Privacy and Cookies Policy
Last updated: March 11, 2020
I. General provisions
This Privacy and Cookies Policy is applicable to Fairmont Residence, as well as any company existing or that shall exist at a certain point in time in its group of company and Neo Group of Company ("us", "we", "our" or the "Company"). Fairmont Residence operates the website https://new.fairmont.town/ (the "Website").
This section informs you of our policy regarding the collection, use and disclosure of personal data we receive from certain categories of individuals, such as Website’s users, buyers, tenants, employees and collaborators/contractual partners of the Company. The Company will process personal data by complying with the provisions herein.
The purpose of this policy is to explain to you which data we process, why we process them and what we do with them when you enter into a legal relationship with the Company (e.g., when you rent/buy properties from us or when you visit this Website).
II. Purposes, bases and categories of personal data
In compliance with the provisions of General Data Protection Regulation 2016/679 (“GDPR”), personal data processed by the Company may be used for purposes, such as:
1. Taking the necessary steps for concluding and performing the contracts and fulfilling the legal obligations, as well as for achieving the legitimate interests of the Company, which also include operations, such as requesting an offer, making payments and drafting the financial and accounting documents based on art. 6 para. (1) letter b), c) and f) of GDPR. For these purposes, we will process personal data, such as first and last name, data in the ID cards of buyers or tenants, contact details, data about property and bank details.
Through this Website, we collect personal data of potential buyers who requested us for an offer, as well as the personal data of landowners, who decide to acquire, enter into a join venture or to different hybrid schemes that transfer the value of the land to shares in the future project, either residential, office or mixed-use.
2. Management and maintenance of this Website, which involves storage of cookies as they are described at the Section B below, based on art. 6 para. (1) letter a) and f) of GDPR.
While using our Website, we may ask you to provide us with certain personal data that can be used to contact or identify you. These personal data may include, but is not limited to your first and last name, e-mail address, information that your browser sends whenever you visit our Website ("Log Data").
This Log Data may include information, such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages and other statistics.
3. Performance of personnel recruitment operations based on art. 6 para. (1) letter a) of GDPR. Through this Website, we collect personal data of candidates, such as first and last name and data included in the CV.
4. Carrying out marketing and advertising activities, including subscription to our newsletters based on art. 6 para. (1) letter a) of GDPR. For these purposes, we will process personal data, such as first and last name,
image and voice, if the case may be.
You may opt out of receiving any, or all, of these newsletters, marketing or promotional materials and other information that that may be of interest to you from us, by following the unsubscribe link or instructions provided in any email we send.
5. Monitoring/security of persons, premises and/or goods of the Company based on art. 6 para. (1) letter f) of GDPR. For this purpose, we may process personal data, such as image, first and last name (if they are identifiable) and car’s registration number, if the case may be.
6. The work relations, which entail data processing for the performance of the employment contracts, the fulfilment of the legal obligations devolving upon the Company in connection with these contracts and/or the achievement of the Company’s legitimate interests deriving from the work relations based on art. 6 para. (1) letter b), c) and f) of GDPR. For these purposes, we will process personal data of our employees, such as first and last name, data in the ID cards, contact details and bank details.
7. Solving of your requests, questions or complaints based on art. 6 para. (1) letter a) and b) or/and f) of GDPR. For this purpose, we will process personal data, such as first and last name and contact details;
8. Communication with our collaborators and contractual partners based on art. 6 para. (1) letter b) and f) of GDPR. For this purpose, we will process personal data, such as first and last name and contact details.
We will not process personal data of children without the prior consent of their parents/legal representatives.
If we intend to use your personal data for a purpose other than the one for which they have been collected, we will inform you in advance about the secondary purpose and will provide any other information requested as per GDPR.
The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
We continuously try to ensure you the most appropriate level for the protection of your personal data and, to this end, we have implemented appropriate technical and organisational protection measures. We are constantly working for improving our security measures.
