PURSUANT TO ART. 13 AND 14 OF THE EUROPEAN REGULATION ON THE PROTECTION OF PERSONAL DATA (GDPR)
The security and protection of your personal data is important for RE ITALY (hereinafter Italy Sotheby's Int. Realty), which acts in accordance with the laws currently in force regarding the protection and the security of personal data. We trust that the information below will help you understand what kind of data Italy Sotheby's Int. Realty collects, how we use the data, how we safeguard them and with whom we share them.
Pursuant to Articles 13 and 14 of EU Reg. 679/2016 (hereinafter also referred to as the "Privacy Regulation"), we therefore wish to inform you that your personal data will be processed in accordance with the principles of correctness, lawfulness and transparency, and by protecting your confidentiality and your rights, in compliance with the current legislation on security and protection of personal data.
In particular, we inform you of the following:
a. Source of personal data and type of data processed
No registration is required to access the Site. However, there are some sections within the Site that require you to provide personal information for the only purposes of being able to receive services, such as subscribing to the newsletter, for contacting us, and for sending marketing communications and invitations to events.
With reference to the data relating to navigation within the Site, see also point 6 below concerning the profiling tools used by the Site.
The personal data in our possession are those provided by you when you access the website https://www.italy-sothebysrealty.com/it/ and its pages, as well as when you submit a request for information and/or when you request to subscribe to our newsletter service via the dedicated pages and checkboxes.
All personal data will be processed in compliance with the Privacy Code, the "Privacy Regulations", the provisions of the Guarantor for the protection of personal data and the confidentiality obligations that have always inspired the activities of our company.
b. Legal basis and Purposes of processing
The purposes for which your data will be processed by us are as follows:
1. Management of connection and navigation data
The legal bases for such processing are:
1) the execution of pre-contractual measures taken at your request, pursuant to Art. 6, para. 1, lett. b) of the "Privacy Regulation".
2) to meet legal obligations to which the data controller is subject, pursuant to Art. 6, paragraph 1, letter c) of the "Privacy Regulation".
3) to pursue the legitimate interest of the data controller pursuant to Art. 6, paragraph 1, letter f) of the "Privacy Regulation".
The data relating to connection and navigation within the Site (such as the URI-Uniform Resource Identifier addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other settings relating to the user's operating system and computer environment) are collected for the only purpose of obtaining anonymous statistical information on the use of the Site and to check its correct operation, and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Site: to the exclusion of this eventuality, the data will be deleted after the time required to provide the services illustrated on the Site has elapsed.
2. Processing requests and sending proposals and commercial communications
The legal basis for such processing is the execution of pre-contractual measures taken at your request, pursuant to Art. 6, paragraph 1, letter b) of the "Privacy Regulation", at the time your data is entered and the information request form is submitted by you.
By processing the data provided by you, we will be able to reply to your requests sent to us by the website https://www.italy-sothebysrealty.com/it/ regarding the search for buying/selling/renting property. On the basis of your requests we will respond with commercial communications relating to your enquiries..
3. Newsletter subscription
The legal basis for such processing is your explicit consent, pursuant to Art. 6, para. 1, letter a) of the "Privacy Regulation".
After collecting your consent in this matter and the data provided by you, we may send you our Newsletter, which is sent by automated means. To allow us to properly manage our Site and the Newsletter service you have requested, your personal data may be transferred to countries outside the European Union where the companies that provide these services are located.
4. Invitations to Events
The legal basis for such processing is your explicit consent, pursuant to Art. 6, para. 1, letter a) of the 'Privacy Regulation'.
Subject to your prior consent, by processing the data provided by you, we will be able to send you information regarding news about our Company, as well as invitations to exclusive corporate events in which we would like you to participate, that will be sent - also by automated means - by e-mail or post. Even if you have given your consent, you may revoke it at any time by making a request to Italy Sotheby's Int. Realty in the manner set out in point i below.
You may also easily oppose further mailings by exercising your so-called right to opt-out, through the modalities present in each type of communication with which the marketing communications in question are sent.
Once your consent has been revoked, you will receive confirmation of receipt of such revocation communication from Italy Sotheby's Int. Realty.
Italy Sotheby's Int. Realty informs you, however, that, even after the exercise of such right of revocation, it is possible that, for technical and operational reasons (e.g. the formation of contact lists already completed shortly before the receipt by Italy Sotheby's Int. Realty of the revocation itself), you will continue to receive certain further communications. Should you continue to receive Marketing communications from the exercise of the above right, please report the problem to Italy Sotheby's Int. Realty, using the contact details set out in point i below.
c. Profiling and/or personalisation tools
Italy Sotheby's Int. Realty does not perform any profiling activities without the prior express consent of the user.
