Policy

The undersigned Daniela Cattini, born in La Spezia (SP) on the 13/10/1959, domiciled for the purposes of the hereby notice at the company handling real estate mediation Casaconvista Srl, located in Lerici (SP), Via Petriccioli 5, tel: 0039.0187.968153, regular e-mail address: info@casaconvista.eu, certified e-mail address: casaconvista@legalmail.it (hereinafter “Agency”), from the very same represented and acting as “data Controller” (hereinafter “Controller”) of Your personal data (hereinafter, as one, also “Data”) of which You are the “Concerned“, pursuant to Regulation UE 2016/679 (hereinafter “Regulation”), and of which the Agency has come into possession through the entrustment of the mediation assignment, supplies the following information in order for You to grant a specific consent, unequivocal, informed, free and mindful of the Processing of Data that might happen also through computer/online tools.

1) Data source.
The data necessary for the development of the contractual relationship between the Parties, as well as the data otherwise obtained throughout such activity, is gathered by the Agency directly from the Concerned and/or through third parties, not to mention consulting various outside, both public and private, databases.

2) Notice availability.
The Agency provides the possibility to consult such notice: a) every time a Client’s personal details are gathered; b) every time the Controller is directly asked; c) through web consultation on the homepage of the site www.casaconvista.eu.

3) Data processing purposes.
The Agency, for its institutional purposes, connected to or aimed towards its own activity, handles Your data with the following objectives:

1. purposes connected to obligations required by laws, regulations and community norms, not to mention instructions given by Authorities to such goal legitimated from the law or from surveillance and/or monitoring powers;
2. contractual purposes, connected to or aimed towards the establishment and management of clientele relationships, such as the acquirement of preliminary information in the eventual closure of a contract;
3. customer satisfaction surveying concerning service quality, run directly by the Agency through the aid of specialized associations using face-to-face or telephone interviews, interactive questionnaires, market tests;
4. promotion of the Agency’s products and services, carried out by sending advertising material, telephone agreements and any other form of electronic communication (e-mails, text messages, multimedia messages, social networks publishing);
5. data communication and/or transferring to third parties when pertaining to the promotion and/or sale of products and services through traditional and/or automatized ways.

With reference to the purposes of letters c), d), e), we inform You that, at any moment, You will be free to withdraw the consent given through the ways listed in the present notice.

4) Nature of Data bestowal.
You have the right to know that the bestowal of data can have both mandatory and optional nature, not to mention entail consequences in case of an eventual refusal.
In this regard, it’s to be clarified to You that:

1. the bestowal of Your consent for the purposes of letters a) and b) of point 3 has mandatory nature inasmuch required by law or to follow up on contractual obligations (as indicated in art. 6, clause 1, letters b) and c) of the Regulation). The refusal of Your consent for the purposes indicated at letter b) of point 3) will therefore prevent the Agency from performing the task You bestowed upon it or from coming to the closure of the contract of which You are part;
2. the refusal to consent to Data processing for the purposes of letters c), d), e) of point 3 is, instead, of optional nature, will not entail any prejudicial consequence against You and can be from You withdrawn at any given time, within the purposes connected to sending advertising material, customer satisfaction surveying concerning service quality, fulfillment of market tests or business communication, through telephone contacts and any other form of electronic communication (e-mails, text messages, multimedia messages, whatsapp, websites publishing, social networks publishing, and so on), run directly by the Agency through the aid of specialized associations using face-to-face or telephone interviews, interactive questionnaires.

5) Particular Data.
Article 9 of the Regulation identifies as particular the data fit to reveal a person’s racial and ethnic origin, political opinions, religious or philosophic or labor beliefs, not to mention genetic and biometric details, details in relation to health or sex life or sexual orientation. It’s possible the Agency will come into possession of particular data in relation to specific procedures requested from the Concerned. In such case, the Concerned has the right to express a specific consent to the processing of their own sensitive data and the Agency will be able to use it only in a manner which is essential to perform the requested services and operations.

6) Retention of Data.
The Data will be kept for the time necessary to handle the contractual relationship and adhere to legal requirements, with particular reference to the Anti-money-laundering legislation. The Data is always handled in full respect of the processing’s proportionality precept (art. 5, clause 1, letter c) of the Regulation), according to which all personal Data and its various processing manners have to pertain to and not exceed the pursued purposes, in order to guarantee adequate safety and privacy and also to prevent unauthorized access or usage of any personal details as well as the equipment employed in their processing, not to mention allow a legitimate and proper processing.

7) Retention of Data timetables.
In accordance with what set out by art. 13, clause 2, letter a) of the Regulation, indications of the timetables regarding the retention of Data, based on the different processing purposes, are hereby supplied:

• with reference to letters a) and b) of point 3, the Data is to be kept for the time necessary to handle the contract and adhere to legal requirements;
• with reference to letters c), d), e) of point 3, the retention time is set at 10 years.

8) Processing of Data manners.
Concerning the purposes outlined at point 3, the personal Data can be also processed by a “Supervisor“, as in a physical person or society, also external to the Agency, who could be tasked with specific and defined assignments in relation to the handling and management of the data processing, as well as by one or more “Appointee(s)“, who will take care of the Data’s elaboration and material usage following instructions given by the Controller or Supervisor (subjects who, if not explicitly indicated on the present notice, are to be considered yet to be designated and not necessarily to be designated if the processing is but casual, and whose details will be provided to You in case of designation).
Still concerning the aforementioned purposes, the Data can be processed through manual, computer and/or otherwise automatized tools according to logistics strictly connected to the purposes of the processing itself and, nevertheless, in manners that guarantee its safety and privacy even in the chance of processing through remote communication tools.

