Privacy Policy

Privacy Policy

Valid from 27 February 2024

Responsible party and rights of the data subject *

( *Note on gender: In order to improve readability, the simultaneous use of the masculine, feminine and different linguistic forms (m/f/d) is hereinafter omitted. All the following personal designations

apply equally to all genders. )

1. Responsible party

The entity responsible for the data processing regulated in this privacy policy is the company

“Belle Epoque RE S.r.l.” (hereinafter: “we” or “us”, or similar). Our contact details:

BELLE EPOQUE RE S.R.L.

Via Rossini 1

21100, Varese (VA)

Italy

baricentro@engelvoelkers.com

License Partner of Engel & Völkers Residential GmbH

2. Data protection officer

If you have any questions about this privacy policy and data protection, please contact our

data protection officer:

Emanuel Roberto Taiano

emanuel.taiano@engelvoelkers.com

3. Rights of the data subject

The data subject has the right to obtain information about the processing of his or her personal data (e.g.,

the origin of such data, the purpose of the processing, the means of processing the data). Furthermore, under certain

conditions, you have the right to object to the processing of your data for the future, to limit it or to request its

cancellation. Finally, you can stop sending advertising material or carrying out market research or commercial communications at any time.

In summary, the interested party has the right

- to information,

- to rectification,

- to cancellation (right to be forgotten),

- to limitation of processing,

- to data portability,

- to object to the processing of your personal data,

- to lodge a complaint with the supervisory authorities.

Furthermore, the data subject has the right to object at any time to the processing of his or her personal data for

direct marketing purposes. If the data subject objects to the processing for direct marketing purposes, we will no longer

process his or her personal data for such purposes.

Pursuant to Art. 7 III of the General Data Protection Regulation of the European Union (hereinafter

"GDPR"), the data subject may withdraw the consent he or she has given us at any time. This has the

consequence that we will no longer be able to continue processing the data based on this consent in the future.

Please note that the right to erasure is subject to restrictions. For example, we must not or cannot

delete data that we still have to retain due to statutory retention periods.

The right to deletion also excludes data that we need to assert, exercise or defend

legal claims.

If you have a complaint about how we process your data, you have the right to lodge a complaint with

a supervisory authority, in particular in the Member State where you reside, work or where the

alleged infringement occurred.

We reserve the right, in the event of a legal obligation, to disclose information about the data subject and if we are requested to do so

by competent authorities or law enforcement agencies. Legal basis: Art. 6 I sentence 1 lit. c GDPR (legal obligation).

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Overview of our data processing procedures

Our data protection information is structured as follows and provides an overview of the

following data processing procedures:

I. The data subject visits us on our corporate website on the Internet

II. The data subject concludes a research or marketing contract with us, requests an exhibition from us or commissions a real estate appraisal

III. We search for a property for the data subject together with another license partner of Engel & Völkers

(referral)

IV. The interested party applies on his/her own initiative or in response to a job advertisement

V. Storage and deletion of your data

I. Collection and processing of personal data when the interested party visits our company website on

the Internet

In principle, we only process personal data if they are sent to us via contact forms on our

company website. Personal data is only processed if the interested party has given his/her consent to do so

or if the processing is permitted by law. For some services we offer on our corporate website, we require a minimum amount of data. We have marked this mandatory data with an

“asterisk”. Without the mandatory data, we cannot provide our services marked in this way.

1. What data of the data subject (hereinafter: “the data subject”) do we process

In the context of the use of our company website, we process personal data, in particular:

Email address, first name, last name, title, address, telephone number, subject data – in the context of

this data protection declaration referred to as “data” or “personal data”) provided by the data subject in the case of the

services offered on our company website (e.g. in the context of contact requests and sending newsletters, as well as determining the market price (“valuation”) of real estate).

_____________________________________________________

Please refer to the description of the processing of usage data in connection with the use of

cookies and other tracking technologies in the "Cookie Information" of

Engel & Völkers GmbH

Vancouverstraße 2a

D-20457 Hamburg

Germany

E-mail: contact@engelvoelkers.com

Information about cookies can be found at the bottom of our company page on the Internet.

_____________________________________________________

2. Purpose of processing and legal basis

We process the data of the data subject for the following purposes:

● Fulfillment of contact requests (the legal basis is the fulfillment of the contract and, in the case of

transfer of the data of the data subject to other license partners of the Engel & Völkers Group (for the

definition, see section 3 below), the consent of the data subject);

● If applicable, the fulfillment of the request for valuation of the property described by the data subject in

based on the market price, as well as the interest in selling thus transmitted (the legal basis is

the fulfillment of the contract as well as - in the case of the entry of contact data by

the data subject and their forwarding to a licensing partner of the Engel & Völkers Group responsible for

the topic or geography (for the definition, please see section 3 below) or

to the company that technically carries out the valuation - the consent of the data subject as well as - in the case

of the use of contact data for direct marketing - the justified interest in marketing i

our services or your consent);

● Telephone contact by us (the legal basis is the fulfillment of the contract or, in the case of

use of the telephone number for advertising purposes, the consent of the data subject);

● Sending an e-mail newsletter about our offers and our own and third-party advertising, to the extent

permitted by law or on the basis of the consent of the data subject (the legal basis is the consent

of the data subject or our legitimate interest in direct marketing, provided that the marketing is

carried out in compliance with data protection requirements and competition law);

Summary:

The legal basis for the processing of 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 basis for the processing is a contractual relationship (possibly pre-contractual) and Art. 6 I sentence 1 lit. f GDPR, if the basis is our legitimate interest. Insofar as the

processing of personal data is necessary for compliance with a legal obligation to which we are subject, Art. 6

I sentence 1 lit. c GDPR serves as the legal basis.

