Impact Developer & Contractor S.A.’s personal data protection policy for the Boreal Plus website (www.boreal-plus.ro)
Our commitment to your personal data
- Impact Developer & Contractor S.A., headquartered in Loc. Bucharest, Willbrook Platinum Business & Convention Center, Building A, floor 1, Sos. Bucuresti – Ploiesti, no. 172 – 176, sector 1, registered at the Trade Register with J40 / 7228/2018, fiscal code RO 1553483 (“IMPACT”), will process the personal data of the users of the sites owned by the IMPACT group, respectively www.boreal-plus.ro, www.impactsa.ro, www.greenfieldresidence.ro, www.luxuria-residence.ro, according to art. 1.3 below, in accordance with its Personal Data Protection Policy (“Policy”) as well as the General Personal Data Protection Policy of the IMPACT group (“IMPACT Policy”) of which the company is a member, in accordance with in force.
- The policy is based on the provisions of Regulation no. 2016/679 on the protection of individuals 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 effective from 25 May 2018, as well as on the applicable national legislation.
- The method of processing IMPACT’s personal data is unitary within the companies from the IMPACT group, respectively BERGAMOT DEVELOPMENTS SRL, ACTUAL INVEST HOUSE, IMPACT FINANCE & DEVELOPMENTS SRL, and the group’s database, including the personal data collected, is administered jointly by the IMPACT group.
- The purpose of personal data processing is based on the main activity of the IMPACT group, namely real estate development, construction of residential or non-residential buildings, as well as ancillary activities for this purpose, such as promoting the group’s products and services or managing construction works.
- 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 identifying element, such as a name, an identification number, location data, an online identifier, or one or more many specific elements, specific to his physical, physiological, genetic, mental, economic, cultural or social identity ”.
6.IMPACT is committed to implementing the highest standards of confidentiality and transparency regarding the personal data it processes in its current activity. Total protection and transparency regarding the processing of your personal data in our business are our most important objectives.
7.Any information regarding the processing of your personal data can be requested at email@example.com belonging to the Data Protection Officer appointed in accordance with the provisions of the GDPR.
- If you do not agree with the Policy, please stop using our services.
Categories of personal data collected
The personal data we process as a result of your use of the boreal-plus.ro site, owned by the IMPACT group may differ, depending on your quality. Thus, in general, we can collect and process:
- Information you provide us when sending a CV to the dedicated e-mail address, data categories that may include: name, surname, email address, telephone number, studies, previous experience and any other data that you you can provide them to us on this occasion;
- Information you provide to us as a result of sending a request: name, surname, email address and / or telephone number;
- Information that we can access through the prism of a contractual relationship between two legal entities. In this sense, in order for the good development of the contractual relations, we can process personal data of the representatives and contact persons designated by our partners. These can consist of: name, surname, position, telephone number and email address.
In the case of customers or potential customers, we can collect and process the following categories of data:
- contact information, such as your name and surname, e-mail address, telephone number;
- details about the type of home you want;
- Your IP which is processed when you contact our operator on the site;
- information you provide to us by using the chat service;
- we can also collect personal data necessary for the conclusion of booking contracts / pre-contracts / sales contracts, they can refer to: name, surname, address, personal numerical code, series and number of identity card, income and source thereof;
- other information that you send us when you make a request on the site or as a result of sending it by email or phone.
Ways of collecting your personal data
The use of the site www.boreal-plus.ro and https://case.boreal-plus.ro/ as well as of the other sites owned by the IMPACT group, does not necessarily imply 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 to us.
- We collect your data that comes from an email or phone request.
- We collect personal data that refers to your name, surname, email address, telephone in order to maintain correspondence or communication with you. Thus, if you make a request by email or phone, we will process your data in order to resolve it.
- In this context, if the situation exposed by you to the request requires it, we will be able to transmit your contact data to financial and governmental institutions, transport companies or post office.
- Except as set out above, the data provided by you while browsing the sites managed by the IMPACT group will be used by the IMPACT group only in its own interest and will not be transmitted to third parties unless your prior consent has been obtained.
- We collect your data that comes as a result of a request to be contacted by a consultant (through the sites corresponding to the residential complexes)
- We collect personal data relating to name, surname, email address, telephone, interest in contracting (the type of housing you want) and which come from the fact that you have requested to be contacted by a consultant in this sense, filling in the fields on the site.
- In this regard, our consultants will contact you to provide you with more information and to send you a personalized offer.
- If you have expressly consented to your personal data being processed for marketing purposes by the IMPACT group, respectively for sending newsletters, information about IMPACT products and services or events, contests organized by us, IMPACT will process your data for marketing purposes.
- Your participation in the campaigns organized on the Instagram page, Facebook or on this Site as well as on the other sites owned by the IMPACT group
- When filling in some participation forms for the campaigns, we will collect the data as they will be defined in the Participation Regulations;
- We can ask for your identity card in order to identify yourself in case of awarding a prize as a result of participating in our campaigns;
- The good development of the relationship with our partners
- We may be in a position to transmit personal data to us from the representatives of our business partners. In this case, we may use the personal data you provide to us in order to manage and ensure the smooth running of the relationship between the parties. If necessary, we may use the personal data you provide to us to assess the satisfaction of business partners or for purposes related to marketing research.
