Privacy Policy

An important piece of information to note initially:

You can, at any time in whole or part, revoke your consent as well as any other settings you set when visiting our website www.engelvoelkers.com and all its associated subpages (hereinafter referred to collectively as our "Website") via the consent management platform of Didomi SAS. To do this, please use the menu item "Manage cookie settings" at the bottom of the Website. Information, in this context, on the use of cookies and other tracking technologies (“trackers”) as well as the processing of personal data in that regard, the consent therein and possible revocation can be found in our "Cookie Policy".

This Privacy Policy is valid from 27th February 2024.

I. Responsible entity (“Controller”) and your rights as the data subject

1. Responsible entity

EV MMC Italia (hereinafter also referred to as "Engel & Völkers" or "we" or "us") is responsible for the data processing governed by this Privacy Policy. Our contact details are:

Engel & Völkers Italia S.r.l.
Via Dante, 16
20121 Milano
Tel.: +39 025849961
E-Mail: italia@engelvoelkers.com

Jointly responsible for the data processing as described in our Cookie Policy are:

Engel & Völkers GmbH
Vancouverstraße 2a
D-20457 Hamburg
Germany
E-mail: contact@engelvoelkers.com

and

Engel & Völkers Technology GmbH
Vancouverstraße 2a
D-20457 Hamburg
Germany
E-mail: contact@engelvoelkers.com

Please note:

The responsibility for the data processing, respectively in connection with the company web presences of the licence partners of the Engel & Völkers Group (hereinafter the "Company web presences") which can also be accessed via our Website rests with named licensees. They are, in this context, responsible for data processing such as contact enquiries and, in particular, for data processing in connection with the search or sale/rental and valuation of properties.

The current overview of these licence partners can be found here: https://www.engelvoelkers.com/it/en/shops/

Unless otherwise stated, our licence partners are legally and commercially independent companies and are not part of the Engel & Völkers group of companies. When we refer to the "Engel & Völkers Group" in this Privacy Policy, we refer to the companies belonging to the Engel & Völkers group of companies pursuant to §§ 15 et seq. of the German Stock Corporation Act (AktG) (hereinafter referred to as the "Engel & Völkers Companies") as well as the (master) licence partners which are by contract directly or indirectly linked to this group of companies. When we refer to "Engel & Völkers", we refer to the companies listed in section I 1 of this Privacy Policy.

To find out which licence partner is responsible for the data processing of the company web presence that you are currently visiting, please refer to the respective data protection notices respectively the imprint at the bottom of the company web presence in question.

2. Data Protection Officer

If you have any questions about this Privacy Policy and data protection in general within the Engel & Völkers group of companies, please contact Engel & Völkers’ external data protection officer:

Dr Stefanie Wegener
Mittelweg 10
20148 Hamburg, Germany
swegener@wegener-ra.de

3. Your rights as a data subject

You may exercise your data protection rights against EV MMC Italia insofar as the Engel & Völkers companies are jointly responsible for data processing in connection with our website. The Engel & Völkers Companies have agreed to this.

You have the following data subject rights:

You have the right to information about the processing of your personal data (for example, the origin of this data, the purpose of processing, and the modalities of data processing). Furthermore, under certain conditions, you are entitled to object to the future processing of your data, as well as the right to restrict the use or the deletion of said data. Finally, you may at any time stop the sending of advertising material or the execution of market research or commercial communications.

In summary, you have a right to:

• Information,

• Correction,

• Deletion (or request to be forgotten),

• Restriction of processing,

• Data portability,

• Object to the processing of your personal data,

• Complaint to supervisory authorities.

In addition, you have the right, at any time, to object to the processing of your personal data for direct marketing purposes. If you object to the processing for direct marketing purposes, we will no longer process your personal data for these purposes.

According to Art. 7 III of the EU General Data Protection Regulation (hereinafter "GDPR"), you may at any time revoke your initial consent towards us. Once the consent is revoked we will no longer continue to process the data.

Please note that your right to the deletion of your data is subject to certain restrictions. For example, we do not have to or are not allowed to delete data that we are required to retain due to legal retention periods. Data that we need to assert, exercise or defend due to legal claims are also excluded from your right of deletion.

If you have a complaint about the way we process your data, you have the recourse to a supervisory authority, in particular in the member state of your residence, workplace or the place of the alleged breach.

