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https://www.engelvoelkers.com/it-it/italia/privacypolicy/

Privacy Policy of Engel & Völkers Italia S.r.l.

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Your partner for contractual or pre-contractual relationships.

Privacy Policy for the use of the website

This Privacy Policy applies to the use of the https://www.engelvoelkers.com/it-it/italia   website (hereinafter referred to as "website") and is effective as of 25 May 2018.

 

Engel & Völkers Italia S.r.l., with registered address at no. 16 Via Dante, 20121 Milan, Taxpayer and VAT number  07768820966, in its capacity of data Controller (hereinafter known as "Engel & Völkers" or "Controller"), hereby informs users, pursuant to Regulation EU 679/2016 (hereinafter known as "GDPR") and the applicable legislative regulations on the matter of personal data protection (hereinafter known as "Privacy Laws"), including national provisions, that data of users of its website  will be processed in the manner and for the purposes listed below.

Data subject to processing

The Controller processes the following personal data (hereinafter "Data" or "Personal Data" provided by users who access the Controller's website and/or in case a contact inquiry is forwarded to the Controller: 

●     personal data and non-confidential/specific data  (e.g. e-mail address, first name, last name, title, address, telephone number) provided by users who register on the website (e.g. contact and newsletter-related inquiries);

●     personal data transmitted by the users' internet browser each time they access the website, which are stored as log files, and also collected by means of cookies or similar technologies. This data includes: the IP address of the computer accessing the website; name of the page accessed; date and time of access; the reference URL from which the user accessed the website; the amount of data transmitted; the "login successful" status message; the session ID number.

Data Processing purposes and legal grounds

Engel & Völkers, in its capacity of data Controller, processes the personal data of its website users pursuant to the following purposes and legal grounds:

A. Without the users' prior consent, for the following Service Purposes:

A.1) to execute the contract or fulfill pre-contractual obligations, specifically:

●      to fulfill user's contact requests (e.g. handling contact inquiries and requests to receive e-newsletters with advertising information on Engel & Völkers), received through the channels at its disposal, such as via e-mail, which may be forwarded to companies in the group or licensed partners of Engel & Völkers

●      to allow users to register on the website; 

A.2) to pursue the Controller's legitimate interests, and specifically:

●      for the technical management of the website and its functionality, which include technical problem solving, statistical analysis, testing and research;

●      to analyze data from cookies – as indicated below- which track user activities on the website;

●      to prevent fraudulent activity or abuse on the website, or in connection with the website;

●      to exercise the rights of the data Controller, such as the right to defense in legal proceedings, and the management of any disputes;

●      to comply with the applicable laws, to protect the security of an individual, protect the rights and property of Engel & Völkers, to prevent intrusions, technical or security problems;

●      to verify solvency, and for fraud prevention activities;

●      to send to registered users, at the e-mail address provided, communication regarding services offered by the Controller, similar to those users already purchased. Users can unsubscribe from future offers by clicking on the link contained in each e-mail;

●      to manage contact inquiries received via the website for the purpose of identifying customers who might be interested in becoming affiliated with the Engel & Völkers network of real estate agencies operating in Italy. 

B. solely with the users' prior consent, for the following Marketing Purposes:

to inform users via regular post and/or phone calls, e-mail, SMS, MMS, notifications, newsletters or even by traditional marketing methods (e.g. mass mailings) of initiatives and promotional offers by the Controller;place ads on behalf of the Controller on real estate portals, as well as via DEM, newsletters, and event invitations;send information on initiatives and activities aimed to promote sales of affiliation licenses;send information advertising current job openings at Engel & Völkers, or licensed partners of the Engel & Völkers Group.

Provision and consequences of refusal to provide personal data

The provision of personal data is voluntary. Users are free to decide whether or not to provide personal data to Engel & Völkers, and may subsequently revoke an existing consent to process  their personal data.

The provision of personal data is however required for Service Purposes. No action will be taken to fulfill requests from users who choose not to provide personal data.

Data processing methods

The users' personal data is only processed when necessary, and solely by electronic means. More specifically, personal data is subject to collection, registration, updates, organization, storage, consultation, processing, changes, selection, extraction, comparison, use, interaction, access, transmission, blocking, erasure and destruction. Processing activities may involve both electronic and non-electronic means.

Access to data

The users' personal data may be accessed, for the purposes stated above, by:

●     employees and/or associates of the Controller and other companies in the Group, who are authorized to manage the website and provide the related services in their capacity of data processors and/or data management staff and/or system administrators;

●     employees and consultants authorized to manage the website and provide related services;

●     third-party companies (e.g. IT service providers, hosting providers, etc.) to which Engel & Völkers has outsourced services.

