Engel & Völkers Commercial Milan Lombardy

Privacy Policy

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Immocomm S.r.l. Privacy Policy

Data Controller and Data Subject Rights *

(*Note on gender: For readability, the simultaneous use of the masculine, feminine, and different (m/f/d) forms is omitted below. All the following personal designations apply equally to all genders.)

Data Controller

The entity responsible for the data processing regulated in this privacy policy is the company "Immocomm S.r.l." (hereinafter: “we” or “to us”, or similar). Our contact details:

Immocomm S.r.l.

Via dei Bossi 7,

20121 Milan

Tel: +39 02 94 43 93

E-Mail: milanocommercial@engelvoelkers.com

Engel & Licensing Partner Völkers Commercial GmbH

Data Protection Officer

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

First and Last Name: Dr. Roberto Magaglio

Email: milanocommercial@engelvoelkers.com

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 source of the data, (the purpose of the processing, the methods of data processing). 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 deletion. Finally, you can stop receiving advertising material or conducting market research or commercial communications at any time.

In summary, the data subject has the right to:

Information;
Rectification;
Erasure (right to be forgotten);
Restriction of processing;
Data portability;
Objection to the processing of your personal data;
Lodge a complaint with the supervisory authority.

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 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 European Union General Data Protection Regulation (hereinafter "GDPR"), the data subject may revoke the consent given to us at any time. This means that we will no longer be able to continue processing the data based on that consent in the future.

Please note that the right to erasure is subject to restrictions. For example, we must not or cannot erase data that we still need to retain due to statutory retention periods. Data that we require for the establishment, exercise, or defense of legal claims is also excluded from the right to erasure.

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 of your residence, place of work, or where the alleged infringement occurred.

We reserve the right to disclose information about the data subject if we are legally required to do so or if requested by competent authorities or law enforcement agencies. Legal basis: Art. 6 (1) (c) GDPR (legal obligation).

Overview of our data processing practices

Our data protection information is structured as follows and provides an overview of the following data processing practices:

The data subject visits our corporate website The data subject concludes a research or marketing contract with us, requests a listing presentation, or commissions a real estate appraisal We search for a property for the data subject together with another license partner of Engel & Völkers (referral) The data subject applies on their own initiative or in response to a job advertisement Storage and deletion of their data

Collection and processing of personal data when the data subject visits our company website

In principle, we only process personal data if it is sent to us via the contact forms on our company website. Personal data is processed only if the data subject has given his or her consent or if processing is permitted by law. For some services we offer on our company 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.

What data of the data subject (hereinafter: "the data subject") do we process?

When using our company website, we process personal data, in particular:

Email address, first name, last name, title, address, telephone number, subject data (referred to in this privacy policy as "data" or "personal data") provided by the data subject in the context 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 properties).

Please refer to the description of usage data processing in connection with the use of cookies and other tracking technologies in the "Cookie Information" section of

Engel & Völkers GmbH

Vancouverstraße 2a

D-20457 Hamburg

Germany

Email: contact@engelvoelkers.com

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

Purpose of processing and legal basis

We process the data of the interested party for the following purposes:

Compliance with contact requests (the legal basis is the fulfillment of the contract and, in the case of the transfer of the data subject's data to other license partners of the Engel & Völkers Group (for the definition, see section 3 below), the data subject's consent);
Where applicable, fulfillment of the request for a valuation of the property described by the data subject based on the market price, as well as the interest in selling it thus expressed (the legal basis is the fulfillment of the contract and—in the case of the data subject's entering contact data and forwarding it to a license partner of the Engel & Völkers Group responsible for the area or geography (for the definition, see section 3 below) or to the company technically carrying out the valuation—the data subject's consent and—in the case of the use of contact data for direct marketing—the justified interest in marketing our services or its consent);
Telephone contact from us (the legal basis is the fulfillment of the contract or, in the case of using the telephone number for advertising purposes, the data subject's consent);
Sending an email newsletter about our offers and our own and third-party advertising, to the extent permitted by law or based on the data subject's consent (the legal basis is the data subject's consent 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 (1) sentence 1 lit. a GDPR; if the processing is based on consent, Art. 6 (1) sentence 1 lit. b GDPR, if the basis for the processing is a contractual relationship (including pre-contractual ones), and Art. 6 I sentence 1 lit. f GDPR, if the basis is our legitimate interest. To the extent that 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 data subject's consent, the data subject has the right to withdraw his or her consent at any time without affecting the lawfulness of the processing of his or her personal data carried out on the basis of 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. Art. 21 GDPR applies in this regard.

