Privacy Policy
Privacy Notice on Personal Data Processing
Within the meaning of Regulation (EU) 2016/679
ACTIVE ITALIAN REAL ESTATE VD S.r.l.s ., with offices in COMO (CO) Via Torriani n. 21A Tax code and VAT no. 04183310137 email address: info@activeitalianrealestate.it, PEC [certified email address]: pec_activeitaliavd@legalmail.it(hereinafter "AIREVS SRLS"), in my capacity of "Controller" (hereinafter "Controller") of your personal data (hereinafter, collectively, also "Data"), of which you are the "Data Subject" under Regulation (EU) 2016/679 (hereinafter "Regulation"), provide the following information so that you can give your specific, unequivocal, informed, free and conscious consent to Data Processing, which may be carried out also by using IT and/or electronic means.
1) Source of Data.
The data required to perform the Parties' contractual relationship and any other data otherwise acquired as part of this activity, are collected by AIREVD SRLS directly from you and/or via third parties, or are obtained by consulting external, public or private data banks.
2) Availability of the Privacy Notice.
AIREVD SRLS makes this Privacy Notice available for consultation: a) when establishing its first contact and in any case whenever it collects personal data from its Customers; b) whenever this is expressly requested to the Controller; c) through online consultation, via access to the home page of the website. www.activeitalianrealestate.it
3) Purposes of Data processing.
For business reasons, connected or instrumental to its activity, AIREVD SRLS processes your personal data for the following purposes:
a) purposes established specifically by anti-money laundering laws (Legislative Decree 231/2007, as amended and supplemented by Legislative Decree 90/2017) and, in any case, for purposes related to obligations laid down by laws, regulations and European law as well as by measures issued by Authorities authorised to do so by law or by supervisory and/or control bodies;
b) contractual purposes, connected and instrumental to the establishment and management of relationships with its customers, such as the acquisition of preliminary information for the possible conclusion of a contract;
c) measurement of customer satisfaction with regard to the quality of AIREVD SRLS's services, carried out either directly by AIREVD SRLS or via expert companies through personal or phone interviews, interactive questionnaires, market surveys;
d) promotion of AIREVD SRLS's services via the sending of advertising material, phone contacts and any other electronic communication (sending of e-mails, text messages, MMS, publications on social networks);
e) communication and/or transfer of data to third parties for the promotion and/or sale of products and services, whether by traditional and/or automated means.
With reference to the purposes referred to in points c), d) and e), please be informed that you may withdraw your consent at any time at the conditions specified in this privacy notice.
4) Nature and legal basis of Data supply.
Your supply of data may be required or optional, and your refusal to supply data may have consequences.
In this respect, please note what follows:
a) the processing of your Data for the purposes referred to in letters a) and b) of point 3 is required since it is demanded by law or is otherwise necessary to perform contractual obligations (Art. 6(1) b) and c) of the EU Regulation). Therefore, your potential refusal to consent to data processing for the purposes indicated in letter b) of point 3) will prevent AIREVD SRLS from signing or concluding the contract you are a party to;
b) your refusal to consent to Data processing for the purposes set out in letters c), d), e) of point 3 is, instead, optional, will not have any detrimental consequence and may be withdrawn at any time, with regard solely to the purposes related to the sending of advertising material, the measurement of customer satisfaction with regard to the quality of services, market surveys or commercial communications via phone calls or any other electronic communication (sending of e-mails, text messages, MMS, Whatsapp messages, publications on web sites, social networks, etc.), carried out either directly by AIREVD SRLS or via expert companies through personal or phone interviews, interactive questionnaires.
5) Special Data.
Art. 9 of the Regulation defines given special categories of Data, indicating them as all those data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation. AIREVD SRLS may acquire such data in relation to specific operations required by you. In this case, you will be asked to specifically consent to the processing of such sensitive data and AIREVD SRLS may use them only to the extent necessary to perform the services and operations requested.
6) Data storage.
Data will be kept for the time required to manage the contractual relationship and to fulfil statutory obligations, with special regard to Anti-money laundering laws. Data are always processed in accordance with the principle of data minimisation (art. 5(1) c) of the EU Regulation), whereby all personal Data and processing operations must be relevant and limited to what is necessary in relation to the purposes for which they are processed, so as to ensure their adequate security and confidentiality and also prevent any unauthorised access to and use of personal data and of the equipment used for data processing as well as to ensure their lawful and proper processing.
7) Storage period.
Pursuant to Art. 13(2) a) of the Regulation, please find below some information on the Data storage period according to the different purposes of data processing:
• with reference to letters a), b) of point 3 above, the storage period is 10 years.
• with reference to letters c) and d) and e) of point 3 above, Data are stored for the period required to manage the contract and to fulfil statutory obligations;
8) Method of Data processing.
With regard to the purposes set out in point 3 above, personal Data may also be processed by a "Processor", i.e. a natural or legal person, external to AIREVD SRLS, which may be given specific and defined duties for the management and control of data processing, and by one or more "Persons authorised to process personal data", who will materially process or use Data according to the instructions given by the Controller or the Processor (if these persons are not expressly indicated in this notice, they are to be deemed as not yet designated, and not necessarily to be designated if data processing is occasional, and their data will be provided in case of their designation).
