Data Protection Policy

Data Protection Policy www.greenfieldresidence.ro

Our commitment regarding your personal data 

1. Impact Developer & Contractor S.A., limited liability company, established and operating in accordance with the laws of Romania, with its registered office in Bucharest, Sector 1, No. 31-41, postal code 014043, registered with the Bucharest Trade Register under number J2018007228408, Unique Registration Code 1553483, fiscal attribute „RO”, will process the personal data of the website users www.greenfieldresidence.ro in accordance with its Personal Data Protection Policy („Policy”) as well as with the General Data Protection Policy of the group to which the company belongs, namely IMPACT Developer & Contractor (“IMPACT Policy”) of which the company is a part, in accordance with current legislation. 
2. Politics is based on the provisions Regulation No. 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation”or„General Data Protection Regulation“), which shall enter into force on May 25, 2018, as well as applicable national legislation. 
3. The data processing method for personal data at IMPACT is uniform across IMPACT group companies, namely Aria Verdi Development SRL, Bergamot Developments SRL, Bergamot Developments Phase II SRL, Greenfield Copou Residence SRL, Impact Finance & Sales, and Spatzioo Management SRL, and the database is jointly managed by the IMPACT group. 
4. GDPR defines personal data as „any information relating to an identified or identifiable natural person („Data subject”; a natural person is one who can be identified, directly or indirectly, in particular by reference to an identification element, such as a name, identification number, location data, an online identifier, or to one or more specific elements, their physical, physiological, genetic, psychological, economic, cultural or social identity“. 
5. Impact Developer & Contractor S.A. is committed to implementing the highest standards of privacy and transparency regarding the personal data it processes in its current activity. Complete protection and transparency concerning the processing of your personal data within our activity are our utmost priorities. 
6. Please also refer to our Cookie Policy available at https://www.greenfieldresidence.ro/baneasa/cookie/ in which the use of cookies/other web tracking devices through our website is explained. 
7. Any information regarding the processing of your personal data can be requested at the address dpo@impactsa.ro belonging to the Data Protection Officer appointed in accordance with the provisions of the GDPR.  

 2. Agreement 

1. Your use of our services is subject to our Cookie Policy. By using our services, you agree to the terms of this Policy. The purpose of the Policy is to inform our customers about how we collect, store, and use personal data. 
2. If you do not agree with the Policy, please stop using our services. 
3. Site Usage www.greenfieldresidence.ro does not necessarily require the provision of personal data. However, should you decide to provide us with personal data, we wish to explain how we process the data you provide. 

3. Categories of personal data collected 

Personal data that we process as a result of your use of the site www.greenfieldresidence.ro pot may contain: 

• contact information, such as your first and last name, email address, phone number; 
• details about the type of housing you're looking for or other project-related information 
• Your IP address that is processed when you connect with our operator on the site;  
• details of your visits to our website (for this purpose, we recommend you read the Cookie Policy); 
• any other information you provide to us when submitting a request on the website or as a result of sending it via email or phone. 

4. Ways we collect your personal data 

 We collect your data which comes from an email or phone request 

1. We collect personal data such as name, surname, email address, and phone number in order to maintain correspondence or communication with you. Thus, if you submit a request by email or phone, we will process your data in order to resolve it.  
2. In this context, if the situation you have described requires it, we will be able to transmit your contact details to financial and governmental institutions, transport companies, or the post office. 
3. Except for the situation described above, the data you provide while browsing the site www.greenfieldresidence.ro will be used solely for your own interest and will not be transmitted to third parties unless your prior consent has been obtained. 

We collect your data as a result of a request to be contacted by a consultant. 

1. We collect personal data relating to first name, last name, email address, phone number, interest in contracting (type of housing you desire), which is obtained as a result of you requesting to be contacted by a consultant by filling out the fields on the website.  
2. In this regard, our consultants will contact you to provide you with more information and send you a personalized offer. 
3. If you have expressly consented to your personal data being processed for marketing purposes by Impact Developer & Contractor S.A., respectively for sending newsletters, information about products and services Impact Developer & Contractor S.A. our events, competitions organized by us, Impact Developer & Contractor S.A. will process your data for marketing purposes. 

5. Purposes for which we process your personal data 

We can collect and process personal data for the following purposes: 

• offering our products and services consisting of apartments or villas in residential complexes built by Impact Developer & Contractor S.A. if companies within the group;
• sending invitations for events organized by Impact Developer & Contractor S.A.if companies within the group;
• compliance with our legal obligations (such as obligations to keep accounting records and supporting documents); 
• analyzing and improving our services and communications to you; 
• protecting security and managing access to our premises, IT and communication systems, online platforms, websites, and other systems, preventing and detecting security threats, fraud, or other criminal or malicious activities; 
• for the purpose of identifying individuals authorized to transact on behalf of our clients, beneficiaries, suppliers, and/or service providers; 
• transferring them to third parties, if you have expressly consented; 
• marketing campaigns, customer surveys, market analyses, prize draws, contests, or other promotional activities or events, if you have expressly consented; 
• for any purpose related and/or ancillary to any of the above or any other purpose for which your personal data has been provided to us. 