Disclosure of data

Data may be disclosed, even without the users' consent, to supervisory authorities, law enforcement, and judicial authorities pursuant to their explicit request. These entities will process the data as independent data Controllers for government purposes and/or law enforcement purposes as required over the course of investigations and surveillance activities. User data may also be disclosed to third-parties (e.g. partners, freelancers, agents, etc.) authorized to independently process data as needed for the above stated purposes, and more specifically whenever required to fulfill obligations or legal obligations pursuant to national and European legislative regulations and directives; to present a defense in a Court of Law, in case of disputes.

If the contact request pertains to products or services from other companies in the Engel & Völkers Group, Engel & Völkers will forward the personal data provided by the user to the appropriate company within the Engel & Völkers Group.

The user personal data will not be shared by the Controller or companies in the Engel & Völkers Group with any other party.

Transmission of data to non-EEA countries

In general, Engel & Völkers does not transmit personal data to countries outside the EEA.

The servers used by Engel & Völkers are located within the European Union.

Nonetheless, data may be transmitted to countries outside the EEA if the user request pertains to offers from Engel & Völkers companies located outside of the European Union. To ensure an adequate level of security, the transfer of personal data will be made pursuant to the provisions of the European Union, meaning by way of the Controller adopting the Standard Contract Clauses established by the European Union. 

Engel & Völkers also uses Google Analytics. Google may use the support team outside of the European Union for software maintenance, and therefore might transfer data to countries outside the EEA. Further details can be found in the analytics section.

Retention of data

Engel & Völkers stores the users' personal data for the time necessary to fulfil the purposes stated above, including any retention period applicable by law, and in any case for no longer than 2 years from the date the personal data was collected.

Use of cookies

Engel & Völkers uses cookies to improve navigation of its website. Cookies are small text files usually consisting of letters and numbers, which web browsers store on the users' own PC, and contain pseudonymized data. Cookies allow websites to recognize each user's computer, to track user searches on multiple webpages, and identify users returning to a website. There are cookies for technical, analytical and profiling purposes. By continuing to navigate our website after clicking accept on the banner, users consent to the use of cookies  for the purposes stated in this notice. Users who do not wish to allow the use of cookies can deactivate them by following the instructions listed later on in this notice.

The direct and indirect cookies used by Engel & Völkers are summarized here:

 https://www.engelvoelkers.com/en-de/privacy-policy-ag/doc/ev_cookies_lp.pdf

The website uses the following technical cookies:

To save the language selection _icl_visitor_lang_js, _icl_current_language, evlocale.

To save the selection of measurement units engelundvoelkersconfig.

To store recent search queries LAST_SEARCH.

To save the ID of the watchlist_id checklist.

To save the test assignment as part of the AB user_ab tests.

To store allocation to distributed systems in load balancers BIGipServergroup-rz-webfe-prod.

Engel & Völkers informs users that they can disable or remove cookies in their own web browser by following the instructions in the links below:

●     Internet Explorer (https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies).

●     Mozilla Firefox (https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored).

●     Safari (https://support.apple.com/kb/PH19214?viewlocale=en_US&locale=en_US).

The website also uses analytical cookies set by third parties such as Google (see also Terms of Use for Analysis Tools and Tracking Tools), Adroll (https://www.adroll.com/en-GB/about) /Privacy) and Haufe (https://en.onlinehelp.umantis.com/index.php/Cookies).

More specifically, these are:

a)      Google Analytics

Engel & Völkers uses the Google Analytics web analytics service provided by Google Inc. ("Google") to analyze the use of the web pages. Cookies-generated information regarding the use of the website pages is usually transmitted to a Google server in the United States and stored there. Engel & Völkers uses Google Analytics exclusively with the extension "ga ('set', 'anonymizeIp', true)" to ensure IP addresses are only processed in a shortened format, as to exclude any direct reference to a specific individual. Google may disclose data to third parties when required to do so by Law, or in order for third parties to process data on Google's behalf. Google will not disclose the users’ IP address in conjunction with other Google data.

Users can prevent recording and storage of data by Google Analytics at any time by installing a Google browser plug-in, which can be downloaded from the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

b)     Universal Analytics

Engel & Völkers uses the universal web analytics service by Google, which allows Engel & Völkers to record and analyze users' socio-demographic information through their Google ID (if available) and Google-generated advertising cookies (DoubleClick). If a Google ID is available, the data Controller may also collect data from all devices (e.g. if users login through both a smartphone and a PC), to analyze visitor streams across all devices.

