Privacy Policy – Personal Data Processing Information

This privacy policy describes the characteristics of the processing of personal data collected and processed through the website www.palazzoxxvluglio.com (the Site and the Policy) by 25 REAL ESTATE S.r.l., with registered office at Via E. Estrafallaces, 26, 73100, Lecce (LE), Italy.

This policy does not apply to third-party websites, applications or content in general, even if accessible from the Site. In such cases, the data protection provisions of those third parties may apply, which may differ from those set out herein. We recommend you consult them before sharing any personal data.

1 – Data Controller and Data Processor

1.1 Controller of Collected Data

For the purposes of this Policy, the data controller is 25 REAL ESTATE S.r.l., with registered office at Via E. Estrafallaces, 26, 73100, Lecce (LE), Italy, registered with the Lecce Companies Register under number 04966080758, as well as the individual legal entity that has received a duly authorised sales mandate as a Real Estate Brokerage Agency and is duly published on the website www.palazzoxxvluglio.com, which processes your personal data in accordance with this privacy policy.

25 REAL ESTATE S.r.l. and the Real Estate Brokerage Agencies that have received a duly authorised sales mandate are legally independent entities, distinct from 25 REAL ESTATE S.r.l. Each of them processes the data of their respective clients as an independent data controller, as described in the privacy policy adopted by each one.

The controller of your personal data is therefore, depending on the circumstances, either 25 REAL ESTATE S.r.l. or the individual Real Estate Brokerage Agency that has received a duly authorised sales mandate. 25 REAL ESTATE S.r.l. processes your personal data in accordance with this privacy policy.

For information on the processing of your personal data by the Real Estate Brokerage Agencies, you may contact directly the Agency of your interest that has received a duly authorised mandate from 25 REAL ESTATE S.r.l. We recommend you request and review the privacy policy of the relevant Real Estate Brokerage Agency before sharing any personal data.

Each Real Estate Brokerage Agency that has received a duly authorised sales mandate may decide to appoint additional data processors. For information on all data processors, you may contact directly the Real Estate Brokerage Agency of your interest.

1.2 Controller of Data Collected via Forms on the Site

For the purposes of this Policy, the data processor for personal data collected via the forms on the Site is the Real Estate Brokerage Agency that has received a duly authorised sales mandate and is duly published on the Site, while the data controller is 25 REAL ESTATE S.r.l.

For information on the processing of your personal data by the Real Estate Brokerage Agency that has received a duly authorised sales mandate and is duly published on the Site, you may contact the Agency directly. We recommend you request and review the Agency’s privacy policy before sharing any personal data.

25 REAL ESTATE S.r.l. processes client data on the basis of and in accordance with the specific mandate received. This means that 25 REAL ESTATE S.r.l. collects and manages data only on the instructions of the Real Estate Brokerage Agency that has received a duly authorised sales mandate.

2 – Data Collected

25 REAL ESTATE S.r.l. collects personal data through the Site when users register for the reserved area, submit requests via forms on the Site, or send communications by e-mail. “Personal data” means any information that can be used to directly or indirectly identify a data subject.

We may also automatically collect certain personal data when you access, use or interact with us through the Site.

Data you provide through the Site

We collect data that each user voluntarily provides, for example by communicating with us, registering in the reserved area on the Site, sending requests or communications by e-mail, or by completing the online forms on the Site to request information. The personal data that each user may provide in this way includes first and last name, e-mail address, phone number, and any other personal data they wish to share.

Data we may collect automatically

We use cookies and similar technological tools (collectively, Cookies) on the Site to collect and store data related to the use of, access to, or interaction with the Site. We may, for example, collect data regarding the type of device used to access the Site, the operating system, your IP address, your approximate geographic location as indicated by your IP address, the type of browser used, the content you view and access through the Site, the way you interact with content available on the Site, and the keywords entered for searches on the Site.

3 – Purposes and Legal Basis for Processing

3.1 Purposes and Legal Basis for Processing

The purposes for which your personal data will be processed by the Real Estate Brokerage Agency that has received a duly authorised sales mandate and is duly published on the Site, acting as data processor on behalf of 25 REAL ESTATE S.r.l., are as follows:

1. to respond to your requests for information, including those sent by e-mail to the contact details indicated on the Site, as well as through the “Services” section;
2. to carry out the mandate conferred and fulfil the related legal obligations;
3. to send you, by post, telephone, SMS, e-mail or instant messaging including via social networks, communications of a commercial, promotional and advertising nature relating to the services and products provided;
4. to send you, by post, telephone, SMS, e-mail or instant messaging including via social networks, communications of a commercial, promotional and advertising nature relating to services and products offered by companies operating in the sectors of real estate brokerage, condominium management, credit mediation, insurance and insurance brokers, auctions, enforcement proceedings and insolvency procedures, property management and maintenance, energy, furnishings, education and training, lettings, IT, marketing and communications;
5. to share data with parent companies, subsidiaries, companies subject to common control, affiliated companies, and companies in which 25 REAL ESTATE S.r.l. holds a stake, and/or third-party companies operating in the sectors of real estate brokerage, condominium management, credit mediation, insurance and insurance brokers, auctions, enforcement proceedings and insolvency procedures, property management and maintenance, energy, furnishings, education and training, lettings, IT, marketing and communications, for the purpose of sending commercial, promotional and advertising communications relating to the services and products they provide, by post, telephone, SMS, e-mail or instant messaging including via social networks.

