

Information clause
GDPR - PERSONAL DATA PROCESSING POLICY
Information required under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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). Data Controller: Prillmont Inmobiliaria Sociedad Limitada Avenida de Palmela 18, local 6 03730 Xàbia/Jávea Alicante España Telephone: Spain +34 613518254, Telephone: Poland +48 537732451, Email: investprill@investprill.com Personal Data: all information relating to an identified or identifiable natural person based on one or more specific factors that determine the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person, including image, voice recording, contact details, location data, information contained in correspondence, information collected through recording equipment or other similar technology. Policy: this Personal Data Processing Policy. Data Subject: any natural person whose personal data is processed by the Data Controller, e.g., a person visiting the Data Controller's office or website, or sending an email inquiry. DATA PROCESSING BY THE CONTROLLER In connection with its business activities, the Controller collects and processes personal data in accordance with applicable regulations, including in particular the GDPR and the data processing principles provided therein. The Controller ensures transparency in data processing, in particular by always providing information about data processing at the time of collection, including the purpose and legal basis for processing – for example, when concluding an intermediation agreement or services provided in connection with such an agreement. The Controller is obligated to ensure that data is collected only to the extent necessary for the indicated purpose and processed only for the period necessary. When processing data, the Controller ensures its security and confidentiality, as well as access to information about such processing for those directly concerned. If, despite the security measures in place, a personal data breach occurs (e.g., server hacking or data loss), the Controller will inform the data subjects of such an event in a manner consistent with the regulations. PERSONAL DATA SECURITY To ensure data confidentiality, the Controller has implemented procedures that allow access to personal data only to authorized persons and only to the extent necessary for the performance of their duties. The Controller uses organizational and technical solutions to record and perform operations on personal data only by authorized persons. The Controller also takes all necessary measures to ensure that its subcontractors and other collaborating entities guarantee the application of appropriate security measures whenever they process personal data on behalf of the Controller. The Controller conducts ongoing risk analysis and monitors the adequacy of the data security measures used to address identified threats. If necessary, the Controller implements additional measures to enhance data security. PURPOSES AND LEGAL BASIS FOR DATA PROCESSING BY THE CONTROLLER Personal data are processed for the following purposes: concluding and performing a real estate brokerage agreement pursuant to Art. 66 § 1 of the GDPR. Article 6, paragraph 1, point b) of the GDPR, handling requests (e.g., via the contact form, email), pursuing claims related to the brokerage agreement concluded with the Client pursuant to Article 6, paragraph 1, point f) of the GDPR, conducting statistical analyses, storing data for archiving purposes, conducting marketing activities undertaken independently or in cooperation with other entities pursuant to Article 6, paragraph 1, point a) of the GDPR, implementing provisions included in the sale of advertising (including banners, mailings), responding to letters and requests, carrying out activities related to ensuring security. Providing personal data is a statutory requirement and a condition for concluding a brokerage agreement. Failure to provide data to the extent required by the Controller may result in refusal to conclude the agreement. Personal data will not be subject to automated decision-making (profiling).RIGHTS RELATED TO PERSONAL DATA PROCESSING In accordance with the General Data Protection Regulation, data subjects have the following rights: to access their data and the right to amend, delete, or restrict processing, to object to processing to the extent that processing is based on the Controller's legitimate interest, to withdraw consent to data processing to the extent that processing is based on consent; withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal, to file a complaint with the President of the Personal Data Protection Office regarding a violation of the right to personal data protection or other rights granted under the GDPR. DATA RECIPIENTS The recipients of personal data will be employees (associates) of the Controller, entities entrusted with data processing by the Controller (e.g., software providers, hosting providers), other cooperating intermediaries (including within the MLS system), and notaries. PERSONAL DATA PROCESSING PERIOD Personal data will be processed for the duration of BEWE Nieruchomości's brokerage services, and then until the statute of limitations for claims arising from the concluded brokerage services agreement expires or until the data retention obligation under applicable law, in particular the obligation to retain accounting and tax documents, expires. DATA TRANSFER OUTSIDE THE EUROPEAN ECONOMIC AREA Data may be transferred to third countries (including the USA) in connection with activities undertaken on social media platforms and the use of plugins and other tools derived from these platforms (including Facebook and Instagram). CHANGES TO THE PERSONAL DATA PROCESSING POLICY This Policy is effective from May 25, 2018, and will be reviewed and updated as necessary. Please send all correspondence regarding the processing of your personal data to: investprill@investprill.com



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