PRIVACY POLICY
Respect for the right to the protection of personal data as well as the right to privacy is one of the fundamental missions of CORDIA PARCULUI RESIDENTIAL PROJECT SRL (Parcului20).
We therefore take all necessary steps to process your personal data in accordance with the principles established by the applicable data protection legislation in Romania, including Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 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 (“GDPR”).
Personal data means 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 factors specific to his physical, physiological, genetic, mental, economic, cultural or social identity.
The processing of personal data is done by: CORDIA PARCULUI RESIDENTIAL PROJECT SRL headquartered in 19-21 Primaverii Blvd., Building B, 1st Floor, Apartment 15, 1st District, Bucharest, registered under no. J40/4984/2016 at the Trade Register, having the Tax ID Code 35914965.
Parcului20 is a controller within the meaning of the GDPR, namely it establishes the means and purposes of the processing of personal data.
In certain personal data processing contexts, CORDIA PARCULUI RESIDENTIAL PROJECT SRL jointly determines the purposes and means of processing alongside another controller: C.D.S. Cordia Development Services S.R.L. with its registered office in 19-21 Primaverii Blvd. 19-21, Building B, 1st Floor, 1st District, Bucharest, registered under no. J40 /15769/2015 at the Trade Register, having the Tax ID Code RO35362631. In these contexts, the two companies are joint controllers within the meaning of Article 26 of the GDPR. The privacy policy of the joint controller is available at www.cordia.ro.
Click on one of the links below to go to a specific section:
- What kind of personal data do we process?
- Personal data of minors
- Special categories of Personal Data
- For what purpose and on what basis do we process your personal data?
- Transmission of your personal data
- Do we collect personal data from third parties?
- Do we transfer your data outside the EU / EEA?
- Your provision of other natural persons’ personal data
- How long do we keep your personal data?
- What are your rights?
- Is your data secure?
- Links to other websites
- Questions or complaints
- Policy changes
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WHAT KIND OF PERSONAL DATA DO WE PROCESS?
If you are a client or potential client
We collect personal data from most interactions with you, and in other aspects of our business activity. The categories of data we process are the following:
- data required for providing you with an offer following your request and data necessary to keep in contact with you (e.g. name, email address, telephone number, address);
- information about your request, including your special requirements and preferences related to the apartment;
- additional personal data necessary for the conclusion of the contracts between you and us (for example, for the conclusion of a rental contract we will need the series and number of your national ID card as well as your address, while for the conclusion of a sale contract we will need your personal identification number in order for a notary public to authenticate the contract);
- information about the vehicles that you can bring to our property, for example the vehicle’s registration plate number;
- information you provide regarding your marketing preferences;
- personal data provided for newsletter subscription;
- reviews and opinions about our services;
- any other information you choose to provide to us.
Also, surveillance cameras and other security measures on our property can capture or record images of clients, tenants and visitors in Parcului20’s public places (such as office entrances or the building’s hallways), as well as your location data (through images captured by the surveillance cameras).
You can always choose what personal data you provide us. However, if you choose not to provide certain personal data, if the basis for our processing is the compliance with a legal obligation, contractual obligation or an obligation necessary for the conclusion of a contract, we will be unable to provide you with certain services, for example: (i) if you do not wish to give us your first name, last name, email address or telephone number when requesting an offer, we will not be able to send you the requested offer, or (ii) considering the legal obligations in force, in case you do not want to give the notary public your personal identification number for the completion and authentication of the sale contract, the contract will not be able to be concluded.
If you are a potential employee
We collect the information sent through your resume and any other information submitted with your resume and / or provided during the interviews in which you participated.
If you are a visitor in our location
Surveillance cameras can capture or record images of visitors in public places (such as the entrances to our locations).
If you are a user of our website www.parcului20.ro
No personal data is required to read the information on the website.
However, for the technical operation of the portal, we collect the time and date when the website was accessed and the IP address that accessed it.
Some personal data is required for the use of some services (e.g. the contact form). For more details, please refer to the sections corresponding to the operation done on the website.
