Data protection

Personal data protection policy of  Impact Developer & Contractor S.A.

 

1. Our commitment to your personal data

1.1. Impact Developer & Contractor S.A., based in Bucharest, Willbrook Platinum Business & Convention Center, Building A, 1st floor, Bucuresti – Ploiesti Street, no. 172 - 176, sector 1, registered at the Trade Register with J40 / 7228/2018, fiscal code RO 1553483 ("IMPACT"), will process the personal data of the users of the websites owned by the IMPACT group, respectively www.impactsa.ro, www.greenfieldresidence.ro, www.luxuria-residence.ro, www.borealresidence.ro, according to art. 1.3 below, in accordance with its Policy for the protection of personal data (the "Policy") as well as the General Policy regarding the protection of personal data of the IMPACT group ("IMPACT Policy") of which the company is a member, according to the legislation in force. 

1.2. The policy is based on the provisions of Regulation no. 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC ("General Data Protection Regulation" or "GDPR"), which becomes effective as of May 25, 2018, as well as applicable national law.

1.3. The method of processing personal data of IMPACT is unitary within the companies of the IMPACT group, respectively BERGAMOT DEVELOPMENTS SRL, ACTUAL INVEST HOUSE, IMPACT FINANCE & DEVELOPMENTS SRL, and the group's database, including the collected personal data, which is jointly managed by the IMPACT group.

1.4. The purpose of processing the personal data is based on the main activity of IMPACT group, namely the real estate development, the construction of residential or non-residential buildings, as well as the activities auxiliary to this purpose, such as promoting the group's products and services or managing the built works.

1.5. GDPR defines personal data as "any information about an identified or identifiable individual ("data subject"); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identification element, such as a name, identification number, location data, an online identifier, or to one or more many specific elements, specific to its physical, physiological, genetic, psychological, economic, cultural or social identity”.

1.6. IMPACT is committed to implementing the highest standards of confidentiality and transparency regarding the personal data that processes it in its current activity. The total protection and transparency regarding the processing of your personal data in our activity are our most important objectives.

1.7. Please also see our Terms and Conditions available at www.impactsa.ro/legal-disclaimer explaining the use of cookies / other web tracking devices through our website, as well as our Cookies Policy. Within each of the sites for the presentation of residential complexes there will be a separate section on the protection of personal data, which you can consult.

1.8. Any information regarding the processing of your personal data can be requested at dpo@impactsa.ro belonging to the Data Protection Officer appointed in accordance with the provisions of the GDPR.

 

2. Agreement

2.1. Your use of our services is subject to the present Policy and Policy regarding cookies. By using our services, you agree to the terms of this Policy. The purpose of the Policy is to inform our clients about how we collect, store and use personal data.

2.2. If you do not agree with the Policy, please stop using our services.

 

3. Categories of personal data collected

The personal data we process as a result of your use of the website impactsa.ro and of the other sites owned by the IMPACT group may differ, depending on your quality. Thus, as a general title, we can collect and process: 

  • Information you provide to us when sending a CV to the dedicated email address for this purpose, categories of data that may include: name, first name, email address, telephone number, studies, previous experience and any other data that you you can provide us with this opportunity;
  • Information you provide to us as a result of sending a request: name, first name, email address and / or telephone number;
  • Information to which we can access through a contractual relationship between two legal entities. In this regard, with a view to the smooth running of the contractual relations, we can process personal data of the representatives and contact persons designated by our partners. These can consist of: name, first name, position, phone number and email address.

In the case of clients or potential clients, we can collect and process the following categories of data:

  • contact information, such as your first and last name, e-mail address, telephone;
  • details about the type of home you want;
  • Your IP that is processed when you contact our operator on the site;
  • details of your visits to our site (in this regard we recommend that you read the Policy regarding cookies);
  • information you provide to us through the use of the chat service;
  • we can also collect personal data necessary for the conclusion of the reservation contracts / pre-contracts / sales contracts, these may refer to: name, first name, address, personal numeric code, series and identity card number, incomes and their source.
  • other information you submit to us when making a request on the site or as a result of their transmission by email or telephone.

 

4. Ways to collect your personal data

The use of the site impactsa.ro as well as of the other sites owned by the IMPACT group, does not necessarily imply the provision of personal data. However, if you decide to provide us with personal data, we would like to explain how we process the data you provide to us.

4.1  We collect your data from an email or phone request

4.1.1. We collect personal data that refers to your name, first name, email address, telephone in order to maintain a correspondence or communication with you. Thus, if you make an application by email or telephone, we will process your data in order to resolve it.

4.1.2. In this context, if the request you have submitted needs it, we will be able to send your contact details to the financial and governmental institutions, to the transport companies or post office.

