Information Note for Newsletter Subscription & Subscriptions Management
Impact Developer & Contractor SA, headquartered in Bucharest- Romania, Willbrook Platinum Business & Convention Center, Building A, floor 1, Bucuresti – Ploiesti Road, no. 172 – 176, Sector 1, registered at the Trade Register with J40 / 7228/2018, fiscal code RO 1553483 and Bergamot Developments S.R.L, based in Bucharest, Șos. Bucharest-Ploiesti, 172-176, Willbrook Platinium & Convention Center, Building A, floor 1, office no. 1, Sector 1, registered in the Trade Register under no. J40 / 6057/2017, fiscal code RO 37471856, as operators of your personal data in the context of subscribing to commercial communications, I would like to inform you how this data is processed.
If for the purpose of subscribing to the commercial communications other operators will be involved, respectively other affiliated companies of the two mentioned operators, this information note will be modified and amended accordingly.
The purpose of the processing of personal data
The processing of your data aims to allow the management of subscriptions to commercial communications and allows us to: send you commercial communications taking into account the interests you marked at the time of subscription; to send you communications regarding news, events / contests and promotions organized by operators, to perform statistical analyses on the performance of this service, but not limited to them.
If at the time of subscription using the tablets available in sales offices or at trade fairs, you have filled in and the phone number you should know that we will be able to send you commercial messages for the purposes mentioned above or we will be able to contact you by phone.
If the subscription to commercial communications was made by any means other than the use of the tablet, we will use as the communication channel exclusively the email address provided at the time of subscription by checking the appropriate box on the subscription. Under these conditions, by using an API, only information including: name, surname, email address, source and date and time of the subscription will be transmitted in the consent management platform.
Subscription to marketing communications is done in two steps (double eight in). To ensure the accuracy of the personal data collected, after completing the form and subscribing to our newsletter, we will send you an email that will contain a link to confirm the email address, which will be valid for 48 hours. If, after the expiration of the 48-hour period, you have not confirmed your email address, your personal data provided by completing the form will be deleted from our database.
Basis of processing
We process your data for the above purposes under art. 6 para. (1) lit. a from GDPR – respectively the express consent expressed by you by going through the subscription process, respectively providing the data within the subscription form and confirming these data by accessing the validation link.
Types of personal data subject to processing
– Mandatory: name, surname, e-mail;
– Optional: phone number
– Observed: date and time of subscription, IP address, source from which the subscription was made.
Regarding the processing of your data having as source the websites operated by the other operators from the Impact group, this will be done based on art. 6 para. (1) lit. f of the GDPR – the legitimate interest of operators, who are part of the same economic group, on the centralization of consents on commercial communications and their management in a unitary database, with adequate security measures.
Failure to provide mandatory data will lead to the impossibility of using the service.
Your newsletter subscription data (respectively name, surname, date and time of subscription and email address) may be sourced from the forms on the websites impactsa.ro, greenfieldresidence.ro, luxuria-residence.ro, boreal-plus. ro through which you have expressly expressed your desire to subscribe to the commercial communications either by filling in the data in the newsletter subscription form, or by checking the appropriate box on the tender form, or by checking the appropriate box on the contact.
Also, your data (name, surname, email address, date and time of subscription) may be sourced from the Impact Genius program to which you have subscribed.
Last but not least, the source of the data can be represented by the completion by you on the tablets available at the profile fairs or in the sales offices of the data necessary for subscribing to the marketing communications.
Categories of persons concerned
Individuals who appear in the sales offices of any of the residential complexes, those who subscribe to these communications in the context of participation in real estate fairs where operators are present, or those who tick the box corresponding to subscription to commercial communications on websites operated by to these operators.
Recipients of data
Your data is not subject to transfer outside Romania.
In the event that we decide to use a proxy for the processing of your data for the purposes set out above, we will do so only with the prior conclusion of a contract of a proxy pursuant to art. 28 of the GDPR and ensuring the transfer of responsibility to him.
Your personal data will be stored until the exercise of the right of deletion. If you exercise only a right of opposition in respect of commercial communications, they will not be deleted, but only properly marked, so that you will no longer receive such communications in the future. In general, your data will be stored within 3 years of obtaining consent or the last interaction with you.
Email addresses and personal data provided but not confirmed within 48 hours of receiving the confirmation link will be automatically deleted immediately.
Personal data security measures
As for personal data collected through each of the operators’ websites, they are transmitted via an API to the database that manages consents.
Regarding the security measures applicable to access to the database, the principle of necessary and sufficient access in relation to users’ service duties was taken into account, as were the internal rules on passwords associated with user accounts.
In order to ensure compliance with the principle of data accuracy, the use of the email address as a communication channel will start only after you have gone through the process of confirming the email address.
Exercise of rights
In accordance with the provisions of art. 15 – 22 of the GDPR (General Regulation on data protection 2016/679), you have the following rights that you will be able to exercise by making a request to firstname.lastname@example.org.
- The right to withdraw consent – which does not affect the processing carried out during the period of validity of this consent and which can be exercised at any time by clicking on the unsubscribe link available in each commercial communication sent or by making a request to withdraw consent. This right may be exercised in respect of any of the channels of communication.
- The right to be informed refers to the obligation of the operators to provide you with correct information regarding the processing of data, regarding the way in which your personal data are used;
- The right of access means that you have the right to obtain from us a confirmation that we process or do not process your personal data, and if so, we offer you access to this data as well as information about how it is processed. You also have the right to obtain a copy of the data we process in respect of you;
- The right to portability refers to the fact that you can receive personal data in a structured, commonly used and automatically readable format as well as the transmission of this data to another operator, subject to certain conditions provided by the provisions of the Regulation;
- The right to object to the right to oppose the processing of personal data when it serves a public interest or a legitimate interest of ours.
- The right to rectification refers to the correction, without undue delay, of inaccurate personal data;
- The right to delete / the right to be forgotten means that you have the right to delete your collected data without undue delay, in any of the following situations: they are no longer necessary to fulfil the purposes for which they were collected, withdrawal of consent, opposition to processing, collection illegal, deletion for compliance with a legal obligation or collection made with the provision of information society services;
- The right to restrict the processing can be exercised if the accuracy of the data is challenged for a certain period, sufficient to verify the data, if the processing is illegal but you do not want to delete the data only the restriction, if we no longer need personal data for processing but you are asking us to defend a right in court or if you have objected to the processing.
If you are not satisfied with the way we have resolved a request regarding the exercise of a right, you have the right to address a complaint to the National Authority for the Supervision of Personal Data Processing.