1. Introduction
In accordance with the provisions of Articles 13 and 14 of Regulation (EU) 2016/679 on the Protection of Personal Data (hereinafter also referred to as GDPR), the text below indicates how we respect the privacy of visitors to this Website, and describes how we collect, use and protect personal information, according to the principles of fairness, legality and transparency; in addition it describes how we grant rights to visitors and how they can interact with us.
2. Data Controller
Personal Data provided by site users will be processed by Real Asset Network s.r.l. registered in Via Nazario Sauro n°6 – 20025, Legnano (MI), Italy (the “Data Controller”), with VAT Number 12587290961 and registered as real estate broker at Milan’s Chamber of Commerce with REA Number 2671107.
The Data Controller is a licensed brokerage firm that helps buyers and sellers transact real estate properties. As part of its role as a real estate agent, the Data Controller has to match the search requests received by property investors with the assets sold by property owners. The trading opportunities are filtered using a high amount of data that Real Asset Network collects from public and private sources and analyses with various digital programs.
Pursuing the Article 24 of the GDPR, the Data Controller will determine the purposes of Personal Data processing.
3. Purposes of data processing
Through this website we collect personal information, which users are free to provide by filling in the dedicated forms, for the following purposes:
- Respond to a specific request submitted by users through the contact us form;
- Send newsletters and carrying out market researches or commercial communications (including the organization of events for network members), through automated or traditional means.
4. Categories of Personal Data collected
The personal data collected through the website concern personal and contact data.
The Data Controller does not deliberately collect any special category of personal data through this website.
In addition to the data provided directly and intentionally by the user, the computer systems and software procedures used to operate this website acquire, during their normal operation, some navigation data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with data subjects, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct functioning. They could be used to ascertain responsibility in case of crimes. For further information on this subject, please refer to our Cookie Policy.
5. Legal basis
The processing of personal data referred to the above purposes is based on the principles expressed in the GDPR, according to which the processing is lawful when necessary for the execution of a contractual obligation or for the execution of pre-contractual measures taken at the request of the user (the “data subject”). The provision of data, for these purposes, is necessary to meet the user’s request, or to improve the relationship between the parties.
The provision of data for these purposes is optional, the refusal of the user does not imply any consequence, except for the impossibility to carry out the above listed activities.
6. Processing Methods
The processing of personal data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction.
As far as security is concerned, we inform you that the database is accessible only by personnel authorised to do so by the Data Controller, as well as the related operations described above, and that your data will be processed using methods and instruments suitable to guarantee its confidentiality and may be carried out by electronic or automated and non-automated means (paper files), both of which are provided with adequate security measures, as provided for by the GDPR, in order to prevent the loss of data, unlawful or incorrect use and unauthorised access.
7. Communication to Third Parties
Without prejudice to any communications to comply with legal obligations, the Data Controller will communicate the personal data provided by users only for the support of the service requested, or for the performance of the purposes listed above
Finally, the data of the users may be transmitted, in compliance with the law, to the police forces and to the judicial and administrative authorities, for the detection and prosecution of crimes, the prevention and protection from threats to public security, to allow the Data Controller to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others.
8. Links to third party Websites and use of Social Media
We invite users to consider that the Website contains links to other websites and social media that are not covered by this privacy policy. Visitors to our Website may be redirected to third party Websites to obtain more information; the Data Controller does not guarantee how user data is stored or used by third party servers. The Data Controller does not make any representations or accept any responsibility for the accuracy or any other aspect of the information available on such Websites. A link to a third party’s Website cannot be understood as a validation, either by the Data Controller or such third party, of the products and services of others or such third party.
9. Data retention
We retain the data provided voluntarily by the person concerned for a period of time necessary in relation to the performance of the services requested and for a maximum of 24 months, in order to correctly manage any subsequent requests from the same User or for additional information related7 to the same or similar topics. At any time, by contacting the Data Controller, users may withdraw their consent to the processing of their data.
10. User Rights
In accordance with the GDPR, the user is entitled to: the right to ask the Data Controller for access to personal data (art. 15), rectification (art. 16), cancellation (art. 17), limitation of the processing of personal data concerning him/her (art. 18), the right to portability of data (art. 20) or to object their processing (art. 21), in addition to the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the subject or which significantly affects him/her in the same way (art. 22).
Requests may be made to the Data Controller in the following ways:
- by email to the following e-mail address: realassetnetwork@pec.it;
- by registered mail to the address: Via Nazario Sauro n°6 – 20025, Legnano (MI), Italy
11. Changes to this policy
The Data Controller reserves the right to modify this privacy policy as necessary. Visitors are encouraged to periodically check this page as well as other related sections of the Website such as the Terms & Conditions or the Cookie Policy to keep track of any changes.