NOTICE ON THE PROCESSING OF PERSONAL DATA
DATA ON THE CONTROLLER
The responsibility for processing of personal data in the capacity of the controller lies with: Name: KADENA INTERNATIONAL REALTY DOO BEOGRAD Address: Milutina Milankovica St. No. 11v, Novi Beograd Registration number: 21496987, TIN: 111529348. In case of any questions or requests regarding the processing or protection of your personal data, you can contact us at the e-mail address: email@example.com or by writing to the above address of our headquarters.
SUBJECT OF THE PRIVACY RULES
These Rules include the ways of processing your personal data when you interact with the Company, i.e. when you express interest in buying or leasing real estate, or when you contact us in connection with the conclusion of a contract for the sale or lease of real estate within a residential and business complex, i.e. when: • visiting our website; • visiting our profiles on social network pages; respectively pages that serve to advertise company’s projects • communicating with us by phone or through the contact form on the website or by e-mail or in some other way; • using our systems and applications; • visiting our sales facilities; • attending our presentations or business events; • participating in our promotional or marketing activities (e.g. signing up for the newsletter), surveys and the like; • concluding a contract with us regarding the purchase and sale of real estate, the lease of real estate or another contract. It is mandatory to submit only those personal data that we collect for the fulfillment of certain legal obligations. Providing personal data on all other legal grounds is voluntary, but please note that if you deny us some data, in certain situations we may not be able to provide you with some services.
PERSONAL DATA WE COLLECT
1. Personal data of visitors to our website: When you visit our website, respectively website that serve to advertise company’s projects, the browser you use on your device will automatically, even without your activity, send to the server of our website: the IP address of the device from which the request was sent and which has access to the Internet, date and time of access, name and URL of the downloaded file, website/application accessed from (referrer URL), browser you are using and, if necessary, the operating system of the computer that supports the Internet, as well as the name of your provider. The server temporarily saves the above data in a so-called log file for the following purposes: ensuring the establishment of a smooth connection, ensuring the comfortable use of our website/application, respectively website that serve to advertise company’s projects, and evaluating the security and stability of the system. The data is stored temporarily during the visit to the page, and then it is automatically deleted. The legal basis for IP address processing is Article 12, paragraph 1 point 6) of the Law on Personal Data Protection (legitimate interest), which derives from the above-mentioned purpose of data processing. 2. Marketing and other activities: For the purposes of sending commercial messages as well as for the purposes of implementing marketing activities, personal data is collected exclusively on the basis of the person’s consent (for example, in the case of signing up for a newsletter, direct marketing, etc.), so that data that you have submitted to us through the contact form, by phone or by e-mail is used in accordance with the purpose established here. If you have given your consent to receive the newsletter via e-mail, sms, viber, whats app and/or to receive other marketing material that contains information about current offers and promotions related to the services from our portfolio, we use your e-mail address or phone number and name and surname for sending information about available real estate, promotions, news and offers for buying, selling or renting real estate. We store and process this data for the purpose of sending commercial messages, newsletters and/or other marketing material, which includes actions (offers, promotions, etc.). The legal basis for data processing when sending commercial messages, newsletters and/or other marketing material is your consent in accordance with Article 12, paragraph 1 point 1) of the Law on Personal Data Protection. You can revoke your consent to receive newsletters/marketing materials at any time. Revocation of consent does not affect the admissibility of processing that was carried out on the basis of consent before the revocation. You can do this by, for example, unsubscribing from the newsletter reception list on our website, respectively website that serve to advertise company’s projects. You can find the newsletter unsubscribe link at the end of each newsletter, and you can unsubscribe for Viber, Whats app or SMS directly via the Viber, Whats app application or SMS message, if you have given your consent for this type of notification. If you revoke your consent, we will delete your data. We inform you that in the case of sending newsletters/viber/whats app/sms, we can engage external partners in order to perform these services so that your data can be transferred to those persons (data on e-mail address and phone number). 3. Personal data of buyers/tenants of real estate The Company processes personal data of persons that is necessary for the preparation, conclusion of contracts and execution of contractual obligations, i.e. realization of rights and obligations from concluded contracts on the purchase and sale of real estate and contracts on the lease of real estate within the residential and business complex. Personal data that we collect from you are: name and surname, address (street, house number, postal code, town, country), personal ID number, ID card/passport number, copies of personal documents and contact information (phone number, e-mail address). We get all your personal data directly from you. In addition to the Real Estate Purchase Agreement and the Real Estate Lease Agreement, the Company may also conclude contracts with you that are concluded in the phase preceding the purchase process, such as real estate reservation agreements, deposit agreements for the purchase of real estate, etc. and in that case, we collect the following data from you: name and surname, address (street, house number, postal code, city, country), as well as contact data (phone number, e-mail address). We process your data for the purpose of preparation of Real Estate Purchase Agreements, preparation, conclusion and execution of Real Estate Lease Agreements and other Agreements listed in this section. The legal basis for the processing of this data is Article 12, paragraph 1, points 2) and 3) of the Law, taking into account the performance of contractual obligations, i.e. legal obligations. 