The purposes for which we process your personal data
We may collect and process personal data for the following purposes:
- offering our products and services consisting of apartment houses or villas in residential complexes built by companies that are part of the IMPACT group;
- sending invitations to events organized by companies that are part of the IMPACT group;
- compliance with our legal obligations (such as obligations to keep records and supporting documents);
- analyzing and improving our services and communications to you;
- protecting security and managing access to our headquarters, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
- in order to identify the persons authorized to trade on behalf of our customers, beneficiaries, suppliers and / or service providers;
- their transmission to third parties, if you have expressly consented;
- marketing campaigns, customer surveys, market analysis, raffles, contests or other activities or promotional events, if you have expressly consented;
- execution and management of contractual relations with our partners;
- for any purpose related to and / or ancillary to any of the above or any other purpose for which your personal data has been provided to us.
Legal grounds for processing
Regarding the legal bases of the data processing on which the processing performed by IMPACT is based, in the context of this Site as well as in general are represented by: the consent of the data subjects, the steps of the data subjects necessary to conclude contracts with IMPACT or group companies. IMPACT respectively BERGAMOT DEVELOPMENTS SRL, ACTUAL INVEST HOUSE, IMPACT FINANCE & DEVELOPMENTS SRL, the execution of the existing contract between the parties, the legal obligations established in charge of IMPACT, especially those in fiscal matters and the legitimate interest.
As regards the legitimate interest of IMPACT in data processing on this basis, we specify that it concerns in particular the processing carried out in the context of actions to promote the brand. For example, a processing based on the legitimate interest is the one related to the publication of materials, especially in social media, which contain images of the people present at the events organized by IMPACT or the companies from the IMPACT group respectively BERGAMOT DEVELOPMENTS SRL, ACTUAL INVEST HOUSE, IMPACT FINANCE & DEVELOPMENTS SRL who interact with photos. In this context, IMPACT’s interest is in promoting the brand by publishing images or videos with people present at the events. It is specified in this sense that during the posts on social media made on the official pages of IMPACT, no persons from registrations / posts will be identified.
- We promote our services to you and others. We use customer information for invitations and communications that promote the products and services we provide. To the extent that you have agreed to this, by checking the box on the contact form, we will be able to use the personal data you provide to send communications about the products and services we provide.
- In all cases, you will be able to unsubscribe from receiving marketing information by accessing the unsubscribe link that you will find in each communication of this type.
- Please note that in the event of a request to unsubscribe there may be a period of up to 48/72 hours within which it is possible to receive further information or marketing communications, for reasons related to the operation of changes to the system. Unsubscribing from marketing emails does not prevent you from continuing to send transactional emails through which we can inform you about the status of the transaction that we may conclude.
Sharing and transferring your personal data
- We may provide access to the personal data you provide to companies in the IMPACT group, namely BERGAMOT DEVELOPMENTS SRL, ACTUAL INVEST HOUSE, IMPACT FINANCE & DEVELOPMENTS SRL, our authorized persons – mainly IMPACT service providers, but we will retain control on your personal data and we will use appropriate safeguards, in accordance with applicable law, to ensure the integrity and security of your personal data. With regard to the access of other companies within the group, access will always be limited to the personal data they may need to provide a service to you.
- We may also disclose your personal data when instructing or giving us permission to do so or when required by applicable law, requests of judicial or official bodies to do so, or to investigate certain activities. fraudulent or criminal, actual or suspected.
- We will not transfer personal data outside the EEA, unless one or more specified guarantees or exceptions apply to the transfer, ie an adequacy decision, Privacy Shield, mandatory corporate rules.
- In the absence of an adequacy decision, membership of the Privacy Shield, mandatory corporate rules, the transfer of personal data to a third country or to an international organization shall take place only under the following conditions:
- the data subject has explicitly agreed to the proposed transfer, after being informed of the possible risks of such transfers for the data subject, due to the lack of an appropriate decision and appropriate security measures;
- the transfer is necessary for the performance of a contract between the data subject and the controller or for the performance of pre-contractual provisions adopted at the request of the data subject;
- 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;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for the establishment, exercise or defense of legal claims.
Storage and security of personal data
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 accessing personal data. Personal data may be stored on our personal data technology systems, those of our contractors or in hard copy.
- We would like to inform you that, under the new regulations on the protection of personal data provided by the General Regulation on EU data protection 679/2016, when 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 process personal data concerning you. You can also ask us for a copy of the data we process about you. Applications must include relevant information in order to be able to identify you in our database. We will solve your request, in maximum 30 days;
- the right to information – implies the information in a concise, transparent and easily accessible manner of the data subjects regarding the processed data;
- the right to rectification, provided by art. 16 of the GDPR, which you can exercise, by formulating a request by 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 the processing, provided by art. 18 of the GDPR, which you can exercise when you challenge the accuracy of the data, consider that the processing is illegal or oppose the deletion of the data. Following the exercise of this right, we will still be able to store your data, the performance of 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 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 may take a reasonable amount of time (up to 72 hours) to register and resolve your request, and you may still receive marketing information from us;
- the right to deletion, 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 keep in mind that deleting them can be a complex process.
- the right to address the National Authority for the Supervision of Personal Data, the Romanian public authority, based in B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania, web page http://www.dataprotection.ro, which aims to protect the fundamental rights and freedoms of individuals, especially the right to privacy , family and private, in connection with the processing of personal data and the free movement of such data (“ANSPDCP”), if you report a breach of the GDPR.
- In order to exercise these rights, please send us a written request, on the e-mail address firstname.lastname@example.org, with the subject ˝Request for personal information˝.
- If you are not satisfied with the way we have handled your request, you can contact the National Authority for the Supervision of Personal Data Processing.
The most recent policy update was made in November 2020. We reserve the right to periodically update and modify this Personal Data Protection Policy to reflect any changes to the way we process your personal data. or any changes to legal requirements. In the event of any such changes, we will display the modified version of the Policy on our website and / or make it available in another way.
For additional information on the content of the data protection policy, please contact us at the e-mail address email@example.com.