9) Offshore Data transfer.
The Data could be transferred towards European Union Countries and third Countries (as in not part of the European Union) exclusively in the range of purposes at letters a) and b) of point 3. In such case, the intention to transfer any personal details needs to be communicated to You beforehand and authorized from You only if an Europe-adequate level of data protection is guaranteed.

10) Communication of Data.
The Data, on account of the established relationship and with the aim to facilitate and allow closure of the deal, can be communicated to: i) outside partners; ii) additional agents in business mediation (companies as well) pinpointed by the Controller to liaise with in order to fulfill the assignment to the former entrusted by the Concerned; iii) banks and other subjects operating in the banking industry; iv) counterparts and their eventual specialists and advisers; v) notaries to arrange notarial deeds and/or connected activities relevant to the assignment entrusted to the Controller; vi) companies and/or experts carrying out services to fulfill technical/cadastral/construction/urban paperwork; vii) insurances leading to the drafting of policies relevant to the assignment entrusted to the Controller; viii) websites for real estate advertising; ix) arbitration boards and, in general, all those public and private subjects whose communication is necessary for the correct fulfillment of the purposes at point 3); x) Surveillance/Management Powers and other Authorities, for the purposes connected to obligations required by laws (anti-wear protection, anti-money-laundering legislation) and/or regulations not to mentions instructions given by the very same Authorities.

All subjects, belonging to the categories under possible Data communication, will use such Data acting as ‘controllers’ pursuant to the law or to specific consent, in full autonomy, being unrelated to the original processing run by the Agency, that is as ‘outside supervisors’. To know, at any time, the subjects to whom Your details might be communicated, it’s sufficient that You ask for the updated list addressing the data processing Controller at the Agency headquarters.

Lastly, Your Data will be disclosed to all of the Agency’s employees and associates, designated processing supervisors and/or appointees, in relation to the execution of each and every one’s assigned work and tasks.

The Data processed by the Agency will not be object of broadcasting.

11) Rights of the concerned.
Within the limits and in accordance with the conditions pinpointed by articles 15 – 23 of the Regulation, the Agency guarantees and acknowledges Your practice of the following rights:

• the right to access the personal data filed in their hard-copy/electronic archives;
• the right to ask for their amendment, update and removal, if incomplete or inaccurate, not to mention to oppose to their processing in the case of legitimate and specific reasons;
• the right to obtain amendment of inaccurate personal data without gratuitous delay. Considering the processing purposes, the concerned has the right to obtain additions to incomplete personal data by supplying an integrative statement too;
• the right to obtain removal of personal data concerning them without gratuitous delay, if one of the reasons at art. 17, clause 1 of the Regulation stands;
• the right to obtain limitation to the processing whenever one of the circumstances at art. 18, clause 1 of the Regulation stands;
• the right to data portability within the limits and manners listed by art. 20 of the Regulation.

You also have, at any given time, the right to withdraw consent to Your data’s processing, without in any way compromising the legitimacy of the processing based on prior consent, not to mention to oppose at any given time to the processing with marketing purposes (opposition right).
You have the right to receive information related to any undertaken action that concerns one of the aforementioned requests or to the effects resulting from the practice of one of the aforementioned rights, without gratuitous delay and, in any case, within a month of having submitted the request itself, extendable, if necessary, for two more months; You also have the right to submit a complaint to a supervising authority as well as judicial review.
Except in the case the Data processing breaks any of the general precepts imposed by the Regulation, the practice of such rights must be relevant and motivated and cannot imply withdrawal of a given consent or a cancellation request of the Data You supplied for the contract’s closure and fulfillment as in point 3), letters a) and b), in so far as and as long as the Data is necessary for such purposes.
The rights in object can be practiced, even through a representative, via request addressing the data processing Controller or Supervisor at the following contacts:

• – Via Petriccioli 5, CAP 19032, town Lerici (SP)
• – tel: 0039.0187968153
• – regular e-mail address: info@casaconvista.eu
• – certified e-mail address: casaconvista@legalmail.it

In the practice of such rights, You can invest, in writing, physical people, companies, associations or systems with a mandate or proxy; You can also benefit from a trusted person’s assistance. The Agency, to guarantee actual practice of Your rights, will implement suitable measures aimed at facilitating access to the Data, the manners to do so, as well as reducing timetables to acknowledge Your request.
Lastly, it’s to notice that You can submit a complaint to a supervising authority as in to the Warrant Officer for the Protection of Personal Data in the following ways:

1. round-trip, registered mail to the attention of the Warrant Officer for the protection of personal data, Piazza di Monte Citorio n.121, 00186 Rome;
2. e-mail address: garante@gpdp.it or protocollo@pec.gpdp.it;
3. fax: 06/69677.3785

All information related to complaints that can be issued by the Concerned are available at the Warrant Officer’s website www.garanteprivacy.it

12) Data processing Supervisor and Appointee.
The Processing Supervisor and Appointee, pursuant to art. 24 of the Regulation, is Daniela Cattini.