Users can prevent Google from recording and storing data at any time by installing a browser plug-in published by Google, which can be downloaded from the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

c) Google Remarketing and Retargeting

Engel & Völkers uses the Google Analytics web analytics service, which allows users who already visited the site and shown interest in particular offers to be redirected through targeted advertising displayed on the pages of Google partner networks.  The ads are selected using cookies that analyze the users' behavior on the website to generate product recommendations targeted to the users' demonstrated areas of interest. Users can block Google Remarketing and disable the cookies used by Google for these purposes from the DoubleClick opt-out page.  Alternatively, users can block third-party cookies by accessing the Network Advertising Initiative deactivation page.

Google also allows users to set their own cookie parameters for personalized advertising:

 http://www.google.com/intl/en/policies/technologies/ads/

Social media plug-ins

This website uses social media plug-ins provided by the main social networks (e.g. Facebook and Twitter). When visiting the website, the browsing data can be transmitted directly to the respective social networks, even without direct interaction by the users. Users acknowledge and agree that the functionality of any social networking plug-in is managed directly by the company providing the plug-in in question. Users that utilize the plug-ins via the website (e.g. login with their social network credentials or link their accounts), can click on the respective button (such as “Like” or “Share” on Facebook) and connect to that specific social network server, which then sends the content of the plug-in directly to the user's browser.

Engel & Völkers therefore, in accordance with the respective terms of use and privacy policy of each social network, may receive the users' data and add it to the information already collected through its own services. Users who decide to share information with social networks effectively also share data, such as their preferences, with Engel & Völkers. To prevent social networks from collecting their personal information, users should check the terms and conditions on the social networks websites.

In particular, the website uses:

a)      Facebook

This website uses Facebook social plug-ins managed by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). If users access the Engel & Völkers pages via Facebook or vice versa, the user's browser will create a direct link to Facebook servers.

If the user is logged into Facebook, Facebook can assign the visit to the user’s Facebook account. If the user interacts with the plug-in by clicking “Like” or posting a comment, that information is transferred directly from the user's browser to Facebook and stored there. The purpose and scope of data processing by Facebook, in addition to its users' rights and privacy protection settings options, can be found in the Facebook Data Policy (https://www.facebook.com/policy.php).

b)     Google "+1"

This Website uses the +1 interface of the Google Plus social network operated by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google"). When the user presses the +1 button, the user's browser will connect directly to Google servers. The content of the +1 interface is transmitted directly from Google to the user's browser, and is integrated into the website from there. The purpose and scope of data processing by Google, in addition to its users' rights and privacy protection settings options, can be found in the Google +1 Buttons Policy (https://developers.google.com/+/web/buttons-policy).

c)      Twitter

This website uses the features of the Twitter short messaging service provided by Twitter, Inc., 795 Folsom Street, Suite 600, San Francisco, CA 94107, USA.  Twitter links the websites visited by users to their Twitter account, and makes them known to other users. During this process, data is also transferred to Twitter.

Engel & Völkers has no knowledge of the nature, content and extent of data transferred by Twitter. Users can change the privacy settings from their own Twitter account page. For more information, see the Twitter’s Privacy Policy.

To prevent social media plug-ins providers from collecting information, users can log out of the social media network at the beginning of their visit to the website, and delete any existing cookies from their browser.

Data subjects’ rights

We hereby inform you that, as the data subject, you have the right to receive information on the processing of your personal data (e.g. the origin of this data, the purposes for which it is processed, and the applicable data processing methods). You are also entitled, at any given time, to oppose processing of your data in the future, limit its processing, or demand deletion of the data. Lastly, you can prevent your data from being used for the purpose of conducting market surveys, sending you advertising or direct sales materials.

In summary, to the extent allowed by law, you have the right to

-       access information

-       rectification

-       deletion (or "purging")

-       restrict processing

-       data portability (obtain and reuse it)

-       object to the processing of your personal data

-       file a complaint with the Personal Data Protection Authorities.

When necessary, pursuant to your exercising any of the above rights, the Controller will notify any third-parties with whom the data was shared,  barring special circumstances (e.g. if notification proves impossible or requires means obviously disproportionate to the right being protected).

Methods by which to exercise your rights

To exercise the above rights and request information, users can send an e-mail  to italia@engelvoelkers.com or mail a letter to Engel & Völkers Italia Srl, Via Dante 16, 20121 Milan. By the same methods, users can revoke, correct and delete the processing of their data at any time.

Contacts

The data Controller is Engel & Völkers Italia S.r.l., Via Dante 16, 20121 Milan, Italy. An updated list of data processors is kept at the Controller's headquarters, and will be made available to you upon request.

