Privacy policy
Valid from 15 August 2022.
Responsibility and rights of the data subject
( *Note on gender: in order to improve readability, the simultaneous use of the masculine, feminine and different (m/f/d) language forms is waived below. All the following personal designations apply equally to all genders. )
1. Responsible
The entity responsible for the data processing regulated in this privacy policy is the company Dritte Real Estate s.r.l. Our contact details
Dritte Real Estate s.r.l.
Via Teramo 13, 95127 Catania
dritte@pec.it
Engel & Völkers Italy Licence Partner
2. Rights of the person concerned
The data subject has the right to obtain information on the processing of his or her personal data (e.g. the origin of such data, the purpose of the processing, the manner in which the data is processed). Furthermore, under certain conditions, he or she has the right to object to the processing of data in the future, to restrict it or to request its deletion. Finally, you can stop the sending of advertising material or the carrying out of market research or commercial communications at any time.
To summarise, the data subject is entitled
to information,
to rectification,
deletion (right to be forgotten),
limitation of processing,
to data portability,
to object to the processing of their personal data,
to lodge complaints with the supervisory authorities.
Furthermore, the data subject has the right to object to the processing of his or her personal data for direct marketing purposes at any time. If the data subject objects to processing for direct marketing purposes, we will no longer process his or her personal data for such purposes.
Pursuant to Article 7 III of the General Data Protection Regulation of the European Union (hereinafter "GDPR"), the data subject may revoke the consent he or she has given us at any time. This has the consequence that we will no longer be able to continue data processing on the basis of this consent for the future.
Please note that the right to erasure is subject to restrictions. For example, we do not or cannot delete data that we still need to retain due to statutory retention periods. Data that we need in order to assert, exercise or defend legal claims are also excluded from the right of deletion.
In the event of a complaint about the way in which we process your data, you have the option of lodging a complaint with a supervisory authority, in particular in the Member State in which you reside, work or in which the alleged breach occurred.
We reserve the right, in the event of a legal obligation, to disclose information about the data subject and if we are requested to do so by the competent authorities or law enforcement agencies. Legal basis: Art. 6 I sentence 1 lit. c GDPR (legal obligation).
___________________________________________________________________________________________
Overview of our data processing procedures
Our data protection information is structured as follows and provides an overview of the following data processing procedures:
-The interested party visits us on our corporate website on the Internet
-The interested party enters into a research or marketing contract with us, requests an exhibition or commissions us for a property valuation
-Looking for a property together with another Engel & Völkers licensee partner (referral)
-The person concerned applies on his or her own initiative or in response to a job advertisement
-Memorization and deletion of one's own data
Collection and processing of personal data when the data subject visits our company's website on the Internet
In principle, we only process personal data if it is submitted to us via the contact forms on our corporate website. We only process personal data if the person concerned has given their consent to do so or if processing is permitted by law. For certain services we offer on our corporate website, we require a minimum amount of data. We have marked this mandatory data with an "asterisk". Without the mandatory data, we cannot provide our services marked in this way.
What data of the data subject ('the data subject') we process
As part of the use of our corporate site, we process personal data, in particular:
E-mail address, first name, last name, title, address, telephone number, subject data - in the context of this privacy policy referred to as "data" or "personal data") provided by the data subject in the case of services offered on our company website (e.g. in the context of contact requests and the sending of newsletters, as well as the determination of the market price ("valuation") of properties).
__________________________________________________________________________________________
Please refer to the description of the handling of usage data in connection with the use of cookies and other tracking technologies in the 'Cookie Information' of
Engel & Völkers GmbH
Vancouverstrasse 2a
D-20457 Hamburg
Germany
E-mail: info@engelvoelkers.com
Information on cookies can be found at the bottom of our company page on the Internet.