If you are a representative or contact person of our suppliers or business partners
We collect your name, job title, and any other data provided by you or the company that you represent.
If you are an employee
Please read our personal data protection policy applicable to employees brought to your attention at the time of employment and available at any time at the Human Resources Department.
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PERSONAL DATA OF MINORS
We protect the confidentiality of data obtained from children under 16 years. If you are under the age of 16 and we process your personal data based on your freely given consent, we are obligated to additionally obtain the consent of your parents / legal guardians.
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SPECIAL CATEGORIES OF PERSONAL DATA
The term “special categories of personal data” refers to racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as to genetic data, biometric data, data concerning health or data on sexual life or sexual orientation.
In general, we do not process such special information unless you wish to provide it to us.
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FOR WHAT PURPOSE AND ON WHAT BASIS IS YOUR PERSONAL DATA PROCESSED?
If you are a client
- Requesting an offer
Purpose: we process your personal data in order to respond to your requests
Basis: conclusion of a contract
- Keeping in contact with you
Purpose: we process your personal data in order to keep in contact with you so that we can send you all necessary and relevant information
Basis: the conclusion and execution of a contract; we may also send you information about your rented or purchased location on the basis of our legitimate interest of letting you know of all relevant information.
- Concluding a contract with you
Purpose: we process your personal data for the valid conclusion of the contract requested by you.
Basis: conclusion and execution of a contract and the fulfillment of legal obligations
- Feedback
Purpose: we process your personal data to ensure that you have had a pleasant experience while using our company’s services
Basis: our legitimate interests to constantly improve the services we offer and to provide services which are appropriate and in accordance with the standards of our customers
- Marketing:
Purpose: we process your personal data for marketing purposes, such as commercial newsletters and marketing communications regarding new products and services or other offers that we think may be of interest to you
Basis: we rely on a legitimate interest in promoting our services by sending the offers which we consider to be of interest to you (see “Right to object” under “Your rights”)
If necessary, in accordance with the applicable law, we will obtain your consent before processing your personal data for direct marketing purposes. In this case, we hereby notify you that you will be able to withdraw the consent for processing for marketing purposes at any time, in which case you will no longer receive any marketing communication from us.
We will include an unsubscribe link which you can use if you do not want to receive any more messages from us.
Also, when taking part in certain events (e.g. real estate fairs), it is possible to have some photos taken, some of which could be distributed online in order to show others how these events are. In each and every such scenario, because we fully take into account your right to privacy, we will do our best to inform you that photographs will be taken (for objecting to these photos please see the “Right to Object” in the “Your rights” section)
- Other communications: by e-mail, mail, phone or SMS
Purpose: these communications are made for a specific reason such as: (i) to respond to your requests, (ii) if you have not completed a request for an offer or a payment, we may send you an e-mail to remind you to complete the process, (iii) to inform you about the manner in which complaints and / or incidents which may have occurred during our collaboration have been resolved
Basis: our legitimate interests to provide services at the desired standard by addressing any claims / complaints and to ensure our full availability; if we respond to a request in the course of executing the contract concluded with you, the basis on which the processing is based is the execution of a contract
- Analysis, improvement and research:
Purpose: to ensure a constant qualitative development of our services, we carefully analyse each complaint / suggestion from you so that we can compile statistical reports to identify problems and find the best solutions to remedy them
Basis: we rely on our legitimate interest to provide services which meet your and our standards
If you are a visitor in our location
Purpose: we process your personal data for the protection of people and goods within our location.
Basis: our legitimate interest to ensure both the protection of the persons in the location and of the property of the clients/ employees within our location
If you are a user of our website www.parcului20.ro
Purpose: to monitor traffic in order to identify errors and / or any other website malfunctions
Basis: we base this data processing activity on our legitimate interest, namely to constantly improve our website and provide you with a fully functional website by fixing any errors
If you are a representative or a contact person of our suppliers or business partners
Purpose: conducting contractual relations with suppliers and business partners
Basis: execution of a contract
If you are a potential employee
Purpose: assessing your application for employment
Basis: conclusion of a contract
If you are an employee
Please read our personal data protection policy applicable to employees brought to your attention at the time of employment and available at any time at the Human Resources Department.