If you have any questions about this Privacy Policy and about data protection, please contact Engel & Völkers' personal data protection officer:

Ms. Stefanie Wegener

Mittelweg 10

20148 Hamburg, Germany

Swegener@wegener-ra.de

If you wish to file a complaint regarding the way we process your information, you can do so with the Personal Data Protection Authority, at:

Autorità Garante della Privacy

Piazza Monte Citorio 121

00186 Roma

Phone: (+39) 06.696771

 E-mail: garante@gpdp.it 

___________________________________________________________________________

Privacy Policy for contractual or pre-contractual relationships.

This Privacy Notice is effective as of 25 May 2018.

 

Engel & Völkers Italia S.r.l., with registered address at no. 16 Via Dante, 20121 Milan, Taxpayer and VAT number  07768820966, in its capacity of data Controller (hereinafter known as "Engel & Völkers" or "Controller") hereby informs its contractual partners, pursuant to Regulation EU 679/2016 (hereinafter known as "GDPR") and the applicable legislative regulations on the matter of personal data protection (hereinafter known as "Privacy Laws"), including national provisions, that the personal data of its website users will be processed in the manner and for the purposes listed below.

Data subject to processing

The Controller processes personal data (identifying, financial and non-confidential/specific data) regularly collected within the scope of a contractual or pre-contractual relationship. More specifically, it includes:

●     First name, last name, company name, address (business), billing address, email address, telephone number, fax number, position, contact history, banking information, VAT identification number, contractual relationship data.

Hereinafter, this data will be referred to as “data” or “personal data”.

Data Processing purposes and legal grounds

Your personal data may be processed for the following purposes and legal grounds:

A. without your prior explicit consent, for the following Service Purposes:

A.  1) to execute the contract and/or fulfill pre-contractual obligations, more specifically:

to manage pre-contractual and contractual relationships;to execute the contract;to manage collections and payments; to negotiate new affiliation contracts via telephone and e-mail contact

A.  2) to fulfill the Controllers' legal obligations, such as:

comply with obligations set-forth by laws, regulations or national and European community legislative provisions, or standards set forth by regulatory Authorities;prepare and file tax statements and comply with the pertaining requirements;keep accurate accounting records and comply with the pertaining requirements.   

A. 3) to pursue the Controller legitimate interests, and specifically:

to exercise the Controller's rights in a Court of Law and manage any dispute; to prevent and curtail illicit activitiesto verify solvency and for fraud prevention activities

●      to send to current customers, at the e-mail address or via the telephone number provided (even after a visit to the shop or client referral between shops), communication regarding  services and products offered by the Controller, similar to those already purchased. Customers can unsubscribe from future offers by clicking on the link contained in each e-mail;

●      to search for clients who might be interested in becoming affiliated with the Engel & Völkers network of real estate agencies operating in Italy, by means of: i) networking activities (e.g. through personal contacts, acquaintances' personal contacts, contacts developed on occasion of conventions, fairs, events, etc.); the Internet (e.g. cold calling potentially interested professionals, or by sending a personalized request to connect on social media followed by a personalized e-mail presentation, maintaining the connection for future contacts, etc.);

●      to store your personal data for future contact purposes (e.g. within the CRM, Salesforce, as well as on computers or company cell phones);    

B.  solely with your prior consent, for the following Marketing Purposes:

to inform you via regular post or phone calls, e-mails, SMS, MMS, notifications, newsletters as well as by traditional marketing methods (e.g. mass mailings) of the Controller initiatives and promotional offers;advertise on behalf of the Controller on real estate portals, as well as via DEM, newsletters, and event invitations;send information on initiatives and activities aimed to promote sales of affiliation licenses;send information advertising current job openings at Engel & Völkers, or licensed partners of the Engel & Völkers Group.

Data processing methods

Your personal data is processed using electronic or paper-based means, by which it is  collected, registered, updated, organized, stored, consulted, processed, changed, selected, extracted, compared, used, interacted with, accessed, communicated, blocked, deleted and destroyed.

Sharing of data  

If your enquiry concerns products or services from other companies in the Engel & Völkers Group, Engel & Völkers will transmit the personal data you provided to the appropriate company in the Engel & Völkers Group with your prior consent.

Moreover, your personal data will only be transmitted by Engel & Völkers within the scope of the contractual relationship, with your prior consent.