__________________________________________________________________________________________
Purpose of processing and legal basis
We process the data of the person concerned for the following purposes:
Fulfilment of contact requests (the legal basis is the fulfilment of the contract and, in the case of the transfer of the data of the data subject to other license partners of the Engel & Völkers Group (for definition, see section 3 below), the consent of the data subject);
If applicable, the fulfilment of the request for the valuation of the property described by the data subject on the basis of the market price, as well as the interest in the sale thus conveyed (the legal basis is the fulfilment of the contract as well as - in the case of the entry of contact data by the data subject and its forwarding to a licensing partner of the Engel & Völkers Group responsible for the subject or geography (for definition, please see Section 3 below) - the consent of the data subject as well as - in the case of the company technically performing the valuation - the consent of the data subject). Völkers Group responsible for the subject matter or geography (for definition, please see section 3 below) or to the company technically carrying out the evaluation - the consent of the data subject as well as - in the case of the use of contact data for direct marketing - the justified interest in marketing our services or his or her consent);
Telephone contact by us (the legal basis is the fulfilment of the contract or, in the case of using the telephone number for advertising purposes, the consent of the person concerned);
Sending an e-mail newsletter about our own and third parties' offers and advertising, to the extent permitted by law or on the basis of the data subject's consent (the legal basis is the data subject's consent or our legitimate interest in direct marketing, provided that the marketing is carried out in compliance with data protection requirements and competition law);
Summary:
The legal basis for the processing of personal data is Art. 6 I sentence 1 lit. a GDPR, if the processing is based on consent, Art. 6 I sentence 1 lit. b GDPR, if the basis of processing is a contractual relationship (possibly pre-contractual) and Art. 6 I sentence 1 lit. f GDPR, if the basis is our legitimate interest. Insofar as the processing of personal data is necessary for the fulfilment of a legal obligation to which we are subject, Art. 6 I sentence 1 lit. c GDPR as the legal basis.
If the legal basis is the data subject's consent, the data subject shall have the right to withdraw his or her consent at any time without prejudice to the lawfulness of the processing of his or her personal data carried out on the basis of the consent until the revocation. If the legal basis is legitimate interest, the data subject also has the right to object at any time to the processing of personal data concerning him or her on grounds arising from his or her particular situation. Article 21 GDPR applies in this regard.
Transmission of the data subject's personal data
We will only pass on the data subject's personal data to third parties if this is necessary for the fulfilment of the contract, if we or the third party have a legitimate interest in passing on the data, if there is a legal obligation to do so, or if the data subject has given his or her consent. If data is transferred to third parties on the basis of a legitimate interest, this will be explained in these data protection provisions.
If the contact request of the data subject concerns offers from other companies of the Engel & Völkers Group, we will transfer the personal data entered by the data subject to the respective company of the Engel & Völkers Group subject to the consent of the data subject or - if legally permissible - on the basis of a so-called legitimate interest. Apart from this, we will not transfer your personal data for other purposes.
When we refer to the 'Engel & Völkers Group' in this Privacy Policy, we mean the companies belonging to the Engel & Völkers Group within the meaning of Sections 15 et seq. of the AktG (German Stock Corporation Act) and the licence partners (masters) who are directly or indirectly contractually affiliated with this group of companies, of which we are also a member. For an up-to-date overview of these licence partners, please see the following link: https://www.engelvoelkers.com/de/unternehmen/standorte/).
Transmission of data to countries outside the EEA
In addition to the preceding paragraph 'Disclosure of Personal Data', the following applies:
Recipients of personal data may be located outside the EEA/UK. In the event that personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that data protection rights are adequately protected, either because the European Commission has decided that the country to which personal data is transferred provides an adequate level of protection (art. 45 GDPR), and also because the transfer is subject to adequate safeguards (e.g. EU standard contractual clauses) agreed with the recipient (Art. 46 GDPR), unless the GDPR provides for an exception (Art. 49 GDPR). Furthermore, where necessary, we intend to agree with recipients on additional measures to ensure an adequate level of data protection. You may request copies of the appropriate safeguards (where we rely on them) and a list of recipients outside the EEA/UK. Note: these copies may be reduced to the extent necessary to protect trade secrets or other confidential information.
