1. PREAMBLE AND CONTACT
THE USE OF THIS SITE MAY INVOLVE THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS POLICY.
The purpose of this document is to inform you about the way we process your personal data (“Personal Data”) as a result of using the website avalonestate.ro (the ”Website”) and to inform about your rights in this regard.
The controller for data collected through this Website is Prime Kapital Development SRL (the ”Controller” or ”we”), a company with headquarteres in Romania, 201 Barbu Vacarescu Street, 11th floor, District 2. Prime Kapital Development is part of a group of companies acting worldwide, MAS Group/ Prime Kapital Companies. Personal Data that may be processed through this Website are managed in our group of companies’ common information management system, based on our legitimate interest in optimizing administrative processes.
Read this Policy carefully before sending us any Personal Data, to find out how we process Personal Data and what rights you have.
For us, the security of your Personal Data is very important and we make every effort to ensure a confidential and secure framework.
If you have any questions/ complaints about the processing of your Personal Data, please contact the Data Protection Officer (”DPO”) in writting at the following contact address: firstname.lastname@example.org. The DPO can also be contacted at the Prime Kapital headquarters in Globalworth Tower, 11th floor, 201 Barbu Vacarescu Street, Bucharest, 020276, Romania.
2. HOW WE COLLECT PERSONAL DATA
Personal Data processed through our website are collected:
- directly from you (for example when you contact us through a form provided on our Website or through the contact details we indicate to you – this category also includes correspondence with you, including, but without being limited to notifications, requests, questions, etc.);
- observed by us when browsing the Website. When accessing our Website we process a series of personal data, transmitted by your browser automatically, such as:
- IP Addresses (internet protocol);
- type of browser and its version;
- type of device used and the operating system;
- date and time of accessing the Website;
- user location (according to IP address).
We use this information to help us design our website so that it best meets the needs of our users. We may also use your IP address to help us diagnose problems with our server and to manage our website, analyze trends, track visitor fluctuations and gather general demographic information to help us identify visitor preferences. These data are kept for 2 years.
Data provided by you directly:
A. When you contact us using the form provided on the website. In this case, a representative of Prime Kapital will contact you in order to provide details about Avalon Estate projects, taking into account your preferences presented in the contact form.
You can contact us through the form provided on the Website and a Prime Kapital representative will return to you by email or phone (using the data indicated in the form) to provide you with more information depending on the preferences you indicated when completing the form.
In order to contact us in this way, we will process personal data such as: name and surname, email address, telephone number and your preferences regarding the number of rooms for the apartment you are looking for (from 1 room to 4 rooms ).
The legal basis on which we contact you for a specfic offer is to take steps at your request for the execution of a contract (i.e. request for an offer). The data are processed for the purpose of sending the offer and to communicate regarding the Avalon Estate project, considering the interest shown by you.
We will keep your contact details until the building development is complete and the project you are interested in is sold, respectively until you ask us to remove you from our prospecting list.
B. Subscribing to the newsletter and other communications which promote the real estate projects of Prime Kapital Companies
This processing is optional. You have the choice whether to select the field related to this text only if you want us to keep you informed, through newsletters and other types of commercial communications, about the residential projects of Prime Kapital Companies.
The subscription to the newsletter and to commercial information takes place based on the consent given by you by checking the subscription box provided in the form. This consent can be withdrawn at any time using the instructions sent by us every time we send commercial communications.
Please note that the software we use to send newsletters and manage the subscriber database (Microsoft Dynamics) processes both individual and aggregate information about the opening rate of e-mail messages and the content with which the user interacted (links in the newsletter accessed).
Your data will be kept in our records for the transmission of commercial communications about the projects of Prime Kapital Companies until the moment you withdraw your consent. However, we reserve the right to maintain a suppression list to ensure that we do not send you commercial communications in the future.
C. When you sign up for free webinars to learn more about Avalon Estate Project
You can register, through the Website, for the webinars offered by our special guests / sales consultants, to find out more information about Avalon Estate Project (eg where the Project is, at what stage of the works it is , which are the available apartments, etc.).
In order to participate to these webinars, you must access the dedicated section („Informatii utile – Webinar”) and fill in a form on the Website with the following personal data: name, surname, email. The Personal Data are processed on the basis of our legitimate interest to contact you and to send you information regarding the Avalon Estate Project.
A link will be sent to the indicated email address to access the webinar. After accessing the link and before actually entering the webinar presentation, you will be asked to enter your name. If you do not want your image or name to appear in the recording, you can turn off your camcorder and provide a nickname when entering the webinar. These webinars are registered and sent to your email address with which you registered for the webinar and will be temporarily available on a private link on the Youtube platform.
You can also express your consent to subscribe to the newsletter by checking the appropriate box below the personal data entry fields. If you choose to benefit from this service, you will receive from us periodically newsletters and information about the residential projects developed by the Prime Kapital Companies. Whenever you wish, you will be able to withdraw this consent through the unsubscription method provided by us every time we send you a newsletter / commercial information.
D. When you contact us in any other way
You may contact us through the details provided on the Website (by e-mail, telephone or by any other forms or means provided). We will process your contact details as well as any other information you choose to provide.
We process this personal data based on our legitimate interest, in order to answer your questions and requests. We will retain this data for a maximum period of 5 years from the last interaction with you, from the final answer to the notified problem or until your request to erasure them (to the extent that the right to erasure applies).