For all abovementioned categories of persons, we can also process your data in the context of the following activities:
- Restructuring, internal reorganization or sale of assets or shares:
Purpose: we process your information for the abovementioned operations
Basis: our legitimate interest to carry out the operations, especially if they would be impossible to do without the processing of your data
However, we asssure you that this possible processing will be carried out in accordance with this policy and by implementing measures in order to ensure the confidentiality of your data.
- Security:
Purpose: we process personal data for the security of goods and the physical integrity of persons
Basis: we rely on our legitimate interests to protect your property and ours as well as to protect the persons in our locations
- Legal grounds:
Purpose: in some cases, we must process information which may include personal data in order to resolve legal disputes or complaints as well as investigations and to comply with the applicable legal regulations, to implement an agreement or in order to comply with requests from public authorities and/or institutions to the extent that these requests meet the legal requirements.
Basis: the basis for the processing may be represented by a legal obligation (where we are legally required to disclose certain personal data to public authorities) or by our legitimate interest to resolve potential disputes and / or complaints.
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TRANSMISSION OF YOUR PERSONAL DATA
To give you the expected level of professionalism and to provide you with high quality services, your data can be transmitted to the headquarters of the company and to the members of the portfolio of companies of which Cordia Park Residential Project SRL is a part. We also provide your data to our service providers and other third parties, as detailed below:
- Providers: in order to provide the requested services, in some cases we will need to pass some of your personal data to service providers, while they have the capacity of processors and process the data in our name, on our behalf and in accordance with our instructions (e.g. software, IT, accounting services and/or medical services providers).
- Business partners: In some cases, we can associate with other companies to provide you with products, services or offers.
- Authorities and / or public institutions: (i) to comply with legal provisions, (ii) to respond to their requests, (iii) for reasons of public interest (e.g. national security).
Your privacy is important to us, which is why, where possible, the transmission of personal data in accordance with the above shall be done only pursuant to a confidentiality agreement from the recipients in order to ensure that this data is kept safe and that such information is provided in accordance with applicable laws and applicable policies. In any case, we will always send to the recipients only the information strictly necessary for achieving that purpose.
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PERSONAL DATA WE COLLECT FROM THIRD PARTIES
To provide you with the expected level of hospitality and the best level of service, we may collect information about you from our business partners and other third parties, as shown in detail below:
- Business partners: such as online real estate sale platforms, social media services, in accordance with the settings you made for these services, or recruitment companies through which you applied for an open position in our company.
In any case, we ensure that your data collected from third parties will be processed under the same conditions as if it were collected directly from you. We also will collect only what is necessary for our purposes (see Section “FOR WHAT PURPOSE AND ON WHAT BASIS IS YOUR PERSONAL DATA PROCESSED?”).
In addition, when we will first contact you, we will first let you know the source from which we obtained your personal data.
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INTERNATIONAL TRANSFERS OF PERSONAL DATA (OUTSIDE THE EU/EEA)
We may transfer your data to our service providers and other third parties that may be based in countries other than the one you reside in, and in some cases in countries outside the EU/EEA.
Although data protection laws in these countries may be different from those in our country, we will take the necessary steps to ensure that your personal data is processed in accordance with this policy and in accordance with applicable law.
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YOUR PROVISION OF OTHER NATURAL PERSONS’ PERSONAL DATA
If you provide us with the personal data of other individuals, please inform them in advance of the way in which their personal data will be processed as described in this Privacy Policy.
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HOW LONG DO WE KEEP YOUR PERSONAL DATA?
Your personal data is retained for the full duration of the purposes detailed in this Policy, if a longer period of retention is not required or permitted by the applicable law.