Transmission of the data subject's personal data

We will only transfer the data subject's personal data to third parties if this is necessary for the performance of the contract, if we or the third party have a legitimate interest in doing so, 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 based on a legitimate interest, this will be explained in this data protection provision.

If the data subject's contact request concerns offers from other companies within the Engel & Völkers Group, we will transfer the personal data provided by the data subject to the respective company within the Engel & Völkers Group. Völkers with the data subject's prior consent or—if legally permitted—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 Group pursuant to Sections 15 et seq. of the German Stock Corporation Act (AKTG) and the licensing partners (masters) that are directly or indirectly contractually affiliated with this group of companies, of which we are also a member. For an up-to-date overview of these licensing partners, please see the following link: https://www.engelvoelkers.com/de/unternehmen/standorte/).

Transmission of data to countries outside the EEA

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

Recipients of personal data may be located outside the EEA/UK. If personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that data protection rights are adequately protected, both because the European Commission has determined that the country to which the personal data is transferred ensures an adequate level of protection (Article 45 GDPR) and because the transfer is subject to appropriate safeguards (e.g., EU standard contractual clauses) agreed with the recipient (Article 46 GDPR), unless the GDPR provides an exception (Article 49 GDPR). Furthermore, 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. Please note: these copies may be limited to the extent necessary to protect trade secrets or other confidential information.

The data subject enters into a search or marketing contract with us, requests a listing presentation, or commissions a property appraisal.

The data subject's data we process.

When searching for, selling, or renting a property, requesting a listing presentation, or appraising a property, we regularly process the following personal data of the data subject:

First name, surname, title, address, telephone number, information about the desired property (in the case of a property search) or (in the case of marketing or appraisal of properties) information on the property;
Email address, if the interested party has agreed to receive promotional information, in particular offers or appraisals of properties, or wishes to receive communications by email;
As well as (in the case of the sale or rental of properties) bank details, identity data, copy of identity document (in the case of the sale of properties), as well as land registry records, electricity, gas, and/or oil bills, general utility bills, division declarations, minutes (resolutions), sales contract (in the case of the sale of properties) or (in the case of the rental of properties) bank details, identity data, possibly a curriculum vitae, proof of salary, proof of solvency, confirmation from the landlord, rental agreement.

Purpose of processing and legal basis

We process this personal data for the following purposes:

Performance of the contractual relationship or a pre-contractual legal relationship - including 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 also fulfill contractual relationships with independent brokers or sub-brokers. The legitimate interest in carrying out credit checks arises from the legitimate interest in protecting against bad debts);
Performance of a legal obligation, in particular in relation to the Anti-Money Laundering Act; (The legal basis is Art. 6 (1) (c) GDPR);
Promotional information on properties marketed by us or other authorized partners of the Engel & Völkers Group (The legal basis is Art. 6 (1) (f) GDPR; the processing of personal data for direct marketing purposes is in our legitimate interest. The legal basis is also your consent pursuant to Art. 6 (1) (a) GDPR, if promotional information is sent to the data subject by email, fax, or telephone).

If the legal basis is your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on your consent until such time as it is withdrawn. If the legal basis is legitimate interest, you also have the right to object at any time to the processing of your personal data for reasons arising from your particular situation. Article 21 of the GDPR applies in this regard.

Transmission of data

If the data subject's request (e.g., in a review request) 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 consent.

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

Furthermore, we transmit personal data to contractual partners (landlords, landlords, search clients) and support service providers such as notaries, lawyers, property managers, and real estate developers as part of the contractual relationship, as well as for credit information purposes or to supervisory authorities (e.g., for anti-money laundering documentation). We may also transfer data to third parties to the extent permitted by law. Third parties to whom we may disclose your personal data, regardless of our performance, include external advisors (e.g., lawyers and auditors), public authorities within their jurisdiction to comply with legal obligations and/or protect our rights (e.g., tax authorities, police, prosecutors, courts), potential purchasers or acquirers of all or part of our assets and/or businesses, and other third parties to whom you have instructed us to disclose the data or have provided your consent.