25 REAL ESTATE S.r.l. processes your data to carry out the activities referred to in point a) of this paragraph 3.1, i.e. to respond to your express requests. The legal basis is therefore the legitimate interest of the Controller in responding to the requests of data subjects. This interest has been balanced against the interests of the data subjects and is compatible with their reasonable expectations, as it is reasonable to assume that they wish to receive a response to their requests.

The Real Estate Brokerage Agency that has received a duly authorised sales mandate and is duly published on the Site processes your data to carry out the activities referred to in point b) of this paragraph 3.1, i.e. to perform the activities related to the mandate conferred by the data subject. The legal basis is therefore the performance of contractual measures.

Processing of your data for the purposes referred to in points a) and b) of this paragraph 3.1 is necessary: without it, it will not be possible to fulfil your requests.

25 REAL ESTATE S.r.l. and the Real Estate Brokerage Agency that has received a duly authorised sales mandate and is duly published on the Site process your data for the activities referred to in points c), d) and e) of this paragraph 3.1 only with your express consent. The legal basis is therefore your consent.

Consent may be given and withdrawn at any time with reference to each of the purposes indicated above.

Consent already given may be withdrawn at any time in a manner similar to that provided for its granting, by contacting us at the details indicated at the end of this Policy, without prejudice to the lawfulness of the processing carried out on the basis of consent prior to its withdrawal.

4 – Disclosure of Collected Personal Data

Data will be processed by each Controller and by the parties appointed by them, and may be disclosed to third parties only where necessary for the performance of the activities referred to in Article 3 above.

Third-party recipients of the Data may process it, as the case may be, as independent data controllers or as duly appointed data processors.

The complete list of data processors is kept at the registered office of each Controller and is available upon request to be sent to the contact details indicated in Article 8 below.

5 – Methods of Processing

Your personal data will be processed by employees and/or collaborators of each Controller under this Policy, specifically designated as persons authorised to process data (including, for example, those responsible for human resources, legal, administrative and IT functions) and by external processors, whose respective names are available upon request from each Controller under this Policy.

Each Controller and the third parties they engage process your personal data using electronic or automated tools, according to logic strictly related to the purposes themselves, storing data on servers and/or archives located within the European Union, and in any case in a manner that ensures the security and confidentiality of the personal data.

6 – Dissemination of Personal Data

Your personal data will not be disseminated.

7 – Personal Data Retention Period

7.1 Personal Data under Controller’s Ownership

25 REAL ESTATE S.r.l. and the Real Estate Brokerage Agency that has received a duly authorised sales mandate and is duly published on the Site will retain your personal data in a form that allows your identification for no longer than necessary to achieve the purposes of the processing and, in particular, for the period necessary to fulfil operational requirements. Specifically:

• for the purposes referred to in point a) of paragraph 3.1: personal data will be retained for a maximum period of 12 months from collection;
• for the purposes referred to in point b): for the entire duration of the mandate, where conferred, and the relevant limitation period, and until the account remains active on the Site;
• for the purposes referred to in points c), d) and e): for a maximum period of 24 months from collection.

8 – Rights of the Data Subject

Each data subject has the right at any time to:

1. obtain confirmation as to whether or not personal data concerning them exists;
2. be informed of the purposes and methods of processing, the recipients of such personal data, and the retention period;
3. obtain rectification or erasure, and where applicable, restriction of processing;
4. object to processing;
5. where applicable, receive the personal data concerning them provided to the Controller in a structured, commonly used and machine-readable format, and transmit such data to another controller without hindrance from the Controller;
6. lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali);
7. select the methods by which they wish to be contacted for the purposes referred to in points c) and d) of paragraph 3 above, and in particular indicate whether they wish to be contacted via so-called traditional means (postal mail, telephone with operator), via so-called automated means (e-mail, SMS, telephone without operator, etc.) or both.

The above rights may be exercised at any time by submitting a simple request to 25 REAL ESTATE S.r.l. by writing to Via E. Estrafallaces, 26 – 73100 Lecce (LE) – Italy, or by e-mail to info@25re.it.