1. OUR COMMITMENT TO YOUR PERSONAL DATA
1.1. Spatzioo Management SRL., with headquarters in Bucharest, Sector 1, Drumul Pădurea Neagră str., no. 56, Corp A and B, ground floor, Lot 1, block BL04, apartment 1-3, registered at the Trade Register under number J40/120/2019, CUI RO 18709383, will process the personal data of the users of the www.spatzioo website. ro in accordance with its Personal Data Protection Policy ("Policy") and the General Personal Data Protection Policy of the IMPACT group ("IMPACT Policy") of which the company is a part, according to the legislation in force.
1.2. The policy is based on the provisions of Regulation no. 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC ("General Data Protection Regulation" or "GDPR"), which is in effective from 25 May 2018, as well as the applicable national legislation.
1.3. The personal data processing method of Spatzioo Management SRL is the same as that of the companies in the IMPACT group, namely IMPACT DEVELOPER & CONTRACTOR S.A., BERGAMOT DEVELOPMENTS S.R.L., IMPACT FINANCE & DEVELOPMENTS S.R.L., and the database is managed jointly with the IMPACT group .
1.4. The GDPR defines personal data as "any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more many specific elements, specific to his physical, physiological, genetic, psychological, economic, cultural or social identity".
1.5. Spatzioo Management SRL is committed to implementing the highest standards of confidentiality and transparency regarding the personal data it processes in its current activity. Full protection and transparency regarding the processing of your personal data in the course of our business are our highest goals.
1.7. Any information regarding the processing of your personal data can be requested to the e-mail address firstname.lastname@example.org belonging to the Data Protection Officer appointed in accordance with the provisions of the GDPR.
2.1. Your use of our services is subject to this Policy as well as the Policy on cookies. When you use our services, you agree to the terms of this Policy. The purpose of the Policy is to inform our customers about how we collect, store and use personal data.
2.2. If you do not agree with the Policy, please stop using our services.
2.3. The use of the www.spatzioo.ro site does not necessarily require the provision of personal data. However, if you decide to provide us with personal data, we would like to explain to you how we process the data you provide.
3. CATEGORIES OF PERSONAL DATA COLLECTED
The personal data we process as a result of your use of the website www.spatzioo.ro may include:
- contact information, such as your first and last name, email address, telephone number;
- details about the type of services you want, real estate preferences, available on the site;
- Your IP which is collected when you contact our operator on the website;
- other information that you send us, when making a request on the website or as a result of sending them by email or phone.
4. METHODS OF COLLECTION OF YOUR PERSONAL DATA
4.1. We collect your data that comes from a request by e-mail, phone or through the contact form on the website:
4.1.1. We collect and process personal data relating to name, surname, e-mail address, telephone number in order to maintain a correspondence or communication with you. Thus, if you make a request by e-mail, phone or through the contact form on the website, we will process your data in order to resolve it.
4.1.2. In this context, if the situation presented by you for the request requires it, we may transmit your contact details to financial and government institutions, transport companies or the post office.
4.1.3. With the exception of the situation set out above, the data provided by you while browsing the www.spatzioo.ro website will be used by Spatzioo Management SRL only for its own purposes and will not be transmitted to third parties except in compliance with the legal provisions.
4.2. We collect your data that comes as a result of a request to be contacted by a consultant:
4.2.1. We collect personal data relating to name, surname, email address, telephone, interest in contracting and which come as a result of the fact that you have requested to be contacted by a consultant in this regard, filling in the fields on the website (if is the case).
4.2.2. In this regard, our consultants will contact you to provide you with more information and send you a personalized offer.
4.2.3. After completing the contact form, your data is imported into the database of Spatzioo Management SRL.
4.2.4. In case you have expressly consented to your personal data being processed for marketing purposes by Spatzioo Management SRL, respectively for sending newsletters, information about the products and services of Spatzioo Management SRL or events, contests organized by us , Spatzioo Management SRL will process your data for this purpose.
5. THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA
We may collect and process personal data for the following purposes:
- offering our or group companies' products and services;
- sending invitations for events organized by Spatzioo Management SRL or the companies in the group;
- compliance with our legal obligations (such as obligations to keep accounting records and supporting documents);
- analyzing, improving our services and communications to you;
- protecting the security and managing websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
- their transmission to third parties, if you have expressly given your consent;
- marketing campaigns, customer surveys, market analysis, sweepstakes, contests or other promotional activities or events, where you have expressly consented;
- for any purpose related and/or ancillary to any of the above or any other purpose for which your personal data has been provided to us.
6. DIRECT MARKETING
6.1. We promote our services to you and to others. We use customer information to send invitations and communications promoting the products and services we provide. To the extent that you have expressed your agreement in this regard, by ticking the box in the contact form, we will be able to use the personal data provided in order to send communications regarding the products and services we provide.
6.2. In all cases, you will have the possibility to unsubscribe from receiving marketing information by accessing the unsubscribe link that you will find within each communication of this type.
6.3. Please note that in the case of an unsubscribe request, there may be a period of up to 48/72 hours in which you may still receive information or marketing communications, due to considerations related to the operation of changes in the system. Unsubscribing from receiving marketing e-mails does not prevent the further transmission of transactional e-mails through which we may inform you about the status of the transaction we may conclude.