We reserve the right to disclose information about you if we are required to do so by law enforcement bodies or other lawful authorities. Legal basis: Art. 6 I sentence 1 lit. c GDPR (legal obligation).

Overview of our data processing procedures

Our Privacy Policy is structured as follows and provides you with an overview of the following data processing procedures:

I. You visit our company web presence on the Internet

II. You conclude a search request; or marketing contract with us, request an exposé from us or commission us to carry out a property valuation.

III. We search for a property for you together with another Engel & Völkers licence partner (Referral)

IV. You manage our newsletters in your Engel & Völkers user account

V. You communicate via Whatsapp with us or use our Whatsapp-Newsletter

VI. You apply at your own initiative or in response to a job advertisement

VII. Storage and deletion of your data

I. Collection and processing of personal data when visiting our Website

We only process personal data if the personal data is sent to us via the contact forms on our company web presence. In this regard, personal data is only processed once explicit consent has been given to us for the processing of your data or if the processing is permitted by legal regulations. For certain services that we offer on our company web presence, we require a minimum amount of data. We have marked mandatory information with an "asterisk". Without the mandatory information, we are unable to provide our services.

1. What data do we process from you (hereinafter referred to as "you" or "user")?

When you use our Website, we process personal data, in particular:

• The e-mail address, first name, last name, title, address, telephone number, property data, participation in events and webinars, hereinafter referred to as "data" or "personal data", provided to us by you in the event that you use individual services offered by us or an Engel & Völkers Company via our Website (e.g. in the context of contact enquiries, newsletter mailings, webinars as well as the market price determination of properties); mandatory fields are marked with an "asterisk" or optional fields with "(optional)";

• Personal data (also hereinafter referred to as "user data") transmitted by the user's internet browser each time they access the Website and stored as part of log files, also known as server log files. This data includes: the IP address (Internet Protocol address) of the accessing computer; the name of the accessed page; date and time of access; URL from which the user accesses the page; the volume of data transmitted; status message for successful access; session ID number;

• Personal data in the form of location data (GPS data, so-called "Locate Me" function), which is transmitted by your Internet browser each time you have activated this setting on the browser by default or application-based.

2. Purpose of the processing

We process the personal data of the users of our Website for the following purposes:

• Provision of online offers for own and third-party advertising (legal basis is the legitimate interest of Engel & Völkers in marketing its own services as well as the services of the companies of the Engel & Völkers Group as described above);

• Fulfilment of user contact requests to the Engel & Völkers Group (legal basis is the fulfilment of the contract as well as, in the event of the user data being passed on, your consent or the legitimate interest of Engel & Völkers to pass on contact or service requests within the Engel & Völkers Group to the relevant (licence partner) company of this Engel & Völkers Group which is responsible in terms of expertise and/or geographical location;

• If applicable, for the purpose of fulfilment of a valuation request of the property as described by the user, as well as the implied interest in the sale of the property as submitted by the valuation request (The legal basis is (a) the fulfilment of the contract as well as, (b) your consent in the event that we need to share your contact data with (i) a suitable licence partner of the Engel & Völkers Group based on expertise or geographical location (for the definition, please see section 3 below)) or (ii) to the company technically implementing the evaluation and (c) the legitimate interest in marketing our services or your consent in the case of the use of your contact data for direct marketing);

• The organisation of webinars (legal basis is the fulfilment of the contract by Engel & Völkers and, in case your contact details are passed on to the lecturer, your consent);

• Contact by telephone by Engel & Völkers or the Engel & Völkers Group (legal basis is the fulfilment of the contract or, in the case of the use of the telephone number for advertising purposes, your consent);

• Sending out an e-mail newsletter by Engel & Völkers or the Engel & Völkers Group containing our offers as well as self and third-party advertising to the extent permitted by law or based on the consent given (the legal basis is either your consent or Engel & Völkers´ legitimate interest in direct marketing, as long as the marketing is carried out in compliance with data protection and competition law requirements of the applicable national regulations);

• For the optimisation and operability of the Website (legal basis is the legitimate interest of Engel & Völkers to constantly improve the quality of the Website and to ensure ease of use);

• If necessary, identification and, if applicable, blocking of users who have installed a so-called adblocker and thus block advertising (legal basis is the legitimate interest of Engel & Völkers to make fully or partially advertising-financed offers available to users who do not block advertising);

• To prevent fraudulent activity or abuse on or in connection with the Website and to be able to ensure the legal requirements that the Website is secure (legal basis is the legitimate interest of Engel & Völkers to eliminate malfunctions, to ensure system security and to detect unauthorised access attempts or access).

