Complying with the right to personal data protection, as well as with the right to private life is one of the fundamental missions of Hercesa Imobiliara SRL (Hercesa Romania)
Thus, we take all the necessary steps to process personal data in compliance with the principles established by the legislation regarding data protection applicable in Romania, including the (EU) Regulation 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”).
Personal data means any information relating to 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 specific elements, specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity.
The processing of personal data is done by: Hercesa Imobiliara SRL with its registered office in Str. Baia de Arama nr.1, Parter, Camera 3, Sector 2, Bucharest, registered under No. J40/11273/2004 with the Trade Register, having TIN RO16596300.
The company Hercesa Imobiliara SRL is a personal data operator in the sense provided by GDPR, respectively establishes the means and purposes of processing personal data.
Click on one of the links below to go to a specific section:
WHAT KIND OF PERSONAL DATA DO WE PROCESS?
If you are a customer or potential customer of Hercesa Imobiliara
We collect personal data as a result of most interactions with you, as well as in other aspects of our business. The categories of data we process are the following:
Surveillance cameras and other security measures on our properties may also capture or record images of tenants and visitors in public places (such as headquarters entrances or lobbies), as well as your location data (through the images captured by the surveillance cameras).
You can always choose what personal data you want to provide us. However, if you choose not to provide certain personal data, if the basis of our request is compliance with a legal obligation, contractual obligation or obligations necessary to conclude a contract, we will be unable to provide you with certain services, for example: ( i) if you do not wish to give us your name, surname, e-mail address or telephone number in case you request an offer, we will not be able to make and send the requested offer, or (ii) considering the legal obligations in force, to the extent that you do not wish to give the notary public your PIN to fill-in and authenticate the sales-purchase contract, it will not be able to conclude the contract with you.
If you are a potential employee
We collect the information from the CV sent by you, as well as any other information sent together with the CV and/or within the interviews you attended.
For more information regarding the processing of your personal data in the context of the recruitment process, we invite you to consult the Information Note on the processing of personal data in the context of recruitment.
If you are a visitor to our locations
Surveillance cameras can capture or record images of visitors in public places (such as entrances to our locations).
If you are a user of our website www.hercesa.ro
It is not necessary to provide personal data to read the existing information on the site.
However, for the purpose of technical operation of the portal we may collect data such as the time and date of access to the website and the IP address from which our website was accessed. For more details on the use of cookies on our website, we invite you to consult Our Cookies Policy.
Certain personal data are required to use certain services (e.g. contact form).
For details, please see the section corresponding to the operation used on the website.
If you are a representative or a contact person of our suppliers or business partners
We collect the surname, given name, position, contact data as well as any other data provided by you or by the company you represent.
If you are an employee
Please read the employee privacy policy, made known at the time of employment and available any time at the headquarters.
PERSONAL DATA OF MINORS
We protect the confidentiality of the data obtained from children under the age of 16. If you are under the age of 16 and we process your personal data based on your freely expressed consent, we are also obliged to request the consent of your parents/legal guardian.
SPECIAL CATEGORIES OF PERSONAL DATA
The phrase “special categories of personal data” refers to data relating to racial or ethnic origin, political opinions, religious denominations or philosophical beliefs or trade union membership and the processing of genetic data, biometric data, health data or data on sexual life or sexual orientation.
Generally, we do not collect such information unless you wish to provide it to us.
FOR WHAT PURPOSES AND ON WHAT GROUNDS DO WE PROCESS YOUR PERSONAL DATA?
If you are a customer or potential customer of Hercesa
Request for a quotation
Purpose: we process your personal data in response to the requests of offers from you.
Grounds: conclusion of a contract
The contact with you
Purpose: we process your personal data in order to keep in touch with you for the purpose of transmitting the necessary information and those of interest to you. We may also contact you to determine together the various possible configurations of your apartment as well as to provide you with various services and optional products regarding your apartment.
Grounds: conclusion and performance of a contract; also, we can transmit information regarding the location you have rented or purchased based on our legitimate interest
In the case of communications with you on the basis of our legitimate interest, you have the right to object to such data processing. In this regard, please refer to the “Right to object” in the “Your Rights” Section below.
Conclusion of the contract with you
Purpose: we process your personal data for the valid conclusion of the contract requested by you.
Grounds: conclusion and performance of a contract and fulfilment legal obligations
Feedback:
Purpose: we process your personal data to ensure that you have had a pleasant experience in the context of using the services offered by our company.