4. Other personal data that you have given us: We process the personal data that you voluntarily gave us when making the initial contact, during subsequent communication (for example, through a phone call, e-mail, questionnaires, etc.), when visiting the company’s Internet page or pages that serve to advertise the company’s project or profiles on social networks, as well as that personal data that resulted from our communication or business cooperation, which includes your identification data (name and surname) as well as your communication data (contact phone number and e-mail address). We process your data in accordance with the established purpose, and in order to respond to your inquiry based on your interest, and present our offer and provide other required information. The legal basis for data processing is Article 12, paragraph 1 point 6) of the Law on Personal Data Protection (legitimate interest). Our and at the same time your (legitimate) interest in this kind of data processing stems from the need to answer your questions, when it is necessary to solve existing problems and to ensure your satisfaction as customer of our services respectively as a user of our website. If you participate in one of our surveys/questionnaires, such participation is voluntary. With anonymous surveys, we do not store data that allows us to conclude who the survey participant is. We only store the date and time of your participation. We consider any personal data that you have given us through the survey as voluntarily given and we store it in accordance with the provisions of the Law. In the event that you have given your consent to conduct the survey, the legal basis for data processing is based on your consent in accordance with Article 12, paragraph 1, point 1) of the Law on Personal Data Protection. In that case, you have the right to revoke your consent at any time. Revocation of consent does not affect the admissibility of processing that was carried out on the basis of consent before the revocation. By submitting personal information, the company’s website, respectively, websites that serve to advertise company’s projects, visitor understands and agrees with the fact that the security, integrity and privacy of his/her data cannot be 100% guaranteed, despite the fact that the Company constantly takes all optimal measures to protect it. 5. Personal data of the social networks users On the pages of the Company’s social networks, the Company processes data for the purpose of informing people about the business and residential complex, the real estate we offer for sale, the services we provide, promotions, important information, news in the Company, and all for the purpose of interacting with visitors to social networks as well as for the purpose of providing answers to questions, complements and criticisms and for the purpose of communicating with persons interested in our services. Data processing is carried out in the interest of achieving communication, that is, in order to interact and improve relations with followers. The legal basis for processing your data is Article 12, paragraph 1 point 6) of the Law (legitimate interest). We have only limited influence on the processing of data by the operators of social network platforms (for example, member administration and information sharing). Where we can influence and adjust parameters for the processing of your data so that the operator of the social network platform acts in accordance with data protection, we take all measures at our disposal. However, in many places we cannot influence the operator’s data processing, nor do we know what data the operator is processing exactly. The platform operator manages the entire IT infrastructure of the service, adheres to its own data protection rules and has a special user relationship with you (if you are a registered user of the social network service). Additionally, the operator is solely responsible for all issues related to your user profile data, to which we as a company do not have access. You can find more detailed information about the processing of data by the social network platforms operators and the possibilities of objection in their data protection rules. Data that you have entered on our social network pages, such as, for example, comments, videos, pictures, likes, public notices, etc., are published by the platform operator, and at no time do we process it for any purpose other than the intended one. We reserve the right to delete illegal or inappropriate content, if necessary. We also process your data for the purpose of communicating with you. We may share your content on our page, if that is the purpose of the social network platform.
ACCESS TO YOUR DATA
We consider your personal data a business secret and protect it as such in accordance with applicable laws and best practice. Within our Company, only those organizational units, i.e. those employees who need it to fulfill the purpose for which the personal data was collected, have access to the data that you have made available to us. We will process your personal data ourselves, while third parties have the right to access and process your personal data only in the situations described below: • Our reliable partners, i.e. legal entities with whom we cooperate in business and who help us in regular business. These can be persons who develop and maintain IT solutions and platforms, servers, as well as persons who provide you with services on behalf of the Company, for example, for marketing purposes. In that case, those legal entities process your personal data exclusively for our needs. These service providers are, in accordance with the concluded contracts, obliged to use the data entrusted to them exclusively in accordance with our instructions, and strictly for the purpose we have determined with the obligation to adequately protect your data and to keep it confidential; • Persons with whom we cooperate in business, when we determine that it is necessary to protect certain legitimate interests of ours, for example, tax advisors, accountants, insurance companies, lawyers and other advisors. In that case, those persons process your personal data exclusively for our needs; • Competent bodies in the implementation of supervision over the legality of business operations and actions, as well as other legal entities when it is necessary to perform some of our legal duties, for example, auditors. In that case, those legal entities process your personal data for the purpose assigned to them by law; • Other parties in connection with business transactions such as, for example, sale of the company or part of the company, reorganization, merger, joint venture or any other type of disposal of our company or assets; Also, there may be a need to forward part of your inquiries to contractual partners (for example, suppliers, architects or contractors for inquiries regarding specific products/materials, etc.), for the purpose of processing your inquiry. However, in those cases, the inquiry is previously anonymized, so that a third party cannot bring it into any connection with you. If in an individual case the forwarding of your personal data is necessary, we will inform you beforehand and ask for your consent. Third parties are limited in their ability to use your personal data for any purposes other than those listed, and are obliged to protect and process your personal data in accordance with legal, regulatory and contractual obligations. All legal entities with whom we cooperate have been selected in a very careful manner and when required by law, they are contractually obligated to keep personal data confidential, in accordance with Article 45 of the Law on Personal Data Protection.