If the legal basis is the consent of the data subject, the latter has the right to withdraw his/her consent at

any time without prejudice to the lawfulness of the processing of his/her personal data carried out on the basis

of the consent until its withdrawal. If the legal basis is legitimate interest, the data subject also has the right to

object at any time to the processing of personal data concerning him/her for reasons arising from his/her

particular situation. In this regard, Art. 21 GDPR applies.

3. Transmission of personal data of the data subject

We will only transmit the personal data of the data subject to third parties if this is necessary for the fulfillment of the contract,

if we or the third party have a legitimate interest in transmitting the data, if there is a legal obligation to do so

or if the data subject has given his or her consent. If data is transferred to third parties on the basis of a legitimate interest, this will be explained in this data protection provision.

If the contact request of the data subject concerns offers from other companies of the Engel & Völkers,

we will transfer the personal data entered by the data subject to the respective company of the Engel & Völkers Group with the prior

consent of the data subject or - if legally permissible - on the basis of a so-called legitimate interest. Apart from

this, we will not transfer your personal data for other purposes.

When we refer to the “Engel & Völkers Group” in this privacy policy, we mean the companies

belonging to the Engel & Völkers pursuant to §§ 15 et seq. AktG (German Stock Corporation Act) and the licensing partners (masters) who are directly or indirectly contractually affiliated

with this group of companies, of which we are also a part. For an up-to-date overview

of these licensing partners, please see the following

link: https://www.engelvoelkers.com/de/unternehmen/standorte/).

4. Data transfer to countries outside the EEA

In addition to the previous paragraph “Disclosure of personal data”, the following applies:

The 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 the personal data is transferred ensures an adequate level of protection (Article 45 GDPR), or

because the transfer is subject to appropriate safeguards (e.g. EU standard contractual clauses

clauses) agreed with the recipient (Article 46 GDPR), unless the GDPR provides

an exception (Article 49 GDPR). In addition, where necessary, we intend to agree additional measures

with recipients to ensure an adequate level of data protection. You may request copies of the appropriate safeguards

(where you rely on them) and a list of recipients outside the EEA/UK. Note: these copies

may be reduced to the extent necessary to protect trade secrets or other confidential information.

II. The data subject concludes a research or marketing contract with us, requests an exhibition from us or commissions us to

evaluate a property

1. The data subject's data processed by us

When searching for, selling or renting a property, requesting an exhibition or evaluating a

property, we regularly process the following personal data of the data subject:

● First name, last name, title, address, telephone number, information on the desired property (in the case of

searching for properties) or (in the case of marketing or evaluating properties) information

on the property;

● Email address, if the interested party has agreed to receive promotional information, in particular

the offer or evaluation of real estate, or wishes to receive communications by email;

● as well as (in the case of sale or rental of real estate) bank details, identity data, copy

of the identity document (in the case of sale of real estate) as well as land registry, electricity, gas

and/or oil bills, generic bills, division declarations, WEG minutes (resolutions), contract of

sale (in the case of sale of real estate) or (in the case of rental of real estate) bank details,

identity data, possibly curriculum vitae, proof of salary, proof of solvency, confirmation of the

lessor, rental agreement.

2. Purpose of processing and legal basis

We process this personal data for the following purposes:

● Fulfilment of the contractual relationship or a pre-contractual legal relationship - also by

independent real estate consultants who work with us - including invoicing and

credit assessment (the legal basis is Art. 6 I lit. b. GDPR and Art. 6 I lit. f GDPR; our

legitimate interest in disclosing data to independent real estate consultants arises

from the freedom to choose to also fulfil contractual relationships with independent

brokers or sub-brokers. The legitimate interest in carrying out credit checks arises from the legitimate interest of

protection from bad debts);

● Fulfilment of a legal obligation, in particular in relation to the Money Laundering Act; (the

legal basis is Art. 6 I lit. c GDPR);

● Promotional information on properties marketed by us or other authorised partners of the

Engel & Völkers (the legal basis is Art. 6 I lit. f GDPR; the processing of personal data for the purposes of direct advertising is in our legitimate interest. The legal basis is also the consent of the user in accordance with Art. 6 I a. GDPR, if promotional information is sent to the data subject by e-mail, fax or telephone).

If the legal basis is the consent of the data subject, the data subject has the right to withdraw his or her consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent until its withdrawal. If the legal basis is legitimate interest, the data subject also has the right to object at any time to the processing of personal data concerning him or her for reasons arising from his or her particular situation. In this respect, Art. 21 GDPR applies.

3. Transmission of data

If the data subject's request (e.g. in the case of a request for evaluation) concerns offers from other

partners of the Engel & Völkers Group, Engel & Völkers will transmit the personal data entered by the data subject to the

respective company of the Engel & Völkers Group, subject to the data subject's prior consent.

In this context, please also refer to our information on the addition in section III.