Access to data

Your personal data may be accessed for the above mentioned purposes by:

●     employees and/or associates of the Controller and other companies in the Group,  in their capacity of data processors and/or data management staff and/or system administrators;

●     companies in the Group and/or third-party companies performing outsourcing activities on the Controller's behalf, in their capacity of external data processors (i.e. IT service providers, hosting providers, or delivery companies, credit institutions, professional firms, etc.);

●     third parties (e.g. consultants, website management staff, accountants, payroll and HR consultants, healthcare bodies, welfare and supplementary health insurance funds, even company owned funds, banking institutions, brokerage and management firms, employers' associations, freelance professionals, etc.) who perform outsourcing activities on the Controller's behalf, and will process the data in their capacity of external data processors.

Disclosure of data

Your data may be disclosed, even without the users' consent, to supervisory authorities, law enforcement or judicial authorities, the Ministry of Finance, the Revenue Agency, ministerial bodies and Authorities, local government entities (regional, provincial, municipal), regional and provincial tax Authorities pursuant to their explicit request. They will  process the data as independent data Controllers for government purposes and/or law enforcement purposes as required over the course of investigations and surveillance activities. Your data  may also be disclosed to third-parties (e.g. partners, freelancers, agents, etc.) authorized to independently process the data as needed for the above stated purposes.

Transmission of data to non-EEA countries

In general, Engel & Völkers does not transmit personal data to countries outside the EEA.

The servers used by Engel & Völkers are located within the European Union.

Engel & Völkers however uses the e-mail service provided by Google Ireland Limited. Within the scope of managing these products Google is also entitled to access e-mail communication systems in countries outside the EEA.  This occurs based on standard EU contracts and based on GDPR certificates of compliance. 

Pursuant to the above mentioned purposes, data might be transmitted to non-EEA countries if your request pertains to Engel & Völkers companies outside the European Union.

Retention of data

Engel & Völkers stores personally identifiable data in connection with a contract for the duration of the retention period specified in the statutory provisions, and in any case for no longer than 10 years after termination of the contractual relationship for the above mentioned Service Purposes.

For Marketing Purposes, Engel & Völkers stores your data together with the advertising information delivery receipt until revocation of your consent from Engel & Völkers, and in any case for no longer than 24 months after its collection date.

Data regarding extra-contractual relationships is retained for up to 24 months.  

Provision of data

The provision of personal data is required for Service Purposes, and necessary to establish a relationship with the Controller. You can choose not to provide your personal Data, but in that case you will not be able to establish or maintain your contractual relationship with the Controller.

The provision of data for Marketing Services is voluntary; the lack of personal data will not prevent you from using the Controller’s services. Nonetheless, if you decide not to provide your data, you will be unable to receive information on initiatives and offers from the Controller.

Data subjects’ rights

We hereby inform you that, as the data subject, you have the right to receive information on  the processing of your personal data (e.g. the origin of this data, the purposes for which it is processed, and the applicable data processing methods). You are also entitled, at any given time, to oppose processing of your data in the future, limit its processing, or demand deletion of the data. Lastly, you can prevent your data from being used for the purpose of conducting market surveys, sending you advertising or direct sales materials.

In summary, to the extent allowed by law, you have the right to

-       access information

-       rectification

-       deletion (or "purging")

-       restrict processing

-       data portability (obtain and reuse it)

-       object to the processing of your personal data

-       file a complaint with the Personal Data Protection Authorities.

When necessary, pursuant to your exercising any of the above rights, the Controller will notify any third-parties with whom the data was shared,  barring special circumstances (e.g. if notification proves impossible or requires means obviously disproportionate to the right being protected).

Methods by which to exercise your rights

To exercise the above rights and request information, users can send an e-mail  to italia@engelvoelkers.com or mail a letter to Engel & Völkers Italia Srl, Via Dante 16, 20121 Milan. By the same methods, users can revoke, correct and delete the processing of their data at any time.

Contacts

The data Controller is Engel & Völkers Italia S.r.l., Via Dante 16, 20121 Milan, Italy. An updated list of data processors is kept at the Controller's headquarters, and will be made available to you upon request.

If you have any questions about this Privacy Policy and about data protection, please contact Engel & Völkers' personal data protection officer:

Ms. Stefanie Wegener

Mittelweg 10

20148 Hamburg, Germany

Swegener@wegener-ra.de

If you wish to file a complaint regarding the way we process your information, you can do so with the Personal Data Protection Authority, at:

Autorità Garante della Privacy

Piazza Monte Citorio 121

00186 Roma

Phone: (+39) 06.696771

 E-mail: garante@gpdp.it 




Licence Partner Contact

Italia

Via Dante, 16 | 20121 Milan
Italia | P.Iva 07768820966

Italia

Via Dante, 16 | 20121 Milan
Italia | P.Iva 07768820966
Phone
+39 02 584 99 61


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