For the purposes of processing in connection with cookies and other tracking technologies, please refer to our "Cookie Policy".

In summary: The legal basis for the processing of your personal data is Art. 6 I sentence 1 lit. a GDPR if the processing is based on consent, Art. 6 I sentence 1 lit. b GDPR if the processing is based on a (possibly pre-contractual) contractual relationship Art. 6 I sentence 1 lit. f GDPR if the processing is based on the legitimate interest of Engel & Völkers. If the processing of personal data is necessary to comply with a legal obligation to which Engel & Völkers is subject, Article 6 I sentence 1 lit. c GDPR is the relevant legal basis.

If the legal basis is your consent, you are entitled to revoke your consent at any time without affecting the lawfulness of the processing of your personal data carried out based on the consent until revocation. If the legal basis is the legitimate interest, you are also generally entitled to object to the processing of personal data relating to you at any time for reasons arising from your particular situation. In this respect, Art. 21 GDPR applies.

3. Disclosure of your personal data

Due to the scale and complexity of data processing by the Engel & Völkers group of companies, it is not possible to list each recipient of your personal data individually in this data protection policy, which is why, as a rule, only categories of recipients are indicated.

Within the Engel & Völkers group of companies, your data will be disclosed to those Engel & Völkers Companies or entities that require the data to fulfil our contractual and legal obligations and to pursue legitimate interests in the context of this Website service or based on your consent. This includes Engel & Völkers Companies that support the provision of our website, direct marketing or other IT infrastructure, that provide webinar events, that carry out the valuation of properties or that send out newsletters.

In addition, as a general principle, we will only pass on your personal data to third parties (i.e. companies that do not belong to the Engel & Völker Group or the Engel & Völkers Companies ) if this is necessary for the fulfilment of the contract, if we or the third party have a legitimate interest in the transfer, if there is a legal obligation or if you have given your consent. If your data is transferred to third parties based on legitimate interest, this will be explained in this Privacy Policy. Third parties to whom we may disclose your personal data, irrespective of our performance, include external advisors (e.g. lawyers and accountants), public authorities within their jurisdiction to comply with legal obligations and/or to protect our rights (e.g. tax authorities, police, prosecutors, courts), potential purchasers or acquirers of all or part of our assets and/or activities, and other third parties where you instruct us to disclose data or give your consent.

In summary:

If your contact request relates to offers from other companies of the Engel & Völkers group of companies (the Engel & Völkers Companies), Engel & Völkers will transmit the personal data you have entered to the respective company based on a so-called legitimate interest within the Engel & Völkers group of companies.

If, on the other hand, your contact request concerns offers from other companies of the Engel & Völkers Group (i.e. our licence partners), we will pass on your personal data from the Engel & Völkers group of companies with your prior consent.

4. Transfer of data to non-EEA countries

In addition to the above paragraph "Disclosure of your personal data", the following applies:

Recipients of personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which personal data is transferred ensures an adequate level of protection (Art. 45 GDPR) or the transfer is subject to adequate safeguards (e.g. standard contractual clauses) as agreed by the European Union and the recipient of the data (Art. 46 GDPR) unless the GDPR provides for an exception (Art. 49 GDPR). Furthermore, where necessary, we intend to agree to additional measures with recipients to ensure an adequate level of data protection.

Copies of the adequate safeguards (where we rely on them) and a list of recipients outside the EEA/UK are available on request. Please note that these copies may be redacted to the necessary extent to protect trade secrets or other confidential information.

II. You conclude a search- or marketing contract with us, request an exposé from us or commission us to carry out a property valuation.

1. Which of your data do we process?

When searching for, selling or renting a property, requesting an exposé or evaluating a property, we regularly process the following of your personal data:

• First name, surname, title, address, telephone number, and in the case of a property search the details of the desired property or in the case of property marketing or property valuation the details of the valuated property;

• E-mail address - provided that you have agreed to receive promotional information, in particular the offer or valuation of properties, or wish to receive communication by e-mail;

• In case of purchase/sale or rental of real estate, the bank details, identity details, copy of ID (in case of purchase/sale of real estate) as well as land register, electricity, oil and/or gas bills, general itemised bills, declarations of partition, WEG minutes (resolutions) and/or purchase contract (in case of sale of real estate) or in case of rental of real estate the bank details, identity details, CV if applicable, proof of salary, proof of creditworthiness, landlord's confirmation and/or tenancy agreement.

