Engel & Völkers Vicenza

Privacy Policy

Valid from 29 August 2022.

Data subject and rights*

(*Gender note: To improve readability, the simultaneous use of masculine, feminine and different language forms (m/f/d) is waived. All personal names below apply equally to all genders.)

1. Responsible

The entity responsible for data processing governed by this privacy policy is E.V. Palladio s.r.l. (hereinafter: "we" or "to us", or similar). Our contact details:

E.V. Palladio s.r.l.

Corso Andrea Palladio 169, Vicenza 36100

engelvoelkersvicenza@pec.it

Licensing partner of Engel & Völkers Italia S.r.l.

2. Data Protection Officer

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

Giovanni Frascolla

giovanni.frascolla@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 (for example, the origin of such data, the purpose of the processing, the way in which the data is processed). You also have the right to object to future processing of your data, to limit it or to request its deletion under certain conditions. Finally, you can stop sending advertising material or market research or commercial communications at any time.

In summary, the person concerned has the right

- to information,

- to the rectification,

- to deletion (right to be forgotten),

- to the limitation of processing,

- data portability,

- to object to the processing of their personal data,

- to complain to the supervisory authorities.

In addition, the data subject has the right to object to the processing of his or her personal data for direct marketing purposes at any time. 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 Article 7 III of the General Data Protection Regulation of the European Union (hereinafter “GDPR”), the data subject may revoke the consent he or she has given us at any time. This has the consequence that we will no longer be able to continue data processing on the basis of that consent in the future.

Note that the right to erasure is subject to restrictions. For example, we do not or cannot delete data that we still need to retain because of statutory retention periods. Also excluded from the right of erasure is data that we need to assert, exercise, or defend legal claims.

If you have a complaint about the way we process your data, you have the option of filing a complaint with a supervisory authority, particularly in the member state where you reside, work, or where the alleged breach 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 the 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 enters into a research or marketing contract with us, requests an exhibition from us, or commissions a real estate appraisal from us

III. We search for a property for the interested party together with another Engel & Völkers licensee partner (referral)

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

V. Storage and deletion of own data

I. Collection and processing of personal data when the data subject visits our company's website on the Internet

In principle, we process personal data only if they are submitted to us via the contact forms on our company website. We process personal data only if the data subject has given his or her consent to do so or if the processing is permitted by legal regulations. 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.

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

In the context of using our corporate website, we process personal data, namely:

Email address, first name, last name, title, address, telephone number, subject data - in the context of this privacy policy referred to as “data” or “personal data”) provided by the data subject in the case of services offered on our corporate 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 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: info@engelvoelkers.com

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

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2. Purpose of processing and legal basis

We process the data subject's data 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 subject's data to other license partners of the Engel & Völkers Group (for definition, see section 3 below), the consent of the data subject);

● If applicable, the fulfillment of the request for the valuation of the property described by the data subject on the basis of the market price, as well as the interest in the sale thus conveyed (the legal basis is the fulfillment of the contract as well as - in the case of the data subject's input of contact data and their forwarding to a licensing partner of the Engel & Völkers Group responsible for the subject or geography (for definition, please refer to section 3 below) or to the company technically carrying out the evaluation - 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 our services or his or her consent);

● Telephone contact by us (the legal basis is the fulfillment of the contract or, in the case of using the telephone number for advertising purposes, the consent of the data subject);

● Sending an e-mail newsletter about our own and third parties' offers and advertising, to the extent permitted by law or on the basis of 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 I sentence 1 lit. a GDPR, if the processing is based on consent, Art. 6 I sentence 1 lit. b GDPR, if the basis of processing is a contractual (possibly pre-contractual) relationship, 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 the fulfillment of a legal obligation to which we are subject, Art. 6 I sentence 1 lit. c GDPR as the legal basis.

If the legal basis is the consent of the data subject, the data subject has the right to revoke 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 revocation. 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 on grounds arising from his or her particular situation. Article 21 GDPR applies in this regard.

3. Transmission of the data subject's personal data

We will only transmit the data subject's personal data 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 provided consent. If data is transferred to a third party on the basis of a legitimate interest, this will be explained in these data protection provisions.

If the data subject's contact request concerns offers from other companies of the Engel & Völkers Group, we will transfer the personal data entered by the data subject to the respective company of the Engel & Völkers Group subject to the consent of the data subject or - if legally permitted - on the basis of a so-called legitimate interest. Apart from that, we will not transfer the user's 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 license 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 license partners, please see the following link: https://www.engelvoelkers.com/de/unternehmen/standorte/).

4. Transmission of data to non-EEA countries.

In addition to the previous paragraph “Disclosure of Personal Data,” the following applies:

Recipients of personal data may be located outside the EEA/UK. In the event that 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 personal data is transferred ensures an adequate level of protection (Art. 45 GDPR), and because the transfer is subject to adequate safeguards (e.g., EU standard contractual clauses) agreed with the recipient (Art. 46 GDPR), unless the GDPR provides an exception (Art. 49 GDPR). In addition, where necessary, we intend to agree with recipients on additional measures to ensure an adequate level of data protection. You can request copies of the appropriate safeguards (where we 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. A data subject enters into a research or marketing contract with us, requests a display, or commissions us to evaluate a property

1. The data subject's data processed by us

While searching for, selling or renting a property, requesting an exhibition or appraising a property, we routinely process the following personal data of the data subject:

● First name, last name, title, address, telephone number, information about the desired property (in case of property search) or (in case of property marketing or valuation) information about the property;

● E-mail address, if the person has agreed to receive promotional information, particularly the offer or valuation of real estate, or wishes to receive communications by e-mail;

● as well as (in the case of buying or selling or renting real estate) bank details, identity data, copy of ID (in the case of buying or selling real estate) as well as land registry, electricity, gas and/or oil bills, general utility bills, division declarations, WEG minutes (resolutions), purchase and sale agreement (in the case of selling real estate) or (in the case of renting real estate) bank details, identity data, possibly resume, proof of salary, proof of solvency, landlord confirmation, lease agreement.