4.1.3. Except the above-mentioned situations, the data provided by you during browsing the websites managed by the IMPACT group will be used by the IMPACT group only in its own interest and will not be transmitted to third parties unless your agreement has been obtained in advance.

4.2 We collect your data coming from a request to be contacted by a consultant (through the websites corresponding to the residential complexes)

4.2.1. We collect personal data that refers to your name, first name, email address, telephone number, interest to contract (the type of home you want) and which are due to the fact that you asked to be contacted by a consultant in this meaning, filling in the fields on the site.

4.2.2. In this regard, our consultants will contact you to provide you with more information and to send you a personalized offer.

 4.2.3. If you have expressly consented that your personal data be processed for marketing purposes by the IMPACT group, respectively for sending newsletters, information about IMPACT products and services or events, contests organized by us, IMPACT will process your data for marketing purposes.

4.3. Your participation in the campaigns organized on the Instagram page, Facebook or this Site as well as on the other sites owned by the IMPACT group

4.3.1. When completing some forms of participation in the campaigns, we will collect the data as they will be defined in the Participation Regulations;

4.3.2. We can ask for your identity card in order to be legitimized in case of awarding a prize as a result of participating in the campaigns carried out by us;

4.4. Good working relationship with our partners

We may be in a position to have personal data sent to us by the representatives of our business partners. In this case, we may use the personal data you provide to us in order to manage and ensure the smooth running of the relationship between the parties. If this is the case, we may use the personal data you provide to us to evaluate the satisfaction of your business partners or for purposes related to marketing research.

 

5. The purposes for which we process your personal data

We may collect and process personal data for the following purposes:

  • offering our products and services consisting of apartment or villa dwellings in the residential complexes built by the companies belonging to the IMPACT group;
  • sending invitations for the events organized by the companies belonging to the IMPACT group;
  • compliance with our legal obligations (such as keeping the accounting records and supporting documents);
  • analyzing and improving our services and communications to you;
  • protecting security and managing access to our headquarters, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
    • in order to identify the persons authorized to trade on behalf of our customers, beneficiaries, suppliers and / or service providers;
  • sending them to third parties, if you have expressly consented to them;
  • marketing campaigns, customer surveys, market analysis, raffles, contests or other promotional activities or events, if you have expressly consented;
  • execution and management of contractual relations with our partners;
  • for any purpose related to and / or ancillary to any of the above or any other purpose for which your personal data were provided to us.

 

6. Legal grounds for processing

Regarding the legal bases of the data processing on which the processing carried out by IMPACT is based, in the context of this Site, as well as in general, they are represented by: the consent of the data subjects, the requests of the data subjects necessary to conclude contracts with IMPACT or the companies in the group IMPACT respectively BERGAMOT DEVELOPMENTS SRL, ACTUAL INVEST HOUSE, IMPACT FINANCE & DEVELOPMENTS SRL, the execution of the existing contract between the parties, the legal obligations established in the task of IMPACT, especially those regarding fiscal matters and the legitimate interest.

Regarding the legitimate interest of IMPACT with regard to data processing having this basis, we should mention the fact that it concerns in particular the processing carried out in the context of actions to promote the brand. For example, a processing based on the legitimate interest is that related to the publication of materials, especially in social media, containing images of the persons present at the events organized by IMPACT or the companies in the IMPACT group respectively BERGAMOT DEVELOPMENTS SRL, ACTUAL INVEST HOUSE, IMPACT FINANCE & DEVELOPMENTS SRL that interacts with photos. In this context, the IMPACT interest concerns the promotion of the brand by publishing images or video recordings with people present at the events. It is specified in this sense that within the social media posts made on the official pages of IMPACT will not be identified persons from registrations / posts.

 

7. Direct marketing

7.1. We promote our services to you and others. We use customer information for invitations and communications that promote the products and services we provide. To the extent that you have expressed your agreement in this regard, by ticking the box in the contact form, we will be able to use your personal data provided for the purpose of transmitting communications regarding the products and services we provide.

7.2. In all cases, you will have the opportunity to unsubscribe from receiving marketing information by accessing the unsubscribe link that you will find in each such communication.

7.3. Please keep in mind that in the case of a unsubscribe request, there may be a period of up to 48/72 hours in which you may receive further marketing information or communications, due to the changes in the system. Unsubscribing from receiving marketing emails does not prevent the further transmission of transactional emails through which we can inform you about the stage of the transaction we can conclude.