2. Purpose of the processing and legal basis

We process personal data for the following purposes:

• Fulfilment of the contractual relationship or a pre-contractual legal relationship - also by independent real estate consultants cooperating with us - including billing and credibility assessment (legal basis is Art. 6 I lit b. GDPR as well as Art. 6 I lit. f GDPR; the legitimate interest of us in connection with the transfer of data to independent real estate consultants derives from the freedom of choice to also fulfil contractual relationships with independent brokers or sub-brokers. The legitimate interest in carrying out credit checks follows from the legitimate interest in protecting against a loss of receivables);

• Fulfilment of a legal obligation, in particular in connection with anti-money laundering law (legal basis is Art. 6 I lit. c GDPR);

• Promotional information about properties that we or other licence partners of the Engel & Völkers Group market (legal basis is Art. 6 I lit. f GDPR; we have a legitimate interest in processing personal data for direct advertising. The legal basis is also your consent according to Art. 6 I a. GDPR, if the promotional information is sent to you by email, fax or telephone).

If the legal basis is your consent, you are entitled to revoke your consent at any time without affecting the lawfulness of the processing carried out based on the consent until revocation. If the legal basis is the legitimate interest, you are also generally entitled to object to the processing of your personal data at any time for reasons arising from your particular situation. In this respect, Art. 21 GDPR applies.

3. Disclosure of your personal data

If your enquiry (e.g. on the occasion of an evaluation enquiry) concerns offers from other licence partners of the Engel & Völkers Group, we will transmit the personal data you have entered to the respective company of the Engel & Völkers Group following your prior consent.

For more information, please see information regarding referrals in section III.

Furthermore, we pass on your data to contractual partners (owners, landlords, search clients) and supporting service providers such as notaries, lawyers, property managers, and property developers as part of the processing of a contractual relationship, as well as in the context of credibility reports or to supervisory authorities (such as for money laundering documentation). We may also transfer your data to third parties to the extent permitted by law. Third parties to whom we may disclose your personal data, irrespective of our performance, include external advisors (e.g. lawyers and auditors), public authorities within their jurisdiction to comply with legal obligations and/or to protect our rights (e.g. tax authorities, police, public prosecutors, courts), potential purchasers or acquirers of all or part of our assets and/or activities, and other third parties where you instruct us to disclose data or give your consent to do so.

Other than that, we will only share your personal data with staff (permanent staff such as employees and freelance property consultants) and third-party companies (e.g. IT service providers, hosting providers, etc.) to whom we have outsourced services involving processing operations under a commissioned processing agreement.

3. Transfer of data to non-EEA countries

In addition to the above paragraph "Disclosure of your personal data", the following applies:

Recipients of personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which personal data is transferred ensures an adequate level of protection (Art. 45 GDPR) or the transfer is subject to adequate safeguards (e.g. standard contractual clauses) as agreed by the European Union and the recipient of the data (Art. 46 GDPR) unless the GDPR provides for an exception (Art. 49 GDPR). Furthermore, where necessary, we intend to agree to additional measures with recipients to ensure an adequate level of data protection. Copies of the adequate safeguards, where we rely on them, and a list of recipients outside the EEA/UK are available on request. Please note that these copies may be redacted to the necessary extent to protect trade secrets or other confidential information.

If your enquiry relates to licence partners of the Engel & Völkers Group outside the European Union, we will transfer your data to the locally / matter-related licence partner following your consent.

III. We search for a property for you together with another Engel & Völkers licensed partner (Referral)

If we search for a property for you together with another licence partner, your data will only be transmitted based on your prior consent. Please note that both we, as your initial contact, and the licence partner of the Engel & Völkers Group to whom your data are supplied process your personal data. Both, we and this licence partner, are independently responsible for the respective data processing. This other licence partner and we do not have access to each other's data and do not process your data jointly. If you wish to assert data subject rights, please check in advance whether you wish to assert them against us or against the other licence partner of the Engel & Völkers Group who also processes your data.

Please refer to the above information on how we process your data in connection with the marketing of your property, what rights you have in this context and who your contact persons are should you wish to assert data subject rights.