TRANSFER OF YOUR PERSONAL DATA TO OTHER COUNTRIES
In certain cases, we may share your personal data or transfer them to other countries in accordance with the Law. When we do this, we transfer your data to servers located in the EU or in a country that provides an adequate level of protection in accordance with the legislation of the Republic of Serbia. Access will be allowed only to a limited number of persons, i.e. authorized persons exclusively for maintaining the functionality of the server.
HOW DO WE PROTECT YOUR PERSONAL DATA
Some of the protection measures we implement are as follows: • Application of modern methods of protection and control of access to data sources containing personal data; • Limiting access to sensitive data as well as limiting user accounts that can have access to certain data, introducing a system of roles and authorizations that will ensure that only certain employees who need access to data to perform work tasks can have access and perform processing of relevant data; • Continuous monitoring of all resources (physical spaces where your data is stored) used to process personal data. The purpose of implementing the above measures is to prevent the risk of destruction, loss, alteration, unauthorized disclosure or access to your personal data. The use of appropriate protection measures, in relation to your personal data, is also required from third parties who have the right to access and process your personal data. All personal data is stored on our server in the Republic of Serbia. Please note that the above safeguards do not apply to information or data that you choose to share publicly through social networks or messaging applications.
STORAGE PERIOD OF YOUR PERSONAL DATA
Personal data is stored for as long as is necessary to ensure the purpose for which the personal data was collected. If you have concluded a contract with us, we store the data while the rights and obligations from the contract last, and after that for as long as required by the applicable regulations. We shall retain your personal data even after termination of the contractual relationship if we need your personal data to establish, exercise or defend legal claims or to comply with applicable laws. To the extent possible, we will limit the processing of your personal data to those limited purposes after the termination of the contractual relationship. After the purpose has been fulfilled, i.e. the expiration of the legally prescribed period for storing of personal data is over, the personal data will be permanently deleted.
If you choose to exercise one or more of your rights listed below, we have the right to verify your identity, all for the purpose of protecting your personal data. You exercise your rights for free. Exceptionally, if your request is clearly unfounded or excessive (for example, you are asking for personal data that you yourself own), and especially if the same request is repeated frequently, we have the right to charge the necessary costs of processing your request or to refuse to process your request. Please send all questions and requests related to your rights in writing to the address specified in the section “Data about the Controller”. We will respond to your request immediately, and within one month at the latest, unless the exceptional complexity of the individual case requires an extension of the specified deadline. In order to protect you as the owner of the personal data, you need to properly identify yourself as the applicant, which will be a guarantee for the Company that it gives personal data to its owner. 1. Access to your personal data You have the right to ask us for information on whether we process your personal data, access to that data, as well as information on processing in accordance with Article 26 of the Law. 2. Correction of incorrect data, supplementing, deletion and restriction of use of personal data You have the right to request the correction of your incorrect personal data, as well as the right to supplement, delete and limit the use of your personal data. 3. Transferability of personal data You have the right to download and request the transfer of your personal data. 4. The right to revoke consent and to have data deleted You have the right to revoke your consent to the processing of personal data as well as to request the permanent deletion of your personal data that we processed on the basis of your consent. 5. Objection against the processing or handling of your personal data You have the right to object to the processing of your personal data as well as to our way of handling your personal data in general. Please, send your request to us by e-mail to the address specified in the section “Data about the Controller”, where in the title of the message you state Objection Against Processing and in the message itself you explain the reason for the objection and your request. 6. The right to file a complaint with the Commissioner for Information of Public Importance and Protection of Personal Data You have the right to file a complaint with the competent authority for the protection of personal data at any time – to the Commissioner for Information of Public Importance and Protection of Personal Data (https://www.poverenik.rs/).