 

8. Sharing and transferring your personal data

8.1. We can provide access to the personal data you provide to companies in the IMPACT group, namely BERGAMOT DEVELOPMENTS SRL, ACTUAL INVEST HOUSE, IMPACT FINANCE & DEVELOPMENTS SRL, our authorized persons - mainly IMPACT service providers, but we will keep your personal data safe by using appropriate protection measures, according to the applicable law, to ensure the integrity and security of your personal data. Regarding the access of the other companies within the group, access will always be limited to the personal data that they may need for the provision of a service regarding you. 

8.2. We will also be able to disclose your personal data when you instruct us or give us permission to do so or when required by applicable law, requests from judicial or official bodies to do so, or to investigate fraudulent activities or criminal, effective or suspected.

8.3. We will not transfer personal data outside the EEA, unless one or more of the safeguards or specified exceptions apply to the transfer, namely a suitability decision, the Privacy Shield - Privacy Shield, mandatory corporate rules.

8.4. In the absence of an appropriate decision, the status of member of the Privacy Shield, the mandatory corporate rules, the transfer of personal data to a third country or an international organization takes place only under the following conditions:

8.5. the data subject explicitly consented to the proposed transfer, after being informed of the possible risks of these transfers for the data subject, due to the lack of an appropriate decision and the appropriate security measures;

8.6. the transfer is necessary for the execution of a contract between the data subject and the operator or for the execution of pre-contractual provisions adopted at the request of the data subject;

8.7. the transfer is necessary for the conclusion or execution of a contract concluded in the interest of the data subject between the operator and another natural or legal person;

8.8. the transfer is necessary for important reasons of public interest;

8.9. the transfer is necessary for establishing, exercising or defending legal claims; and / or.

 

9. Storage and security of personal data

9.1. Ensuring the confidentiality of the personal data you transmit to us is an important concern for us. We have implemented technical and organizational measures to maintain the confidentiality and security of your personal data, in accordance with our internal procedures regarding the storage, disclosure and access of personal data. Personal data can be stored on our personal data technology systems, those of our contractors or in printed format.

 

10. Your rights

10.1. We want to inform you that, in the new regulations regarding the protection of personal data provided by the General Regulation on data protection EU 679/2016, if we process your personal data, you have the following rights:

  • the right of access, provided by art. 15 of the GDPR, based on which you can ask us, for free, to confirm whether or not we process personal data concerning you. You can also request a copy of the data we process about you. Applications must include relevant information in order to be able to identify you in our database. We will solve your request within 30 days;
  • the right to information - implies the information in a concise, transparent and easily accessible way of the data subjects regarding the processed data;
  • the right to rectification, provided by art. 16 of the GDPR, which you can exercise, by making a request by which you can ask us to modify the information we already have about you. You can make such a request when you notice that your data is incomplete or inaccurate;
  • the right to restrict the processing, provided by art. 18 of the GDPR, which you can exercise when you dispute the accuracy of the data, consider the processing to be illegal or oppose the deletion of the data. Following the exercise of this right, we will continue to be able to store your data, carrying out other processing operations only with your consent, except as expressly provided by law;
  • the right to portability, provided by art. 20 of the GDPR, which you can exercise only in cases where the processing is based on your consent or contract and only if your data is processed by automated means. If you meet the conditions, you can send us a data porting request to the operator you want;
  • the right to oppose the processing of data for marketing purposes, provided by art. 21 of the GDPR. You may exercise this right at any time, and we guarantee that your data will not be processed for this purpose. However, there is a possibility that a reasonable timeframe (up to 72 hours) may be needed to register and process your application, in which you may receive further marketing information from us;
  • the right to delete, provided by art. 17 of the GDPR, based on which we have the obligation to delete the personal data we process about you. This right is not an absolute one, having applicability only in certain situations expressly provided by law. When making a deletion request, please bear in mind that deleting them can be a complex process
  • the right to address the National Authority for the Supervision of Personal Data, the public authority in Romania, with its headquarters in G-ral Boulevard. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania, web page http://www.dataprotection.ro, which aims to defend the fundamental rights and freedoms of individuals, especially the right to intimate life. , family and private, in connection with the processing of personal data and the free movement of these data ("ANSPDCP"), in case you notice a violation of the GDPR.

10. 2. In order to exercise these rights, please send us a written request, on the e-mail address dpo@impactsa.ro, with the subject "Requesting personal information".

10. 3. If you are not satisfied with the way we have solved your request, you can contact the National Supervisory Authority for Personal Data Processing.

 

11. Updating our privacy policy

The most recent update of the Policy was made in February 2020. We reserve the right to periodically update and modify this Privacy Policy, to reflect any changes in the way we process your personal data. or any changes to the legal requirements. In the case of any such changes, we will display on our website the modified version of the Policy and / or make it available in another way.

 

12. Contact

For further information on the content of the data protection policy, please contact us at dpo@impactsa.ro.

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