We constantly review the need to keep your personal data, and to the extent that that processing is no longer required and there is no legal obligation to keep your personal data, we will delete / destroy your personal information as soon as possible and in such a way as to prevent subsequent recovery or reconstitution (e.g., we will delete / destroy all data of persons that have not been hired after having been interviewed, unless there is a serious prospect of future employment).
If personal information is printed on paper, it will be destroyed in a way that eliminates it completely, and if it is stored on an electronic medium, it will be erased by technical means as to ensure that the information can no longer be subsequently recovered or reconstituted.
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WHAT ARE YOUR RIGHTS?
As the data subject, you are entitled to the following rights under GDPR:
- Right of access: You may request (i) a confirmation that your personal data is processed or not, and, if so, access to such data and information about the data, and (ii) a copy of your personal data that we may hold (Article 15 of the GDPR);
- Right to rectification: You can inform us of any changes to your personal data or you may ask us to correct the personal data that we hold about you (Article 16 of the GDPR);
- Right to erasure ( “right to be forgotten”): In certain circumstances (such as (i) where data has been collected illegally, (ii) the deadline for storing the data has expired, (iii) you have exercised the right to object, or (iv) data processing was done on the legal basis of consent and you have withdrawn your consent), you may ask us to delete the personal data we hold about you (Article 17 of the GDPR);
- Right to restriction of processing: In certain circumstances (such as when you are contesting the accuracy of such data or the basis of the processing), you may ask us to restrict your data processing for a certain period (Article 18 of the GDPR);
- The right to data portability: You have the right to ask us to send your personal data to third parties or directly to you (art. 20 of GDPR);
- Right to object: In certain circumstances (such as the processing that has a legitimate interest as legal basis), you may request that we no longer process your data (Article 21 of the GDPR).
- If we process your personal data based on your consent, you may withdraw this consent.
If we process your personal data based on your consent, you may withdraw this consent at any time. In this case, your data will no longer be processed by us, unless a legal provision forces us to keep and archive it. In any case, we will inform you if there is such a legal provision and we will expressly indicate it .
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IS YOUR DATA SAFE?
We take your personal data security seriously, which is why we have implemented important security measures necessary to protect against unauthorized access to data or unauthorized modification, disclosure or destruction. This requires internal reviews of the data collection, storage and processing practices and of the security measures, as well as physical security measures to protect against unauthorized access to systems where we store personal data.
We also require our service providers and business partners to take all necessary steps to protect against unauthorized access to data or unauthorized modification, disclosure or destruction of data.
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LINKS TO OTHER WEBSITES
Our website contains links to third party websites. Please note that we do not take responsibility for the collection, use, storage, sharing or disclosure of data or information by such third parties. If you use or provide information on third-party websites, the terms and privacy policies of those sites apply. We encourage you to read the privacy policies of the websites you visit before submitting any personal information.
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QUESTIONS OR COMPLAINTS
If you have any questions or concerns regarding the processing of your personal data or if you wish to exercise any of the abovementioned rights, you are welcome to contact us using our contact form available on the website or by sending us an e-mail at the following address: dpo@parcului20.ro and we will reply within 30 days of the receipt of the request.
We are also providing you with the contact details of our Data Protection Officer: dpo@parcului20.ro.
To the extent that you do not have electronic means or do not want to use them, you can submit a written request at our registered office in Bucharest, 1st District, 19-21 Primaverii Blvd., Building B, 1st Floor, Apartment 15.
To the extent that you are not satisfied with the manner in which your request has been resolved, you may file a complaint with the National Supervisory Authority for Personal Data Processing.
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Policy Changes
From time to time, this Privacy Policy may change in accordance with the amendments to the data policy legislation or based on changes to our services or organizational arrangements. If we make any material changes to this Policy, we will publish a link to the revised policy on the homepage of our website. If we make significant changes that will impact your rights and freedoms (for example, if we begin processing your personal data for purposes other than those specified above), we will contact you before we begin this processing.
To help you track the most important changes, we will include below a history of the changes as to help you identify the changes to this Policy.
Last change: 25th of April 2019