest, for internal administrative purposes (e.g. data management in internal IT systems, dispute resolution, etc.) or for auditing and monitoring our internal processes. Access to the information is limited to personnel who need to know the personal information.

4.2 Disclosure of data to other third parties

We may also disclose your personal data to third parties who provide us with certain services that also require the processing of your personal data:

(a) Companies that provide us with products and services (processors), such as:

  • Media or marketing agencies, such as those that organize promotional campaigns, administer our website, administer the email newsletter, other types of marketing and sales or customer support;
  • Website services: analytics, advertising;
  • Information technology system providers and support, including email archiving, back-up and disaster recovery services and cybersecurity.

(b) External professional consultants (e.g. accountants, auditors, lawyers, etc.) when their activity requires knowledge of the data or when the law requires us to disclose it;

(c) Other entities, such as public authorities and institutions.

We may also disclose your personal data to other third parties:

  • If you request or consent to us doing so;
  • To persons who can demonstrate that they have the legal authority to act on your behalf;
  • Where it is in our legitimate interest to do so to administer, expand or develop our business (e.g. where the group of companies of which we are a part, or a substantial part of its assets, is acquired by a third party, in which case the personal data held by the group of companies of which we are a part will constitute one of the transferred assets);
  • Where we are under a duty to disclose your personal data to comply with a legal obligation or a request from the authorities.

(d) RB Real Estate Services S.RL. – part of the Reuben Brothers global group of companies in Romania.

Third parties to whom we choose to share your personal information as set out above are limited (by law and contract) in their ability to use your personal data strictly for the specific purposes identified by us. We will always ensure that any third parties with whom we choose to share your personal data are subject to data protection obligations. However, for the avoidance of doubt, this may not apply where disclosure is not our decision (for example, if we are required to provide your personal data in response to a mandatory request from a public authority).

Our website may contain links to other websites belonging to third parties. We do not control the privacy policies of such websites.

  1. YOUR RIGHTS

5.1 Right of access

You have the right to obtain from us, upon request, information about the personal data we hold about you, including:

  • Confirmation of whether or not we are processing your personal data;
  • Information about the purpose of the processing;
  • The categories of personal data concerned;
  • The recipients or categories of recipients to whom the data have been or are to be disclosed;
  • The period for which the data are expected to be stored;
  • Where the data are not collected directly by us, any available information about their source;
  • The right to obtain a copy of the personal data we process about you. If you request further copies of your personal data, we may charge you a reasonable fee based on administrative costs.

5.2 Right to withdraw consent

Where you have given your consent to the processing of your personal data, you may withdraw your consent at any time.

5.3 Right to rectification

You may obtain from us the rectification of your personal data if it is incorrect or incomplete.

5.4 Right to erasure

You have the right to request that we erase the Personal Data that we process about you in the following situations:

  • The Personal Data is no longer necessary for the purposes for which it was collected or processed;
  • You withdraw your consent to the processing of the Personal Data and there is no other legal basis for the processing;
  • You object to the processing of the Personal Data and there are no overriding legitimate grounds for the processing;
  • The Personal Data has been processed unlawfully;
  • The Personal Data must be erased for compliance with a legal obligation to which we are subject.

We must comply with a request for erasure that meets the conditions set out above, except where the data is necessary for:

  • Exercising the right to freedom of expression and information;
  • Compliance with a legal obligation to which we are subject;
  • To achieve purposes in the public interest, for scientific or historical purposes or for statistical purposes; or
  • The establishment, exercise or defense of legal claims.

5.5 Right to restriction of processing

You may obtain from us the restriction of the processing of your personal data in the following cases:

  • You contest the accuracy of your personal data, the restriction will take place during the period in which we verify the accuracy of these data;
  • The processing of the data is unlawful, and you oppose the erasure of your personal data, requesting instead the restriction of their use;
  • We no longer need your personal data for the purposes of the processing, but you request them from us for the establishment, exercise or defense of legal claims;
  • You object to the processing, while we verify whether our legitimate grounds override your rights as a data subject.

In this situation where processing has been restricted, personal data may, with the exception of storage, only be processed with your consent or may be processed for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person for reasons of public interest.

5.6 Right to object

You have the right, at any time, to object to the processing of your personal data, due to your particular situation, provided that the processing is not based on your consent, but on our legitimate interests or those of a third party. Your right to object can be exercised by sending us a request to this effect, in writing. For the purposes of the above, you can address a request directly to our data protection officer.

In this case, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing and an overriding interest in the processing or for the establishment, exercise or defense of legal claims. If you object to the processing, please indicate whether you also wish your personal data to be erased, otherwise they will only be restricted.

5.7 Right to lodge a complaint

If you have a complaint, please notify us first, so that we can try to remedy the situation. If we are unsuccessful, you can contact the National Authority for the Supervision of Personal Data Processing, through the procedure described on the authority’s website:

https://www.dataprotection.ro/?page=Plangeri_RGPD&lang=ro  

Note:

  • Time period: We will try to resolve your request within one month, which may be extended for specific reasons related to a particular legal right or the complexity of your request. In all cases, if this deadline is extended, we will inform you of the duration of the extension and the reasons for it.
  • Lack of identification: In some cases, we may not be able to search for your personal data due to the identification elements you have indicated in your request. In such cases, where we cannot identify you as the data subject, we cannot comply with your request to exercise your legal rights described in this section unless you provide us with additional information that allows you to be identified. We will inform you and give you the opportunity to provide such additional details.
  • Exercise of rights: To exercise your rights, please contact us in writing (including electronically) at the contact details provided in the section below.
  1. CONFIDENTIALITY AND SECURITY

The protection of your personal data is very important to us. We will take all necessary security measures to protect your data against unauthorized access to data or unauthorized modification, disclosure or destruction of data. This involves internal reviews of data collection, storage and processing practices and security measures, as well as physical security measures to protect against unauthorized access to the systems where we store personal data.

We have implemented technical and organizational security measures to protect your personal data against unauthorized access to data, accidental or intentional loss, destruction or modification.

  1. AMENDMENT OF THIS POLICY

This Policy may be modified unilaterally by us at any time. To the extent that such a modification occurs, it will be valid from the date of publication of the updated version on our website.

  1. LEGAL CHANGES WITHIN THE COMPANY

In the event that any of our group companies are involved in a reorganization, merger, acquisition or any other change of control over us or transfer of assets, your personal data may be transferred as part of that transaction.

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