Impact Developer & Contractor SA a Romanian legal entity established in Bucharest, 172-176 Bucuresti-Ploiesti Road, Willbrook Platinum Convention Center, Building A, Floor 1, Office no. 1, District 1, registered at the Trade Register under no. J40/7228/2018, with Fiscal Code 1553483, bank account no. RO83BTRL05001202G09191XX opened with Banca Transilvania, will process the personal data of the site's users www.greenfieldresidence.ro
As the controller of your personal data concerning your subscription to commercial communications, we would like to inform you about how this data is processed.
For the purpose of subscribing to commercial communications, other controllers will be involved, respectively other companies affiliated to Impact Developer & Contractor SA Group: Greenfield Copou Residence SRL, along with Actual Invest House SRL and Bergamot Development SRL.
The purpose of personal data processing
The processing of your data is intended to enable commercial communications and allows us to: send you commercial communications taking into account the interests you have identified when transmitting your contact details; send you communications on news, events/contests, and promotions organized by the controllers; send you communications on events dedicated to potential investors; and perform statistical analysis on the performance of this service, among other things.
If you provided your phone number when subscribing via tablets at sales offices or relevant trade fairs, please be aware that we may send you commercial messages for the purposes stated above or contact you by phone.
If the subscription to commercial communications was made by any means other than the use of the tablet, we will use only the email address provided at the time of subscribing via the appropriate subscription box as the communication channel. Under these conditions, using an API will transmit only information regarding last name, first name, email address, source, and the date and time of subscription to the consent management platform.
Subscribing to marketing communications is a two-step process (double opt-in). To ensure the accuracy of the personal data collected, after completing the form and subscribing to our newsletter or to receive commercial information, we will send you an email containing a link to confirm your email address, which will be valid for 48 hours. If you have not confirmed your email address after 48 hours, your personal data submitted through the form will be deleted from our database.
Processing basis
We process your data for the above purposes under Art. 6 para. (1) a of the GDPR – respectively, the express consent given by you by going through the subscription process, respectively providing the data in the subscription form, and confirming this data by accessing the validation link.
Types of personal data processed
– Last name, first name, email address (required);
– Optional: phone number
– Observed: subscription date and time, IP address, source from which the subscription was performed.
Regarding the processing of your data sourced from websites operated by other controllers within the Impact group, this will be carried out based on Article 6, paragraph 1(f) of the GDPR – the legitimate interest of the controllers, who are part of the same economic group. This legitimate interest pertains to the centralization of consents for commercial communications and their management within a unified database, protected by appropriate security measures.
Failure to provide the mandatory data will make it impossible to use the service.
Data source
Your data provided to receive commercial information (last name, first name, email and/or telephone number) will be sourced from the website forms www.greenfieldresidence.ro Baneasa or Copou, www.luxuria-residence.ro, www.impactsa.ro, www.boreal-plus.ro through which you have expressly expressed your desire to subscribe to commercial communications, either by filling out the data in the contact form or in the newsletter, by checking the appropriate box on the request form, or by ticking the appropriate box on the contact form.
Also, your data (last name, first name, email address, and/or phone number) may be the source for the Impact Genius program you have signed up for.
Finally, the data source can be the completion of the data required for subscribing to marketing communications on the tablets available at the relevant trade fairs or in the sales offices.
Target categories
Individuals who visit the sales offices of any residential complexes, those who subscribe to these communications as participants in real estate fairs where controllers are present, or those who check the box for subscribing to commercial communications on websites operated by these controllers.
Data recipients
Your data is not transferred outside of Romania.
Should we decide to engage a processor for the processing of your data for the purposes outlined above, we will do so only after a processor agreement has been concluded in accordance with Article 28 of the GDPR, and with the transfer of responsibility to them.
Storage time
Your personal data will be stored until you exercise your right to delete it. If you exercise only a right to object to commercial communications, they will not be deleted but will be properly marked so that you will not receive such communications in the future. In general, your data will be stored for 3 years from obtaining your consent or from your last interaction with us.
Email addresses and personal data provided but not confirmed within 48 hours of receiving the confirmation link will be automatically deleted.
Personal data protection measures
Regarding the personal data collected through each of the controllers’ websites, it is transmitted via an API to the consent management database.
Regarding the security measures applicable to database access, the principle of necessary and sufficient access in relation to user duties has been taken into account, as have the internal rules on passwords associated with user accounts.
To ensure compliance with the principle of data accuracy, the use of the email address as a communication channel will begin only after you have completed the email address confirmation process.
Exercise of rights
In accordance with the provisions of Articles 15-22 of the GDPR (General Data Protection Regulation 2016/679), you have the following rights, which you may exercise by submitting a request to dpo@impactsa.ro.
- The right to withdraw consent – which does not affect the processing conducted during the validity period of this consent and which can be exercised at any time by clicking on the unsubscribe link available in each commercial communication sent or by making a request to withdraw your consent. This right may be exercised with respect to any of the communication channels.
- The right to be informed refers to the obligation of the controllers to provide you with correct information regarding the processing of data, regarding the manner in which your personal data is used;
- The right to access means you have the right to obtain confirmation from us about whether or not we process your personal data, and if so, we will provide you with access to that data, as well as information about how it is processed. You also have the right to obtain a copy of the data we process concerning you.;
- The right to portability refers to the fact that you can receive personal data in a structured, commonly used, and machine-readable format, as well as transmit this data to another controller, subject to certain conditions provided by the provisions of the Regulation;
- The right to object targets the right to object to the processing of personal data when it serves a public interest or a legitimate interest of ours.
- The right to rectification refers to the correction, without undue delay, of inaccurate personal data;
- The right to delete / the right to be forgotten means you have the right to delete your collected data without undue delay in any of the following situations: the data is no longer necessary for the purposes for which they were collected, withdrawal of consent, objection to processing, unlawful collection, deletion to comply with a legal obligation, or collection made with the provision of information society services;
- The right to restrict processing can be exercised if the accuracy of the data is disputed for a certain period, sufficient to verify the data, if the processing is illegal but one doesn’t want to delete the data, only to restrict it; if we no longer need the personal data for processing but you are asking us to defend a right in court; or if you have objected to the processing.
If you are not satisfied with the way we have resolved a request to exercise a right, you have the right to file a complaint with the National Supervisory Authority For Personal Data Processing.