Personal data protection policy

Personal data protection policy of www.greenfieldresidence.ro

1. Our commitment to your personal data
   • Impact Developer & Contractor SA a Romanian legal entity established in Bucharest, 172-176 Bucuresti-Ploiesti Road, Willbrook Platinum Covention Center, Building A, Floor 1, Office no. 1, District 1, registered at the Trade Register under no. J40/7228/2018, with Fiscal Code 1553483, bank account no. RO83BTRL05001202G09191XX opened with Banca Transilvania, will process the personal data of the users of the sitegreenfieldresidence.ro in accordance with its Personal Data Protection Policy (“Policy”).
   • 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 the Directive 95/46/EC (“General Data Protection Regulation” or “GDPR“), which enters into force from May 25^th, 2018, as well as on the applicable national legislation.
   • The method of processing personal data of IMPACT is unitary within the companies from the IMPACT Group, respectively Bergamot Developments SRL, Greenfield Copou Residence SRL, Actual Invest House SRL, and the database is managed jointly by the IMPACT Group.
   • The GDPR defines personal data as “any information about 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 their physical, physiological, genetic, mental, economic, cultural, or social identity”.
   • IMPACT DEVELOPER & CONTRACTOR SA undertakes to implement the highest standards of confidentiality and transparency regarding the personal data it processes in its current activity. The protection and total transparency regarding the processing of your personal data in our activity are our most important objectives.
   • Please also consult our Cookie Policy available at greenfieldresidence.ro which explains our use of cookies / other web location devices through our website.
   • Any information regarding the processing of your personal data can be requested at dpo@impactsa.ro, belonging to the Data Protection Officer appointed in accordance with the provisions of the GDPR.

2. Agreement
   • Your use of our services is subject to the provisions of the Policy and the Cookie Policy. By using our services, you agree to the terms of this Policy. The purpose of the Policy is to inform our clients about the collection, storage, and use of personal data.
   • If you do not agree with the Policy, please stop using our services.
   • The use of the site greenfieldresidence.ro 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 the manner in which we process the data you provide to us.

3. Categories of collected personal data

The personal data we process as a result of your use of thewww.greenfieldresidence.ro site may include:

• contact information, such as your first and last name, e-mail address, telephone number;
• details about the type of housing you want or other information about the project
• your IP which is processed when you contact our site operator;
• details of your visits to our website (in this sense we recommend that you read the Cookies Policy);
• other information that you send to us when you make a request on the site or as a result of sending it by email or phone.

4. Ways of collecting your personal data

• We collect your data from an email or phone request
  • We collect personal data relating to your last name, first name, email address, telephone number 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 required by your request, we may send your contact details to financial and governmental institutions, transport companies or the post office.
  • Except as set forth above, the data provided by you while browsing the greenfieldresidence.ro will be used only in your own interest and will not be passed on to third parties unless your prior consent has been obtained.
• We collect your data as a result of a request to be contacted by a consultant
  • We collect personal data relating to your last name, first name, email address, telephone number, interest in contracting (the type of home you want) and which is provided as a result of your request to be contacted by a consultant, by 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 in order to send you newsletters, information about products and services or events, contests organized by us, our company will process your data with marketing purposes.

5. 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 type houses or villas in residential complexes built by Impact Developer & Contractor SA and the affiliated companies within the Group;
• sending invitations for events organized by Impact Developer & Contractor SA and the companies within the Group;
• compliance with our legal obligations (such as obligations to keep records and supporting documents);
• analysing 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 clients, beneficiaries, suppliers and/or service providers;
• their transmission to third parties, if you have expressly consented;
• marketing campaigns, client surveys, market reviews, raffles, contests or other promotional activities or events, if you have expressly consented;
• 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.

6. Direct marketing
   • We promote our services to you and others. We use customer information to send out 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 such communication.
   • Please note that in the event of an unsubscribe request, there may be a time limit of up to 48/72 hours in which you may receive further information or marketing communications for reasons related to the operation of system changes. Unsubscribing from marketing emails does not preclude further transmission of transactional emails through which we can inform you of the status of the transaction that we may conclude.

7. Sharing and transferring your personal data
   • We may provide access to personal data you provide to companies in the IMPACT Group, namely Bergamot Developments SRL, Actual Invest House SRL – our authorized persons – mainly service providers, but we will retain control over the data and we will use appropriate safeguards in accordance with the applicable law to ensure the integrity and security of your personal data. With regard to the access of the other companies in the Group, access will always be limited to the personal data that they may need to provide a service to you.
   • We may also disclose personal data when you are instructing or giving us permission to do so or when required to do so by the applicable law, requests from judicial or official bodies to do so, or for the purpose of investigating fraudulent or criminal, actual or suspected activities.
   • We will not transfer personal data outside the SEE, unless one or more specified guarantees or exceptions apply to the transfer, i.e. an adequacy decision or binding corporate rules.
   • In the absence of an adequacy decision or binding 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 adequacy 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 arrangements adopted at the request of the data subject;
     • the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the controller 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 defence of legal claims; and / or

8. 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 access to personal data. Personal data may be stored on our personal data technology systems, those of our contractors or in print.

9. Your rights
   • We want to inform you that in the new regulations on the protection of personal data provided by the General Regulation on data protection EU 679/2016, when we process your personal data, you have the following rights:

• the right to 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 may also request a copy of the data about you that we process. Requests must include relevant information in order to be able to identify you in our database. We will resolve your request within a maximum of 30 days;
• the right to information – implies the information in a concise, transparent, and easily accessible way of the data subjects regarding the processed data;
• the right to rectify, 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, other processing operations being possible only with your consent, except as expressly provided by law;
• the right to portability, provided by art. 20 of the GDPR, which you can only exercise in 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 in that time you may still receive marketing information from us;
• the right to delete, provided by art. 17 of the GDPR, based on which we have the obligation to delete the personal data about you that we process. This right is not an absolute one, being applicable only in certain situations expressly provided by law. When requesting a deletion, please note that deleting the data can be a complex process.
• the right to address the National Supervisory Authority For Personal Data Processing, the Romanian public authority, based in 28-30, G-ral Gheorghe Magheru Blvd., District 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, with regard to the processing of personal data and the free movement of such data (“ANSPDCP“), in case you report a breach of the GDPR.
  • In order to exercise these rights, please send us a written request, to the e-mail address dpo@impactsa.ro, with the subject “Request for personal information”.
  • If you are not satisfied with the manner in which we managed your request, you can contact the National Supervisory Authority For Personal Data Processing.

10. Our Privacy Policy update

The most recent policy update was made in March 2022. We reserve the right to periodically update and amend this Data Protection Policy to reflect any changes to the way we process your personal data or any changes of the 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 manner.

11. Contact

For additional information on the content of the Data Protection Policy, please contact us at the e-mail address dpo@impactsa.ro.