IV. You manage our newsletters in your Engel & Völkers user account

1. What data do we process about you?

By using the newsletter management function within the user account provided by Engel & Völkers GmbH on the engelvoelkers.com website, you can subscribe to and unsubscribe from our electronic newsletters; In doing so, we process personal data, in particular your email address and, if applicable, your first name and last name - hereinafter referred to as “data” or “personal data” — which we receive from you or from our service providers in connection with your use of the newsletter management function within the Engel & Völkers user account.

2. Purpose of processing and legal basis

Provision of a management function for electronic newsletters (the legal basis in each case is your consent, Art. 6 I lit a. GDPR).

3. Disclosure of your personal data

We will only disclose your personal data to third parties if this is necessary for the performance of a contract, if we or the third party have a legitimate interest in the disclosure, if there is a legal obligation to do so, or if you have given your consent. If data is transferred to third parties on the basis of a legitimate interest, this will be explained in these data protection provisions.

4. Transfer of data to non-EEA countries

In addition to the above paragraph “Transfer of your personal data,” the following applies: The recipients of personal data may be located outside the EEA/UK. When personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which personal data is transferred ensures an adequate level of protection (Art. 45 GDPR) or the transfer is subject to appropriate safeguards (e.g., standard contractual clauses) agreed with the recipient (Art. 46 GDPR), unless the GDPR provides for an exception (Art. 49 GDPR). In addition, we intend to agree additional measures with recipients, where necessary, to ensure an adequate level of data protection. Copies of the appropriate safeguards (to the extent we rely on them) and a list of recipients outside the EEA/UK may be requested. Please note that these copies may be redacted to the extent necessary to protect trade secrets or other confidential information.

V. You communicate with us via WhatsApp or use our WhatsApp newsletter

We offer you the opportunity to contact us via the WhatsApp messenger service and to subscribe to our WhatsApp newsletter. Our WhatsApp communication with you and its central administration is not carried out with WhatsApp, but via the messaging platform “Superchat” of the accredited Meta/WhatsApp Business Solution Provider Super X GmbH, Schlesische Straße 12, 108997, Berlin, with whom we have concluded a data processing agreement and whose servers are located in Germany. As an official WhatsApp partner, this provider uses the WhatsApp Business API, which means that no other third parties or WhatsApp have access to your communication content within our area of responsibility.

1. What data do we process about you

When you use WhatsApp functions, we process your name in WhatsApp, your WhatsApp number (mobile phone number), your chat history, and any interests you may have specified during the registration process.

2. Purposes and legal basis of processing

• Contract initiation and customer service: If you contact us via WhatsApp to make inquiries about real estate offers or the sale/rental of your property, or to initiate service contracts (e.g., brokerage contracts), we process your name, mobile phone number, and the content of the message history. The legal basis is Art. 6 (1) (b) GDPR (implementation of pre-contractual measures) or your consent, Art. 6 (1) (a) GDPR.

• WhatsApp newsletter: If you have given us your express consent (e.g., by confirming in a double opt-in procedure in the chat), we use your data to send you advertising information and real estate offers from us and other licensees of the Engel & Völkers licensee network. The legal basis is Art. 6 (1) (a) GDPR (consent). You can revoke this consent at any time with effect for the future (e.g., by sending the message “STOP” in the chat).

3. Service providers used

• Superchat (SuperX GmbH): We have concluded a data processing agreement with SuperX GmbH in accordance with Art. 28 GDPR. Superchat serves as an interface through which we receive and respond to your WhatsApp messages.

• WhatsApp (Meta): WhatsApp is provided by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Although message content is end-to-end encrypted, Meta has access to metadata (e.g., who communicated with whom and when) – for more information, see section 5.

4. Disclosure of your personal data

We will only disclose your personal data to third parties if this is necessary for the performance of a contract, if we or the third party have a legitimate interest in the disclosure, if there is a legal obligation to do so, or if you have given your consent. If data is transferred to third parties on the basis of a legitimate interest, this will be explained in this privacy policy.

