Privacy Policy

Privacy Policy

Data Controller and rights of the interested party

Data Controller

 The Data Controller governed by this privacy policy is the company

REACTIVE S.R.L.

Via Lungolago Marconi n.10

25049 Iseo (BS)

Tel.+39 030 5780499

E-mail: Lagodiseo@engelvoelkers.com

(hereinafter: “us” or “us”, or similar).

License Partner of Engel & Völkers Lago d’Iseo Franciacorta and Engel & Völkers Ponte di Legno Bormio

Data Protection Officer

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

REACTIVE S.R.L.

With headquarters in Iseo, Via Lungolago Marconi n.10 | VAT number 03842170163 | Registered in the Brescia Companies Register under REA BS-BS-581447

Contacts:

Lagodiseo@engelvoelkers.com

+39 030 5780499

Rights of the data subject

The data subject has the right to obtain information on the processing of his or her personal data (for example, the origin of such data, the purpose of the processing, the methods of data processing). Furthermore, under certain conditions, he or she has the right to object to the processing of data for the future, to limit it or to request its deletion. 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 erasure (right to be forgotten),

to restriction 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 given to 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. Data that we need to assert, exercise or defend 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 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 required 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: 

The interested party visits us on our corporate website on the Internet 

The interested party concludes a research or marketing contract with us, requests a listing presentation from us or commissions a real estate appraisal 

We search for a property for the interested party together with another license partner of Engel & Völkers (referral)

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

Storage and deletion of your data 

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 data subject has given his or her consent to do so or if the processing is permitted by law. For some services that 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?

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).

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Please refer to the description of usage data processing in relation to the use of cookies and other tracking technologies in the “Cookie Information” 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:

Satisfaction contact requests (the legal basis is the fulfillment of the contract and, in the case of transfer of the data subject's data 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 based on the market price, as well as the interest in selling thus transmitted (the legal basis is the fulfillment of the contract and - 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 area or geography (for the definition, please see section 3 below) or to the company technically carrying out the valuation - the consent of the data subject and - in the case of the use of contact data for direct marketing - the justified interest in marketing our services or his/her 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 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 the consent until the 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 respect. 

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 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 Group, we will transmit the personal data entered by the data subject to the respective company of the Engel & Völkers with the prior consent of the data subject or - if legally permissible - on the basis of a so-called legitimate interest. Apart from that, we will not pass on 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 within the meaning of Sections 15 et seq. of the AktG (German Stock Corporation Act) and the licensing partners (masters) that 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/).

Transmission of data 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 we transfer personal data 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 (for example, EU standard contractual 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 can request copies of the appropriate safeguards (where you rely on them) and a list of recipients outside the EEA/UK. Please note that these copies may be reduced to the extent necessary to protect trade secrets or other confidential information.

The data subject concludes a search or marketing contract with us, requests a listing presentation from us or commissions a property valuation from us 

 

The data subject's data processed by us

When searching for, selling or renting a property, requesting a listing presentation or valuing 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 valuation of properties) information about the property;

Email address, if the interested party has agreed to receive promotional information, in particular the offer or evaluation of properties, or wishes to receive communications by email;

as well as (in the case of sale or rental of properties) bank details, identity data, copy of the identity document (in the case of sale of properties) as well as land registry, electricity, gas and/or oil bills, generic bills, division declarations, minutes (resolutions), sales contract (in the case of sale of properties) or (in the case of rental of properties) bank details, identity data, possibly curriculum vitae, proof of salary, proof of solvency, confirmation of the lessor, rental contract.

Purpose of processing and legal basis

We process this personal data for the following purposes:

Fulfillment 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 of choice 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); 

Fulfillment 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 Group (the legal basis is Art. 6 I lit. f GDPR; the processing of personal data for the purpose of direct advertising is in our legitimate interest. The legal basis is also your consent pursuant to Art. 6 I a. GDPR, if the 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 latter 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 the 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.

Transmission of data 

If the request of the data subject (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.  

Furthermore, we transmit personal data to contractual partners (landlords, lessors, search clients) and support service providers such as notaries, lawyers, property managers, real estate developers in the context of processing a contractual relationship, as well as in the context of credit information or to supervisory authorities (e.g. for documentation of money laundering). We may also transfer the data of the data subject to third parties to the extent permitted by law. Third parties to whom we may disclose your personal data, independently 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, prosecutors, courts), prospective purchasers or acquirers of all or part of our assets and/or business, and other third parties where you have instructed us to disclose the data or have given your consent.

In addition, 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, 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: 

Recipients of personal data may be located outside the EEA/UK. Where we transfer personal data 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 (for example, EU standard contractual 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 can request copies of the appropriate safeguards (where you rely on them) and a list of recipients outside the EEA/UK. Please note that these copies may be reduced to the extent necessary to protect trade secrets or other confidential information.

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

We are looking for a property for the data subject together with another licensing partner of Engel & Völkers (“referral”).

If we are looking for a property for the data subject together with another licensing partner, the data of the data subject will only be passed on on the basis of the prior consent of the data subject. Note: Both we, as the initial contact, and the licensing partner of the Engel & Völkers to whom your data is provided, we process the personal data of the data subject. Both of us - we and this licensing partner - are independently responsible for the respective data processing. We and this other licensing partner do not have access to the data of the other and do not process the data of the data subject jointly. If the data subject wishes to assert his rights, please check in advance whether he wishes to assert them against us or against the other partner of the Engel & Völkers Group that processes the data of the data subject. 

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 the contact persons are in case the data subject wishes to assert his rights.  

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

The data subject's data processed by us

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, which are advertised as mandatory data, is necessary in order to contact the data subject regarding his or her application and to be able to assign the application.

Purpose of processing and legal basis

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

● Processing of the application for an employment relationship within our company (the legal basis is Art. 6 I lit. b GDPR, if applicable in conjunction with Art. 26 BDSG (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 that this is necessary (the legal basis is our legitimate interest interest in fulfilling the obligation to provide evidence in proceedings under the General Equal Treatment Act (AGG); Art. 6 I lit. f GDPR).

● Furthermore, we process the personal data of the data subject on the basis of a previously given consent in order to inform him/her about interesting job offers (the legal basis is Art. 6 I lit. a GDPR). 

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 affecting the lawfulness of the processing carried out on the basis of the consent until the 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. Art. 21 GDPR applies in this respect GDPR.

We need the personal data of the data subject to fulfill 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 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. data.

If the data subject has applied via the global online job portal of Engel & Völkers Holding GmbH, the application documents of the data subject have been transmitted to us by Engel & Völkers Holding GmbH. The data subject has learned how Engel & Völkers Holding GmbH processes his or her personal data during the application process and can view this data at any time via the global online job portal on the respective website of Engel & Völkers Holding GmbH. 

Transmission of data to countries outside the EEA

In addition to the previous paragraph on “Sharing of personal data”, the following also applies: follows: 

Recipients of your personal data may be located outside the EEA/UK. Where we transfer your personal data 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) 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 can 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.

Storing and deleting your data

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

In the context of application procedures that end without hiring, your data will routinely be retained for a further six months for documentation purposes and then deleted or destroyed, together with the documents that have been sent to us. With your consent to the processing of your data for future application procedures, we also retain them for a proportionally longer period of time. long.