3. TRANSFERS OUTSIDE OF THE EUROPEAN ECONOMIC AREA
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, the data you provide to us may be disclosed to companies in our group, from countries outside the European Economic Area. In this case, we will take appropriate measures to ensure that your data is used in accordance with this Policy and that the necessary security measures are taken. Such measures include, as the case, the guarantee represented by the adequacy decision issued by the European Commission or the conclusion of standard contractual clauses approved by the European Commission.
4. DISCLOSURE OF PERSONAL DATA
We may disclose your personal data to third parties who provide us with certain services that require the processing of your personal data:
(a) Companies which provide us products and services (Data Processors), such as:
i. media or marketing agencies, such as those that organize promotional campaigns, manage our website, manage the newsletter through the email (e.g., Microsoft Dynamics), other types of marketing and sales, or customer support;
ii. website services: analytics, advertising;
iii. providers of information technology and support system, including email archiving, disaster recovery and cybersecurity and recovery services.
(b) External professional consultants (eg. accountants, auditors, lawyers etc.) when their activity requires knowledge of the data or when the law requires us to disclose them.
(c) Other entities such as public authorities and institutions.
We may also disclose your personal data to other third parties:
- where you request or agree to it;
- to persons who demonstrate they are acting on your behalf;
- if it is in our legitimate interest to do so in order to manage, expand or develop the business (eg if the Prime Kapital group, or a substantial part of its assets, is acquired by a third party, in which case the personal data held by the Prime Kapital group will be one of the transferred assets);
- where we are required to disclose your data in order to comply with a legal obligation or a request from the auhtorities.
Third parties with whom we choose to share your personal data in accordance with the above are limited (by law and contract) in their ability to use personal data strictly for the specific purposes identified by us. We will always ensure that any third party with whom we choose to share personal data are subject to data protection obligations. However, for the avoidance of doubt, this may not be applicable when disclosure is not our decision (for example, whether we need to provide personal data as a result of 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 these websites.
5. YOUR RIGHTS
5.1. Right to acces
You have the right to obtain from us, based on a request made by you in this regard, information related to the personal data we hold about you, including:
- to confirm that we process or not your Personal Data;
- information related to the purpose of processing; the categories of personal data concerned; the recipients or categories of recipients to whom this data has been or is to be disclosed; the period for which this data is expected to be stored;
- if the data are not collected directly by us, any available information on their source;
- the right to obtain a copy of your Personal Data that we process. If you request other copies of your personal data, then we may charge you a reasonable fee based on administrative costs.
5.2. Right to withdraw the consent
Where you have given consent for the processing of your personal data, you may withdraw your consent at any moment.
5.3. Right to rectification
You have the right to obtain the rectification of your personal data, if inaccurate or incomplete.
5.4. Right to erasure
You have the right to request that we delete the personal data we process about you, in the following situations:
- personal data are no longer necessary for the purposes for which they were collected or processed;
- you withdraw the consent you have given us for the processing of Personal Data and there is no other legal basis for the processing;
- you object to the processing of Personal Data and there are no legitimate reasons to prevail regarding the processing;
- Personal data have been processed illegally;
- Personal data must be deleted in order to comply with a legal obligation incumbent on us.
We must comply with this request, unless the data is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation that binds us;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or
- for the establishment, exercise or defence of legal claims.
5.5. Right to restriction
You may obtain from us restriction of processing of your personal data, if:
- you contest the accuracy of your personal data, for the period we need to verify the accuracy;
- the processing is unlawful, if you request the restriction of the processing instead of the erasure of your personal data;
- we do no longer need your personal data, but you request it for the establishment, exercise or defence of legal claims; or
- you object to the processing while we verify whether our grounded reasons override yours.
In this situation where the processing has been restricted, Personal Data may, except for storage, be processed only with your consent or may be processed to establish, exercise or defend a right in court or to protect the rights of another natural or legal person from reasons of public interest.
5.6. Right to object
You may object, at any time, 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 may be exercised by sending a request in this regard to us, in writing. In the light 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 prove the legitimate grounds that bind us and an interest that prevails for processing or for the writting, exercise or defense of legal action. If you object to the processing, please indicate whether you also want your personal data to be deleted, otherwise they will be limited.
5.7. Right to lodge a complaint
If you have any complaints about the way in which we process your personal data, we would prefer that you contact us directly in order to address your problem. However, you may contact the Romanian Data Protection Authority (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal) using the information posted on their website http://www.dataprotection.ro.
- Time period: We will try to fulfil your request within one month, a period which may be extended due to specific reasons relating to the context of the situation or the complexity of your request. In all cases, if this period is extended, we will inform you about the term of extension and the reasons that led to it.
- No identification: In some cases, we may not be able to identify your personal data due to the identifiers you provide in your request. In such cases, where we cannot identify you as a data subject, we are not able to comply with your request in accordance with this section, unless you provide additional information enabling your identification. We will inform you and give you the opportunity to provide such additional details.
- Exercise your legal rights: In order to exercise your rights, please contact us in writing (including electronically) at the contact details provided below.
6. 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, in order to protect your Personal Data against unauthorized access to data, loss, destruction or accidental or intentional modification.
This Policy may be modified unilaterally by us at any time. To the extent that such a change occurs, it will be valid from the date of publication on our website of the updated version.
8. LEGAL CHANGES WITHIN THE COMPANY
In the event that any of the Prime Kapital Companies or other companies of the MAS Group will be involved in a process of 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.