2. Purpose of processing and legal basis

We process this personal data for the following purposes:

● Fulfillment of the contractual or pre-contractual legal relationship - including by independent real estate consultants working with us - including billing and credit assessment (the legal basis are Art. 6 I lit b. GDPR and Art. 6 I lit. f GDPR; our legitimate interest in connection with the disclosure of data to independent real estate consultants stems from the freedom of choice to fulfill also contractual relationships with independent brokers or sub-brokers. The legitimate interest in conducting credit checks derives from the legitimate interest of protection from bad debt);

● Fulfillment of a legal obligation, particularly in connection with the Money Laundering Act; (the legal basis is Art. 6 I lit. c GDPR);

● Promotional information about properties marketed by us or other authorized 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 the user's consent under 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 data subject's consent, the data subject has the right to revoke his or her consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent until revocation. 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 on grounds arising from his or her particular situation. Article 21 GDPR applies in this regard.

3. Transmission of data

If the data subject's request (e.g. in connection with an evaluation request) relates to offers from other partners of the Engel & Völkers Group, Engel & Völkers will pass on the personal data entered by the data subject to the respective company of the Engel & Völkers Group, subject to the consent of the data subject.

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

In addition, we transfer personal data to contractual partners (landlords, landlords, research clients) and support service providers such as notaries, lawyers, property managers, real estate developers as part of the processing of a contractual relationship, as well as in the context of solvency information or to supervisory authorities (e.g. for money laundering documentation). We may also transfer the data subject's data to third parties to the extent permitted by law. Third parties to whom we may disclose the data subject's personal data, regardless of our performance, include outside consultants (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), potential buyers or acquirers of all or part of our assets and/or business, and other third parties to whom the data subject has instructed us to disclose data or has provided consent.

In addition, we will only share the data subject's personal data with employees (permanent staff such as employees 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.

4. Transmission of data to non-EEA countries.

In addition to the previous paragraph on “Sharing of Personal Data,” the following applies:

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

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

If we seek a property for the data subject together with another licensing partner, the data subject's data will only be transmitted based on the data subject's prior consent. Note: Both we, as the first 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 the respective data processing. We and this other license 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 that processes the data subject's data.

Please refer to the above information 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 data subject should contact if the data subject wishes to assert his or her rights.

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

2. Purpose of processing and legal basis

3. Data Transmission

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, with the prior consent of the data subject.

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

Furthermore, we transmit personal data to contractual partners (owners, lessors, search clients) and service providers such as notaries, lawyers, property managers, real estate developers within the framework of processing a contractual relationship, as well as in the context of solvency information or to supervisory authorities (e.g., for money laundering documentation). We may also transfer the data of the data subject to third parties to the extent permitted by law. The third parties to whom we may disclose the personal data of the data subject, regardless of our performance, include external consultants (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 buyers or acquirers of all or part of our assets and/or activities, and other third parties to whom the data subject has instructed us to disclose the data or has provided consent.

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

4. Data Transmission to Countries Outside the EEA

In addition to the previous paragraph on "Sharing of Personal Data," the following applies:

The recipients of the personal data may be located outside the EEA/UK. In the event that 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 for an exception (Article 49 GDPR). Furthermore, where necessary, we intend to agree with the recipients on additional measures to ensure an adequate level of data protection. Copies of the appropriate safeguards (where relied upon) and a list of recipients outside the EEA/UK can be requested. Note: these copies may be reduced to the extent necessary to protect trade secrets or other confidential information.

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

III. We are searching for a property for the data subject together with another Engel & Völkers license partner (“referral”).

If we are searching for a property for the data subject together with another license partner, the data of the data subject will only be transmitted based on the prior consent of the data subject. Note: both we, as the first point of contact, and the Engel & Völkers license partner to whom your data is provided, process the personal data of the data subject. Both - we and this license partner - are independently responsible for the respective data processing. We and this other license partner do not have access to each other's data and do not process the data of the data subject jointly. If the data subject wishes to assert their rights, please check in advance whether they wish to assert them with us or with the other Engel & Völkers partner who processes the data of the data subject.

Please refer to the information above on how we process the data of the data subject in relation to the marketing of their property, what rights the data subject has in this context, and the people to contact if the data subject wishes to assert their rights.

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

2. Purpose of Processing and Legal Basis

If the legal basis is the consent of the data subject, the data subject has the right to withdraw their consent at any time without affecting the lawfulness of processing based on 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 them for reasons arising from their particular situation. This is subject to Article 21 GDPR.

3. Data Transmission

We will transmit the personal data of the data subject to third parties only 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 provided their consent. If data is transferred to third parties based on legitimate interest, this will be explained in these data protection provisions.

4. Data Transmission to Countries Outside the EEA

In addition to the previous paragraph on "Sharing of Personal Data," the following applies:

5. Retention and Deletion of Personal Data

We retain the personal data of the data subject for the time necessary to achieve the purposes for which the data was collected and subsequently processed, including any retention period required by applicable law (e.g., retention of accounting records).

In the context of application procedures that conclude without hiring, the data of the data subject will be regularly retained for another six months for documentation purposes and then deleted or destroyed, along with the documents that have been submitted to us. With the consent of the data subject to process the data for future application procedures, we also retain them for a proportionally longer period of time.