5. Transfer of data to non-EEA countries

In addition to the above paragraph “Transfer of your personal data,” the following applies: The recipients of personal data may be located outside the EEA/UK. When personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which personal data is transferred ensures an adequate level of protection (Art. 45 GDPR) or the transfer is subject to appropriate safeguards (e.g. standard contractual clauses) agreed with the recipient (Art. 46 GDPR), unless the GDPR provides for an exception (Art. 49 GDPR). In addition, we intend to agree additional measures with recipients where necessary to ensure an adequate level of data protection. Copies of the appropriate safeguards (to the extent we rely on them) and a list of recipients outside the EEA/UK are available upon request. Please note that these copies may be redacted to the extent necessary to protect trade secrets or other confidential information.

Please note that when using WhatsApp, data (such as communication data and your mobile phone number) may be transferred to Meta Platforms Inc. in the United States. Meta is certified under the EU-U.S. Data Privacy Framework. Nevertheless, we would like to point out that, from the EU's perspective, the United States does not offer a level of data protection that is fully equivalent to the GDPR. For more information, please refer to WhatsApp's privacy policy (https://www.whatsapp.com/legal/privacy-policy-eea). We have no specific knowledge of or influence over the data processing carried out by WhatsApp Ireland Limited.

VI. You apply on your own initiative or in response to a job advertisement

1. Which of your data do we process?

If you apply via our website or via a job advert with us or a job advert published by us from other companies in the Engel & Völkers Group, we will process your name as well as your address, telecommunications and application data. The provision of your address and telecommunications data (email address), which are mandatory, is necessary in order to contact you about your application and to be able to allocate the application.

2. Purpose of the processing and legal basis

We process your personal data for the following purposes:

• Checking the application for an employment relationship within our company (legal basis is Art. 6 I lit. b GDPR).

• Defence against any legal claims asserted against us from the application process, if this is necessary (the legal basis for this is our legitimate interest in meeting our obligation to provide evidence in proceedings under the General Equal Treatment Act (AGG); Art. 6 I lit. f GDPR).

• Furthermore, we process your personal data based on previously given consent in order to inform you about potential job offers (legal basis is Art. 6 I lit. a GDPR).

If the legal basis is your consent, you are entitled to revoke your consent at any time without affecting the lawfulness of the processing carried out based on the consent until revocation. If the legal basis is the legitimate interest, you are also generally entitled to object to the processing of personal data relating to you at any time for reasons arising from your particular situation. In this respect, Art. 21 GDPR applies.

We need your personal data to fulfil the processing purposes listed above. You are free to not disclose any personal data to us. In this case, you will be unable to participate in the application process for job vacancies

3. Disclosure of your data

We will only disclose your personal data to third parties if this is necessary for the fulfilment of the contract, if we or the third party have a legitimate interest in the disclosure, if there is a legal obligation or if you have given your consent. If data is transferred to third parties based on legitimate interest, this will be explained in this Privacy Policy.

If you have applied via the global online job portal of Engel & Völkers Holding GmbH, your application documents have been transmitted to us by Engel & Völkers Holding GmbH. How Engel & Völkers Holding GmbH processes your personal data as outlined during the application process and can be found at any time via the global online job portal on the relevant Engel & Völkers Holding GmbH website.

4. Transfer of data to non-EEA countries

In addition to the above paragraph "Disclosure of your personal data", the following applies:

Recipients of personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which personal data is transferred ensures an adequate level of protection (Art. 45 GDPR) or the transfer is subject to adequate safeguards (e.g. standard contractual clauses) as agreed by the European Union and the recipient of the data (Art. 46 GDPR) unless the GDPR provides for an exception (Art. 49 GDPR). Furthermore, where necessary, we intend to agree to additional measures with recipients to ensure an adequate level of data protection. Copies of the adequate safeguards (where we rely on them) and a list of recipients outside the EEA/UK are available on request. Please note that these copies may be redacted to the necessary extent to protect trade secrets or other confidential information.

V. Storage and deletion of your data

Engel & Völkers will retain your personal data for the time necessary to achieve the purposes for which data is collected, including any retention period required by the applicable law (e.g. retention of accounting records).

In the context of application procedures that end without employment, your data is regularly stored for six months for documentation purposes and then deleted or destroyed, as are the documents sent to us. With your consent to the processing of the data for future application procedures, we will also store it for a correspondingly longer period.

Data from WhatsApp communications will be deleted as soon as it is no longer required to fulfill the purpose (e.g., responding to the inquiry or concluding the contract initiation), provided that there are no legal retention obligations to the contrary. Newsletter data will be deleted immediately upon revocation of consent.