IV. Processing duration and categories of recipients of the personal data
The Company processes your personal data for the period of time required based on the legal provisions applicable, same for the cases when the data are required for pursuing a legitimate interest.
After the expiry of the storage period, personal data shall be destroyed or erased from the IT systems or rendered anonymous, to the extent that they need to be used for scientific or statistical research purposes.
Personal data are mainly processed by the Company’s personnel in charge of processing these data. We will disclose your personal data where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Website. Also, there are situations where your personal data are sent to our contractual partners, which may be:
a) subcontracting third parties (for example, contractors, manufacturers, accounting firms, audit firms, IT services providers, maintenance companies, post offices, couriers);
b) competent authorities and institutions;
c) law firms, public notaries, auditors, bailiffs, real estate brokers, safety and security firms;
d) banks and financial institutions;
e) third-parties in case of transfer of contractual rights.
Whenever we use subcontractors, we ensure that the requirements set by GDPR are met and that your personal data are processed in an adequate manner.
V. Rights of data subjects
According to GDPR, you benefit from the following rights with regard to personal data processing:
a) right to be informed – the right to receive a minimum content of information in relation to the processing activities performed by the Company, in accordance with GDPR;
b) right of access to data – the right to obtain from the Company, upon request and based on the conditions set by GDPR, confirmation as to whether or not your personal data are being processed, and, where that is the case, access to the personal data and information on the processing;
c) right to rectification - the right to obtain from the Company, without undue delay, the rectification of inaccurate personal data concerning you;
d) right to erasure of data – you can exert your right to erase the data from the Company’s files, in accordance with the data protection provisions;
e) right to restriction of processing – may be exerted if one of the following applies: the accuracy of the personal data is contested by you, the processing is unlawful and you oppose the erasure of the personal data, the Company no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims, you have objected to processing pending the verification whether the legitimate grounds of the controller override yours;
f) right to data portability - the right to receive the personal data from the Company in a structured, commonly used and machine-readable format;
g) right to object - the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, save for contrary legal provisions. This right may be exerted in the following conditions: you request in written to the Company the exertion of this right, you specify the data and the legitimate grounds relating to your particular situation;
h) right not to be subject to an individual decision - the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. In relation to a decision based solely on automated processing, you have the right to obtain human intervention and to contest the decision, to the contact details specified in this policy;
i) right to contact the supervisory authority, namely the National Supervisory Authority for Personal Data Processing; and
j) right to lodge a complaint with the competent courts of law.
The rights listed above are not absolute. There are exceptions, which is why every received request will be analysed so as to decide if it is grounded or not. If the request is grounded, we shall facilitate the exercise of your rights. If the request is ungrounded, we shall reject it, but we shall inform you about the grounds of such a rejection and about the right to submit a complaint with the supervisory authority or the competent courts of law.
VI. Whom can you contact?
In order to exert your rights, you may submit a written request to the address [email protected].
We shall attempt to answer your request within 30 days. However, the term may be extended according to GDPR, depending on the complexity of the request, the large number of requests received during that period or the inability to identify you in due time.
If we use our best endeavours and we do not manage to identify you and you do not provide us with additional information in order to be able to identify you, we are not bound to answer your request.
B. COOKIES POLICY
The information presented below aims at providing users with more details on the placing and use of the cookies used by this Website.
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer's hard drive.
In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Website's functionality. These third party service providers have their own privacy policies addressing how they use such information.
For cookies which are not strictly necessary, as provided at Sections B – D inclusively above, you may withdraw your consent at any time by accessing the links below. It is important to note that the deactivation or refusal to receive certain types of cookies can make certain sections of the website difficult to view and use.
All the modern browsers offer the possibility to change the settings of cookies. You can configure the settings of the cookies following the instructions by accessing the links below.
Settings Cookie in Internet Explorer
Settings cookie in Firefox
Settings cookie in Chrome
Settings cookie in Safari
If we make any material changes to this Privacy and Cookies Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our Website.
If you have any questions about this Privacy and Cookies Policy, please contact us, or at the contact details provided at Section VI. above.