The Site uses "cookies", both technical (i.e. to facilitate navigation and use of the Site) and profiling (i.e. to analyse users and their behaviour and preferences, and thus customise the browsing experience).
d. Treatment methods
The data will be processed manually or electronically, in such a way as to guarantee their security in relation to the purposes for which they were communicated and collected, and to prevent unauthorised access by third parties and, in any case, in compliance with national and European legislation. The processing is carried out by the Data Controller, by the Data Processors and by the persons assigned to the processing for this purpose.
e. Nature of assignment
The provision of data in relation to the purposes set out in point b1. is compulsory as it is a necessary requirement in order to be able to respond to your requests and in the event of failure to provide such data, the consequences of your refusal will be that you will not be able to receive information relating to the information you have requested and for which you have expressed an interest.
The provision of data in relation to the purposes set out in points b.2 and b.3 is optional, but is a necessary requirement in order to be able to receive marketing communications/invitations to events and the Newsletter from Italy Sotheby's Int. Realty. We invite you not to provide, during the use of interactive services, sensitive data, i.e. data from which it may be possible to identify, by the way, your racial or ethnic origin, religious beliefs, political opinions, membership of parties, trade unions, associations and organisations of a religious, philosophical, political or trade-unionist character, as well as your state of health. Any sensitive data provided will be deleted immediately.
f. Authorized persons to process and communication of data
Your personal data may be disclosed to employees engaged to perform for Italy Sotheby's Int. Realty the activities necessary to achieve the purposes of the processing referred to in paragraph b. (b.1), (b.2) and (b.3) above.
Suppliers of IT and logistics services functional to the operation of the site, suppliers of outsourced services, professionals and consultants, companies entrusted with the sending of commercial e-mails or communications on Events or the Newsletter (where you have consented to this) may also become aware of them.
Such persons, formally appointed by Italy Sotheby's Int. Realty as Persons authorized, the Data Processors and/or System Administrators, shall process your data in compliance with and exclusively for the purposes indicated in this policy and under the control and supervision of Italy Sotheby's Int. Realty itself. The complete and updated list of the persons to whom your data have been communicated may be requested from the Data Controller, whom you may contact by writing to the e-mail address indicated in point i.
Your personal data may also be shared with the Companies of the Italy Sotheby's Int. Realty Group for the contractual and pre-contractual purposes referred to in point b.1.
g. Data Dissemination
Your personal data will not be disseminated by the data controller.
h. Transfer of data outside Europe
Your personal data may be transferred abroad to countries that are not Members of the EEA (European Union, Iceland, Liechtenstein and Norway) and, in particular, to the companies that provide basic services for the operation of the site, for managing the application systems and for managing the sending of the Newsletter, on the basis of a contract of appointment and definition of the security measures necessary for the transfer of data from the Data Controller to the Processors with the consequent guarantee of data processing in compliance with European standards. External Processors may process personal data coming from Italy Sotheby's Int. Realty only on the basis of instructions provided by the Data Controller and indicated in the deeds of appointment stipulated between the Data Controller and the Processors
i. Rights of the data subject
▪ Finally, we would like to inform you of the possibility of exercising the rights granted to you by law at any time, which are set out below:
▪ access to the data provided;
▪ obtain the rectification of the data provided, their deletion, transformation into anonymous form, the blocking of data processed in violation of the law or the restriction of data processing concerning you;
▪ object to data processing;
▪ revoke your consent;
▪ obtain portability of your data;
▪ obtain confirmation as to whether or not your data is being processed, know its content and source, check its accuracy or request that it be supplemented or updated, know the purposes and methods of data processing, the logic applied in case of processing by electronic means, the identification data concerning data controller, data processors, data processors and the DPO, if one is appointed
▪ lodging a complaint with the supervisory authority (Privacy Guarantor);
▪ object to an automated decision-making process concerning natural persons, including profiling;
▪ obtain, without undue delay, notice of a breach of your personal data.
▪ obtain a copy of the data being transferred countries outside the EEA, as well as the place where it is made available
Requests should be addressed
j. Period of data retention
The data provided by you in relation to purpose b.1) above shall be kept for the time necessary to process your request for information and, thereafter, for the time necessary for the performance of the contract, if one is concluded, following your request for information. Only in the event that you, by making an enquiry to our company, have also given your consent in relation to the purpose b.2 above, your data will be kept for a maximum period of five (5) years from the last contact and unless you request early deletion.
The data provided by you in connection with purpose b.3 above shall be retained for the duration of your subscription to our Newsletter service or - in any event - until you revoke your consent (which can be requested at any time, including by using the link provided in all of our Newsletters); thereafter, the data shall be deleted or anonymised.
l. Data controller
The Data Controller is RE ITALY S.r.l., in the person of its legal representative pro tempore, Piazza G Mazzini 27 - 00195 Rome - operational headquarters via Manzoni 45, 20121 Milan, e-mail: firstname.lastname@example.org