Grounds: our legitimate interest in constantly improving the services we offer and in providing services that are as appropriate and in line with our customers’ standards as possible.
Marketing:
Purpose: we process your personal data for marketing purposes, such as business newsletters and marketing communications about new products, services, events we host, or other offerings that we believe may be of interest to you.
Grounds: we rely on the legitimate interest in promoting our services by submitting offers that we consider to be of interest to your company (see “Right to object” in the “Your Rights” Section)
If necessary, in accordance with the applicable law, we will obtain your consent before processing your personal data for direct marketing purposes. In this case, we inform you that you will be able to withdraw your consent for the processing for marketing purposes, in which case you will not receive any marketing communication from us.
We will include an unsubscribe link, which you can use if you do not want us to send you messages anymore.
Also, on the occasion of the participation within certain events (e.g. real estate fairs), it is possible to take a few photos, and some of them might be distributed online as well, in order to show others how those events took place. In any case, because we take into account your right to privacy, we will do our best to inform you that photos will be taken (for objections to our photos, see “Right to object” in the “Your Rights” Section)
Other communications: by e-mail, telephone or text message
Purpose: these communications will be made for a specific reason such as: (i) to respond to your requests, (ii) if you have not completed a request for quotation or payment, we may send you an email to remind you to complete (iii) to inform you of the manner in which complaints and/or incidents arising from our cooperation have been resolved
Legal grounds: our legitimate interest in providing services to the desired standards by resolving any requests/complaints and in ensuring our full availability; if we respond to a request in the course of the contract concluded with you, the grounds on which the processing is based is the performance of a contract
Other communications: from the financing partner bank
Purpose: your data may be processed by the banking financial institution financing the real estate project in order to fulfil certain formalities and legal obligations
Grounds: performance of the contract concluded between us and you.
Analysis, improvement and research:
Purpose: In order to constantly ensure the qualitative evolution of our services, we take care to analyse every complaint / suggestion from you, so that we prepare statistical reports to identify the problems and find the best solutions to remedy them.
Grounds: we rely on our legitimate interest in providing services that meet your standards and Hercesa’s standards.
If you are a visitor to our location
Purpose: we process your personal data to ensure the protection of property and people within the location.
Grounds: our legitimate interest in ensuring both the protection of customers’/staff’s goods, and the protection of persons within our location.
If you are a user of our website www.hercesa.ro
Purpose: traffic monitoring in order to identify errors and/or any other site malfunction.
Grounds: we base this data processing activity on our legitimate interest, namely to provide you with a fully functional site by repairing any errors, as well as by continuously improving it.
If you are a representative or contact person of our suppliers or business partners
Purpose: developing contractual relationships with our suppliers or business partners.
Grounds: performance of a contract.
If you are a potential employee
Purpose: assessing your employment application.
Grounds: performance of a contract.
For more information on the processing of your personal data in the context of the recruitment process, we invite you to consult the Information Note regarding the processing of personal data in the context of recruitment.
If you are an employee
Please see the employee privacy policy, notified at the time of employment and available any time at the office.
For all categories of people above, we may also process your data in the context of the following activities:
Restructuring, internal reorganization or sale of assets or social parts/shares:
Purpose: we process your data to perform the operations mentioned above.
Grounds: the legitimate interest in carrying out the operations, especially in the event that they would be impossible to achieve without processing your data.
However, we assure you that this possible processing will be carried out in accordance with this policy and by implementing a measure to ensure the confidentiality of your data.
Security:
Purpose: we process personal data for the security of goods and the physical integrity of persons.
Grounds: we rely on our legitimate interest to ensure the protection of your goods and those of Hercesa Imobiliara SRL, as well as the protection of persons being within the perimeter of our location.
Legal reasons:
Purpose: in certain cases, we must process the information provided, which may include personal data, to resolve legal disputes or complaints, to investigate and comply with applicable legal regulations, to implement an agreement or to comply with requests from public bodies to the extent these requests meet the obligations imposed by the law.
Grounds: the reasons for processing may be the legal obligation (if we have a legal obligation to disclose certain personal data to public authorities) or our legitimate interest in resolving any disputes and/or complaints.
TO WHOM DO WE TRANSMIT YOUR PERSONAL DATA?