6. Direct Marketing 

1. We promote our services to you and to others. We use customer information to send invitations and communications that promote the products and services we provide. To the extent that you have expressed your agreement to this by ticking the box within the contact form, we will be able to use your personal data provided for the purpose of sending communications regarding the products and services we provide. 
2. In all cases, you will have the option to unsubscribe from receiving marketing communications by clicking the unsubscribe link found in each such communication.  
3. Please note that in the event of an unsubscribe request, there may be a grace period of up to 48-72 hours during which you may still receive marketing information or communications, due to system processing times for these changes. Unsubscribing from marketing emails does not prevent the continued transmission of transactional emails, through which we can inform you about the status of a transaction we may complete.  

7. Sharing and Transferring Your Personal Data 

1. We can provide access to the personal data you provide us with to companies in the IMPACT group, namely Aria Verdi Development S.R.L., Bergamot Developments SRL, Bergamot Developments Phase II SRL, Greenfield Copou Residence SRL, Impact Finance & Sales, and Spatzioo Management SRL –  our authorized personnel - mainly service providers, however, we will retain control over your personal data and will use appropriate protective measures, in accordance with applicable law, to ensure the integrity and security of your personal data. Regarding access by other companies within the group, access will always be limited to the personal data they may need to provide a service concerning you. 
2. We may also disclose your personal data when you instruct or permit us to do so, or when required by applicable law, judicial or official requests, or for the investigation of actual or suspected fraudulent or criminal activities. 
3. We will not transfer personal data outside the EEA unless one or more of the specified safeguards or exceptions apply to the transfer, respectively adequacy decision sauce Mandatory corporate regulations. 
4. In the absence of an adequacy decision or appropriate safeguards, the transfer of personal data to a third country or an international organization shall only take place on the following conditions: 
5. the data subject has explicitly consented to the proposed transfer, after having been informed of the possible risks to the data subject arising from the transfer, in the absence of an adequacy decision and appropriate safeguards; 
6. the transfer is necessary for the performance of a contract between the data subject and the controller or for the performance of pre-contractual measures taken at the data subject's request; 
7. the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person; 
8. the transfer is necessary for important reasons of public interest; 
9. the transfer is necessary for the establishment, exercise, or defense of legal claims; and/or 

8. Storage and security of personal data  

1. Ensuring the confidentiality of the personal data you transmit to us is an important concern for us. We have implemented technical and organizational measures to maintain the confidentiality and security of your personal data, in accordance with our internal procedures regarding the storage, disclosure, and access of personal data. Personal data may be stored on our personal data technology systems, those of our contractors, or in hard copy format. 

9. Your Rights 

We wish to inform you that, within the framework of the new personal data protection regulations provided by the EU General Data Protection Regulation 679/2016, if we process your personal data, you have the following rights: 

• right of access, as provided by Article 15 of the GDPR, under which you can ask us, free of charge, to confirm whether or not we process personal data concerning you. You can also request a copy of the data we process about you. Requests must include relevant information to enable us to identify you in our database. We will resolve your request within a maximum of 30 days; 
• the right to information – assumes informing the data subjects concisely, transparently, and in an easily accessible manner about the processed data; 
• right to rectification, as provided for by Article 16 of the GDPR, which you can exercise by submitting a request asking us to modify the information we already have about you. You can make such a request when you notice that your data is incomplete or inaccurate; 
• right to restrict processing, as provided for by Article 18 of the GDPR, which you can exercise when you contest the accuracy of the data, consider the processing to be unlawful, or object to the erasure of the data. Following the exercise of this right, we will be able to continue storing your data, and other processing operations will only be possible with your consent, except in cases expressly provided for by law; 
• Right to portability, as provided for by Article 20 of the GDPR, which you can exercise only in cases where the processing is based on your consent or a contract, and only if your data is processed by automated means. If you meet the conditions, you can send us a request to port the data to the operator of your choice; 
• the right to object to data processing for marketing purposes, as provided for by Article 21 of the GDPR. You can exercise this right at any time, and we guarantee that your data will no longer be processed for this purpose. However, it is possible that a reasonable period of time (up to 72 hours) may be required to register and process your request, during which time you may still receive marketing information from us; 
• Right to erasure, under Article 17 of the GDPR, under which we are obligated to delete the personal data we process about you. This right is not absolute, as it only applies in certain situations expressly provided for by law. When submitting a deletion request, please keep in mind that deleting data can be a complex process. 
• the right to address the National Supervisory Authority for Personal Data Processing, public authority in Romania, located at B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania, web page http://www.dataprotection.ro, whose objective is to defend the fundamental rights and freedoms of individuals, in particular the right to intimate, family, and private life, in connection with the processing of personal data and the free movement of such data („ANSPDCP”), in case you notice a GDPR violation. 

To exercise these rights, please send us a written request to the email address dpo@impactsa.ro, with the subject Request for personal information. 

If you are not satisfied with how we have resolved your request, you can contact the National Supervisory Authority for Personal Data Processing.  

10. Updating Our Privacy Policy 

The most recent update to the Policy was made in March 2022. We reserve the right to update and amend this Data Protection Policy periodically to reflect any changes in how we process your personal data or any changes in legal requirements. In the event of any such changes, we will display the amended version of the Policy on our website and/or make it available in another way. 

11. Contact  

For additional information regarding the content of the data protection policy, please contact us at the email addressdpo@impactsa.ro.