The interested party enters into a research or marketing contract with us, requests an exhibition or commissions us to evaluate a property
The data of the data subject processed by us
When searching for, selling or renting a property, requesting an exhibition or evaluating a property, we routinely process the following personal data of the data subject:
Name, surname, title, address, telephone number, information on the desired property (in case of property search) or (in case of property marketing or valuation) information on the property;
E-mail address, if the data subject has agreed to receive promotional information, in particular the offer or valuation of real estate, or wishes to receive communications by e-mail;
as well as (in the case of buying or selling real estate) bank details, identity data, copy of identity document (in the case of buying or selling real estate) as well as land registry, electricity, gas and/or oil bills, general utility bills, division declarations, WEG minutes (resolutions), purchase contract (in the case of selling real estate) or (in the case of renting real estate) bank details, identity data, possibly CV, proof of salary, proof of solvency, landlord confirmation, rental contract.
Purpose of processing and legal basis
We process this personal data for the following purposes:
Fulfilment of a contractual or pre-contractual legal relationship - also by independent real estate advisors working with us - including billing and credit assessment (the legal basis is Art. 6 I lit b. GDPR and Art. 6 I lit. f GDPR; our legitimate interest in connection with the disclosure of data to independent real estate consultants stems from the freedom of choice to also fulfil contractual relationships with independent brokers or sub-brokers. The legitimate interest in carrying out credit checks derives from the legitimate interest in protection against bad debts);
Fulfilment of a legal obligation, in particular in connection with the Money Laundering Act; (the legal basis is Art. 6 I lit. c GDPR);
Promotional information on properties marketed by us or other authorised partners of the Engel & Völkers Group (the legal basis is Art. 6 I lit. f GDPR; the processing of personal data for the purpose of direct advertising is in our legitimate interest. The legal basis is also the user's consent pursuant to Art. 6 I a. GDPR, if promotional information is sent to the data subject by e-mail, fax or telephone).
If the legal basis is the data subject's consent, the data subject has the right to withdraw his or her consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent until the revocation. If the legal basis is legitimate interest, the data subject also has the right to object at any time to the processing of personal data concerning him or her on grounds arising from his or her particular situation. Article 21 GDPR applies in this regard.
Data transmission
If the data subject's request (e.g. in connection with an evaluation request) concerns offers from other partners of the Engel & Völkers Group, Engel & Völkers will pass on the personal data entered by the data subject to the respective company of the Engel & Völkers Group, subject to the consent of the data subject.
In this context, please also refer to our information on addition in Section III.
In addition, we pass on personal data to contractual partners (landlords, tenants, research clients) and support service providers such as notaries, lawyers, property managers, real estate developers within the scope of processing a contractual relationship, as well as within the scope of solvency information or to supervisory authorities (e.g. for money laundering documentation). We may also transfer the data subject's data to third parties to the extent permitted by law. Third parties to whom we may disclose the data subject's personal data, regardless of our performance, include external advisors (e.g. lawyers and auditors), public authorities within their jurisdiction to comply with legal obligations and/or to protect our rights (e.g. tax authorities, police, prosecutors, courts), potential purchasers or acquirers of all or part of our assets and/or business, and other third parties to whom the data subject has instructed us to disclose the data or has given their consent.
In addition, we will only share the data subject's personal data with employees (permanent staff such as employees and freelance property consultants) and with third-party companies (e.g. IT service providers, hosting, etc.) to which we have outsourced services involving processing operations under a contractual processing agreement.
Transmission of data to countries outside the EEA
In addition to the preceding paragraph on 'Sharing of Personal Data', the following applies:
Recipients of personal data may be located outside the EEA/UK. In the event that personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that data protection rights are adequately protected, either because the European Commission has decided that the country to which personal data is transferred provides an adequate level of protection (art. 45 GDPR), and also because the transfer is subject to adequate safeguards (e.g. EU standard contractual clauses) agreed with the recipient (Art. 46 GDPR), unless the GDPR provides for an exception (Art. 49 GDPR). Furthermore, where necessary, we intend to agree with recipients on additional measures to ensure an adequate level of data protection. You may request copies of the appropriate safeguards (where we rely on them) and a list of recipients outside the EEA/UK. Note: these copies may be reduced to the extent necessary to protect trade secrets or other confidential information.
If the data subject's request concerns licensing partners of the Engel & Völkers Group outside the European Union, we will transfer the data subject's data to the locally/currently competent licensing partner after obtaining the data subject's consent.
We are looking for a property for the interested party together with another Engel & Völkers licensee partner ('referral').