For the purposes set out above, Data may be processed by manual, IT and/or otherwise automated means according to logics that are strictly related to the purposes of data processing and, in any case, in such a way as to ensure their security and confidentiality, even where they are processed through remote communication tools.
9) Transfer of Data abroad.
Data may be transferred to EU countries and to third party Countries (i.e. extra-EU countries) solely for the purposes set out in letters a) and b) of point 3. In this case, our intention to transfer your personal data must be previously notified to and authorised by yourself, provided a level of protection that is adequate to the European one is ensured.
10) Data communication.
By reason of our relationship and in order to facilitate and allow for conclusion of the deal, your Data may be communicated to: i) external collaborators; ii) other brokers (including companies) identified by the Controller for the purpose of collaborating in the performance of the appointment assigned by the Data Subject; iii) banks and other parties in the banking sector; iv) counterparties and their technicians and advisors; v) notaries for the purpose of drawing up notarial deeds and/or related activities connected with the appointment assigned to the Controller; vi) companies and/or professionals offering technical/cadastral/building/town-planning/legal and tax services; vii) insurance companies for the purpose of stipulating insurance policies relating to the appointment assigned to the Controller; viii) websites for real estate advertising purposes; ix) arbitration boards and, in general, all those public and private bodies to which such communication is necessary in order to duly attain the purposes indicated in point 3); x) Supervisory/Control Bodies and other Authorities, for purposes related to obligations laid down by law (anti-usury and anti-money laundering laws) and/or regulations, as well as by measures issued by the same Authorities.
All subjects falling within the categories to which your Data may be communicated, will use these Data as "controllers" within the meaning of the law or pursuant to specific consent, in full autonomy, without any connection with AIREVD SRLS 's original processing operations, or as "external processors". To learn at any time about the subjects to whom your Data are communicated, you can ask for their updated list by writing to the Data Controller atAIREVD SRLS 's offices.
Lastly, your Data will be disclosed also to all AIREVD SRLS's employees and collaborators, designated as processors and/or persons authorised to process personal data, for the performance of their duties and tasks.
The Data processed by AIREVD SRLSwill not be disseminated.
11) Rights of the data subject.
Within the limits and at the conditions set out in Art.s 15 - 23 of the Regulation, AIREVD SRLS ensures and acknowledges your exercise of the following rights:
• the right to access your personal data kept in paper and/or electronic records;
• the right to obtain the rectification, updating and erasure of data, if incomplete or erroneous, and to object to their processing on legitimate and specific grounds;
• the right to obtain without undue delay the rectification of inaccurate personal data. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement;
• the right to obtain the erasure of personal data concerning you without undue delay where one of the grounds specified in Art. 17(1) of the Regulation applies;
• the right to obtain restriction of processing where one of the conditions specified in Art. 18(1) of the Regulation applies;
• the right to data portability to the extent and at the conditions set out in Art. 20 of the Regulation.
You may also withdraw your consent at any time, without this affecting the lawfulness of processing based on consent before its withdrawal, and object at any time to data processing for marketing purposes (right to object).
You are entitled to receive information on action taken on the aforesaid requests or on the effects arising from exercise of any of the aforesaid rights, without undue delay and, in any event, within one month of receipt of the request; that period may be extended by two further months, if necessary; you also have the right toto lodge a complaint with a supervisory authority and to seek a judicial remedy.
Except where Data processing infringes the general principles laid down by the Regulation, the exercise of these rights must be relevant and reasoned and cannot imply withdrawal of consent or the request to erase Data supplied by yourself to conclude and execute the contract under point 3 a) and b), to the extent and as long as such Data are necessary for this purpose.
The rights in question may be exercised, also through a representative of the data subject, by sending a request to the Controller at the following addresses:
in COMO(CO), street Torriani n. 21A tax and VAT number 04183310137, email address : info@activeitalianrealestate.it, pec (certified email address) pec: pec_activeitaliavd@legalmail.itIn exercising your rights, you may grant a written power of attorney or proxy to natural persons, entities, associations or bodies; you may also be advised by a trusted person. To ensure the effective exercise of your rights, AIREVD SRLS will take appropriate measures aimed at facilitating access to your Data, simplifying procedures and reducing the time needed to answer your request.
Lastly, please note that you may lodge a complaint with the supervisory authority or the Personal Data Authority by:
a) registered letter with return receipt, sent to Garante per la protezione dei dati personali [Personal Data Authority], Piazza di Monte Citorio n. 121 00186 Rome;
b) e-mail to: garante@gpdp.it, or protocollo@pec.gpdp.it;
c) fax, to fax number: 06/69677.3785.
Full information on the complaints that can be lodged by you is available on the Authority's website at www.garanteprivacy.it.
The Controller
ACTIVE ITALIAN REAL ESTATE VD SRLS