In order to offer you the expected level of professionalism and to provide you with high quality services, your data can be transmitted to the headquarters of the company and the members of the brand portfolio of which Hercesa Imobiliara SRL is part. We also provide your data to our service providers and other third parties, as detailed below:
The confidentiality of your data is important to us, which is why, where possible, the transmission of personal data in accordance with the above is done only on the basis of a confidentiality commitment from the recipients, which guarantees that this data is kept and that the provision of this information is in accordance with applicable law and applicable policies. In any case, each time we will send to the recipients only the information strictly necessary to achieve that goal.
DO WE COLLECT PERSONAL DATA FROM THIRD PARTIES?
In order to provide you with the expected level of hospitality and the best services level, it is possible to collect information about you from our business partners and other third parties, as presented in detail below:
In any case, we assure you that your data collected from third parties will be processed under the same conditions as if it were collected directly from you. We will also collect only what is necessary to fulfill our purposes. (see Section “FOR WHAT PURPOSE AND FOR WHAT GROUNDS IS YOUR PERSONAL DATA PROCESSED?”).
In addition, when we contact you for the first time, we will inform you, first of all, of the source from which we obtained your personal data.
DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EU/EEA?
We may transfer your data to some providers based in countries other than your own and in some cases to countries outside the EU/EEA.
Although the data protection laws in these countries may be different from those in your country, we will take the necessary steps to ensure that your personal data is processed in accordance with this policy and in accordance with the applicable law.
YOUR PROVISION OF PERSONAL DATA OF OTHER NATURAL PERSONS
If you provide us with the personal data of other natural persons (e.g. your spouse.), please communicate this to them before this disclosure and the modality in which they are to be processed, as described in this privacy policy.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
Your personal data is kept throughout the period of achieving the purposes detailed in this policy, if a longer retention period is not required or allowed by the applicable law.
We constantly review the need to retain your personal data, and to the extent that processing is no longer necessary and there is no legal obligation to retain your personal data, we will erase/destroy your personal information as soon as possible and in such a way that they can no longer be recovered or reconstituted (for example, we will erase/destroy all the data of the persons who were not hired after the interviews, if there is no serious prospect of employment in the future).
If personal information is printed on paper, it will be destroyed in a way that ensures its complete elimination, and if it is saved on electronic media, it will be erased by technical means to ensure that the information can no longer be recovered or reconstituted later.
WHAT ARE YOUR RIGHTS?
As a data subject, you have the following rights under the GDPR:
If we use your personal data based on your consent, you have the right to withdraw this consent.
If we use your personal data on the basis of your consent, you have the right to withdraw this consent at any time. In this situation, your data will no longer be processed by us, unless a legal provision obliges us to keep and archive them. In any case, we will inform you if there is such a legal provision and we will expressly indicate it.
ARE YOUR DATA SAFE?
We treat your personal security seriously, therefore, we take important security measures, necessary to protect against unauthorized access to data or modification, disclosure or destruction of unauthorized data. This involves internal reviews of data collection, storage and processing practices and security measures, as well as physical security measures to protect against unauthorized access to the systems where we store personal data.
We also ask our service providers as well as business partners to take all necessary measures to protect against unauthorised access to data or unauthorised modification, disclosure or destruction of data.
LINKS TO OTHER WEBSITES
Our site contains links to third party websites. Please note that we do not assume any responsibility for the collection, use, storage, sharing or disclosure of data or information by such third parties. If you use or provide information on third party websites, the terms and privacy policy of those websites apply. We advise you to read the privacy policy of the websites you visit before submitting personal data.
QUESTIONS OR COMPLAINTS
If you have any questions or concerns regarding the processing of your personal data or if you wish to exercise any of the rights mentioned above, you are welcome to contact us by sending an e-mail to the following address: dataprotection_buc@hercesa.com and we will reply within maximum 30 days from the receipt of your request.
To the extent that you do not have electronic means or do not want to use them, you can make a written request that you submit to the registered office in Str. Baia de Arama nr.1, Parter, Camera 3, Sector 2, Bucharest.
To the extent that you are not satisfied with the way in which your request has been resolved, you can file a complaint with the
National Supervisory Authority for Personal Data Processing.
POLICY MODIFICATIONS
This privacy policy may change in accordance with changes in data policy legislation or changes to our services or the way we organize from time to time. If we make material changes to this, we will post a link to the revised policy on the home page of our site. If we make significant changes that will affect your rights and freedoms (for example, when we begin processing your personal data for purposes other than those specified above), we will contact you before we begin such processing.
To help you keep track of the most important changes, we will include a modification history below to acknowledge changes to this policy.
Last update: 16 September 2020