7. SHARING AND TRANSFER OF YOUR PERSONAL DATA
7.1. We can provide access to the personal data that you provide to the companies in the IMPACT group, respectively IMPACT DEVELOPER & CONTRACTOR S.A., BERGAMOT DEVELOPMENTS SRL, IMPACT FINANCE & DEVELOPMENTS SRL, our authorized persons - mainly Spatzioo Management SRL service providers, but we retain control over your personal data and we will use appropriate safeguards, in accordance with applicable law, to ensure the integrity and security of your personal data. In terms of access to other companies within the group, access will always be limited to the personal data they may need to provide a service to you.
7.2. We may also disclose your personal data when you instruct or give us permission to do so or when we are required by applicable law, requests by judicial or official bodies to do so, or in order to investigate fraudulent activities or criminal, actual or suspected.
7.3. We will not transfer personal data outside the EEA, unless the transfer is subject to one or more specified safeguards or exceptions, i.e. a suitability decision, Standard Contractual Clauses, binding corporate rules.
7.4. In the absence of an adequacy decision, the Standard Contractual Clauses, the mandatory corporate rules, the transfer of personal data to a third country or to an international organization takes place only under the following conditions:
7.4.1. the data subject has explicitly consented to the proposed transfer, after being informed of the possible risks of such transfers to the data subject due to the lack of a suitability decision and adequate safeguards;
7.4.2. the transfer is necessary for the execution of a contract between the data subject and the operator or for the execution of pre-contractual provisions adopted at the request of the data subject;
7.4.3. the transfer is necessary for the conclusion or execution of a contract concluded in the interest of the data subject between the operator and another natural or legal person;
7.4.4. the transfer is necessary for important reasons of public interest;
7.4.5. the transfer is necessary for the establishment, exercise or defense of legal claims;
8. STORAGE AND SECURITY OF PERSONAL DATA
8.1. Ensuring the confidentiality of the personal data you transmit to us is an important concern for us. We have implemented technical and organizational measures to maintain the confidentiality and security of your personal data in accordance with our internal procedures regarding the storage, disclosure and access of personal data. Personal data may be stored on our technology systems, those of our contractors or in hard copy.
8.2. The site is protected by the SSL (Secured Socket Layer) standard encryption system. This technology encrypts all your personal data that you transfer to Spatzioo Management SRL.
9. YOUR RIGHTS
9.1. We would like to inform you that, within the framework of the regulations on the protection of personal data provided by the General Regulation on the protection of data EU 679/2016, if we process your personal data, you have the following rights:
- the right of access, provided by art. 15 of the GDPR, based on which you can ask us, free of charge, to confirm whether or not we are processing personal data concerning you. You can also ask us for a copy of the data we process about you. Applications must include relevant information to identify you in our database. We will resolve your request, within a maximum of 30 days;
- the right to information – involves informing the data subjects in a concise, transparent and easily accessible manner about the processed data;
- the right to rectification, provided by art. 16 of the GDPR, which you can exercise, by making a request through which you can ask us to modify the information we already have about you. You can make such a request when you notice that your data is incomplete or inaccurate;
- the right to restrict processing, provided by art. 18 of the GDPR, which you can exercise when you dispute the accuracy of the data, consider the processing to be unlawful or object to the deletion of the data. Following the exercise of this right, we will still be able to store your data, performing other processing operations being possible only with your consent, except in cases expressly provided by law;
- the right to portability, provided by art. 20 of the GDPR, which you can exercise only for cases where the processing is based on your consent or the contract and only if your data is processed by automated means. If you meet the conditions, you can send us a data porting request to the operator you want;
- the right to oppose the processing of data for marketing purposes, provided by art. 21 of the GDPR. You can exercise this right at any time, and we guarantee that your data will no longer be processed for this purpose. However, it is possible that a reasonable period of time (up to 72 hours) is required to register and process your request during which you may still receive marketing communications from us;
- the right to erasure, provided by art. 17 of the GDPR, based on which we have the obligation to delete the personal data we process about you. This right is not an absolute one, having applicability only in certain situations expressly provided by law. When making a deletion request, please be aware that deleting them can be a complex process.
- the right to contact the National Authority for the Supervision of Personal Data, the public authority in Romania, with headquarters in B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania, website http://www.dataprotection.ro, which aims to protect the fundamental rights and freedoms of individuals, especially the right to private life , family and private, in relation to the processing of personal data and the free circulation of these data ("ANSPDCP"), in case you report a violation of the GDPR.
- 9.2. In order to exercise these rights, please send us a written request, to the e-mail address email@example.com, with the subject ˝Personal information request˝.
10. UPDATE OF OUR DATA PROTECTION POLICY
The most recent update of the Policy was made in September 2021. We reserve the right to periodically update and amend this Data Protection Policy to reflect any changes to how we process your personal data or any changes of legal requirements. In the event of any such modification, we will display the modified version of the Policy on our website and/or otherwise make it available.
For additional information on the content of the data protection policy, please contact us at firstname.lastname@example.org.