If we search for a property for the data subject together with another licensing partner, the data subject's data will only be passed on on the basis of the data subject's prior consent. Note: Both we, as the first contact, and the licensing partner of the Engel & Völkers Group to whom you provide your data, process the personal data of the data subject. Both of us - we and this licensing partner - are independently responsible for the respective data processing. We and this other licence partner do not have access to each other's data and do not process the data of the data subject jointly. If the data subject wishes to assert his or her rights, please check in advance whether he or she wishes to assert them against us or against the other Engel & Völkers Group partner processing the data subject's data.
Please refer to the above information on how we process the data of the data subject in connection with the marketing of the data subject's property, what rights the data subject has in this context, and who to contact if the data subject wishes to assert his or her rights.
The person concerned applies on his/her own initiative or in response to a job advertisement
The data of the data subject processed by us
If the person concerned applies via our website or a job advertisement, we process the name and address of the person concerned as well as telecommunication and application data. The provision of the address and telecommunication data, which are advertised as mandatory data, is necessary in order to contact the person concerned about his/her application and to be able to assign the application.
Purpose of processing and legal basis
We process the personal data of the person concerned for the following purposes:
● Examination of the application for an employment relationship within our company (the legal basis is Art. 6 I lit. b GDPR, if applicable in combination with. Art. 26 of the BDSG (German Federal Data Protection Act) (for the scope of application of the Federal Republic of Germany).
● Defence against any legal claims made against us as a result of the application process, to the extent necessary (the legal basis is our legitimate interest in fulfilling our obligation to provide evidence in proceedings under the General Equal Treatment Act (AGG); Art. 6 I lit. f GDPR).
● In addition, we process the data subject's personal data on the basis of previously given consent, in order to inform him/her about interesting job offers (the legal basis is Art. 6 I lit. a GDPR).
If the legal basis is the data subject's consent, the data subject has the right to withdraw his or her consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent until the revocation. If the legal basis is legitimate interest, the data subject also has the right to object at any time to the processing of personal data concerning him or her on grounds arising from his or her particular situation. Article 21 GDPR applies in this regard.
We need the personal data of the data subject in order to fulfil the processing purposes listed above. The data subject is free not to provide us with any personal data. In this case, we will not be able to allow the person concerned to participate in the application process for vacancies.
Data transmission
We will only pass on the data subject's personal data to third parties if this is necessary for the fulfilment of the contract, if we or the third party have a legitimate interest in passing on the data, if there is a legal obligation to do so, or if the data subject has given his or her consent. If data is transferred to third parties on the basis of a legitimate interest, this will be explained in these data protection provisions.
If the data subject applied via the global online job portal of Engel & Völkers Holding GmbH, the data subject's application documents were transmitted to us by Engel & Völkers Holding GmbH. The data subject learned about how Engel & Völkers Holding GmbH processes personal data during the application process and can view this data at any time via the global online job portal on the relevant website of Engel & Völkers Holding GmbH.
Transmission of data to countries outside the EEA
In addition to the preceding paragraph on 'Sharing of Personal Data', the following applies:
Recipients of personal data may be located outside the EEA/UK. In the event that personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that data protection rights are adequately protected, either because the European Commission has decided that the country to which personal data is transferred provides an adequate level of protection (art. 45 GDPR), and also because the transfer is subject to adequate safeguards (e.g. EU standard contractual clauses) agreed with the recipient (Art. 46 GDPR), unless the GDPR provides for an exception (Art. 49 GDPR). Furthermore, where necessary, we intend to agree with recipients on additional measures to ensure an adequate level of data protection. You may request copies of the appropriate safeguards (where we rely on them) and a list of recipients outside the EEA/UK. Note: these copies may be reduced to the extent necessary to protect trade secrets or other confidential information.
Storing and deleting your data
We retain the data subject's personal data for as long as is necessary to fulfil the purposes for which the data were collected and subsequently processed, including any retention period required by applicable law (e.g. retention of accounting records).
In the context of application procedures that end without recruitment, the data subject's data will be routinely stored for a further six months for documentation purposes and then deleted or destroyed, together with the documents sent to us. With the data subject's consent to the processing of data for future application procedures, we will also retain them for a proportionately longer period.