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

Transmission of data to countries outside the EEA

In addition to the previous paragraph on "Sharing personal data," the following applies:

If the data subject's request concerns licensing partners of the Engel & Völkers Group outside the European Union, we will transfer the data subject's data to the locally/factually competent licensing partner after obtaining the data subject's consent.

We are looking for a property for the data subject together with another Engel & Völkers license partner ("referral").

If we are looking for a property for the data subject together with another licensing partner, the data subject's data will only be transferred based on the data subject's prior consent. Please note: Both we, as the initial contact, and the Engel & Völkers Group licensing partner to whom your data is provided, process the data subject's personal data. Both of us—we and this licensing partner—are independently responsible for their respective data processing. We and this other licensing partner do not have access to each other's data and do not process the data subject's data jointly. If the data subject wishes to assert his or her rights, please check in advance whether he or she wishes to assert them against us or against the other Engel & Völkers Group partner processing the data subject's data.

Please refer to the information above on how we process the data subject's data in connection with the marketing of the data subject's property, what rights the data subject has in this context, and who to contact if the data subject wishes to assert his or her rights.

The data subject applies on their own initiative or in response to a job advertisement

The data subject's data we process

If the data subject applies via our website or a job advertisement, we process the data subject's name and address, as well as telecommunications and application data. Providing the address and telecommunications data, advertised as mandatory data, is necessary to contact the data subject regarding their application and to be able to assign the application.

Purpose of processing and legal basis

We process the data subject's personal data for the following purposes:

Examining applications for employment within our company (the legal basis is Art. 6 I lit. b GDPR, if applicable in conjunction with Art. 26 BDSG (German Federal Data Protection Act) (for the scope of application of the Federal Republic of Germany).
Defense against any legal claims asserted against us as a result of the application process, to the extent necessary (the legal basis is our legitimate interest in fulfilling the obligation to provide evidence in proceedings under the General Data Protection Act (GDPR)). Equal Treatment (AGG); Art. 6 (1) (f) GDPR).
Furthermore, we process the data subject's personal data based on a previously given consent in order to inform them about interesting job offers (the legal basis is Art. 6 (1) (a) GDPR).

If the legal basis is the data subject's consent, the data subject has the right to withdraw his or her consent at any time without affecting the lawfulness of processing based on consent until such time as it is withdrawn. 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. Art. 21 GDPR applies in this regard.

We need the data subject's personal data to fulfill for the processing purposes listed above. The data subject is free not to provide us with any personal data. In this case, we will not be able to allow the data subject to participate in the application process for vacant positions.

Transmission of data

We will only transfer the data subject's personal data to third parties if this is necessary for the performance of the contract, if we or the third party have a legitimate interest in transferring 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 based on a legitimate interest, this will be explained in this data protection provision.

If the data subject If you applied via the global online job portal of Engel & Völkers Holding GmbH, your application documents were sent to us by Engel & Völkers Holding GmbH. You have learned how Engel & Völkers Holding GmbH processes your personal data during the application process and can view this data at any time via the global online job portal on the relevant Engel & Völkers Holding GmbH website.

Transfer of data to countries outside the EEA

In addition to the previous section on "Sharing of personal data," the following applies:

Recipients of personal data may be located outside the EEA. EEA/UK. If personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that 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) agreed with the recipient (Article 46 GDPR), unless the GDPR provides an exception (Article 49 GDPR). Furthermore, 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. Please note: These copies may be limited to the extent necessary to protect trade secrets or other confidential information.

Storing and Deletion of Your Data

We retain the data subject's personal data for as long as necessary to achieve the purpose for which the data was collected and subsequently processed, including any retention periods required by applicable law (e.g., retention of accounting records).

In the context of application procedures that end without hiring, the data subject's data will regularly be retained for an additional six months for documentation purposes and then deleted or destroyed, along with any documents sent to us. With the data subject's consent to data processing for future application procedures, we will also retain the data for a proportionately longer period.