Personal Data Protection Policy

Personal Data Protection Policy of www.greenfieldresidence.ro

1. Our commitment to your personal data
   • Impact Developer & Contractor SA a Romanian legal entity established in Bucharest, District 1, Drumul Padurea Mogosoaia, 31-41, registered at the Trade Register under no. J2018007228408, with Fiscal Code 1553483, bank account no. RO83BTRL05001202G09191XX opened with Banca Transilvania, will process the personal data of the site's usersgreenfieldresidence.ro in accordance with its Personal Data Protection Policy („Policy”).
   • The policy is based on the provisions of 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 goes into effect on May 25^The, 2018, as well as on the applicable national legislation.
   • The method of processing personal data by IMPACT is uniform across all companies within the IMPACT Group, specifically Bergamot Developments SRL, Greenfield Copou Residence SRL, and Actual Invest House SRL. The database is jointly managed by the IMPACT Group.
   • „The GDPR defines personal data as „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 many specific elements, specific to their physical, physiological, genetic, mental, economic, cultural or social identity.
   • IMPACT DEVELOPER & CONTRACTOR SA undertakes to implement the highest standards of confidentiality and transparency regarding the personal data it processes in its current activity. The protection and total transparency regarding the processing of your personal data in our activity are our most important objectives.
   • Please also consult our Cookie Policy available at greenfieldresidence.ro which explains our use of cookies / other web tracking technologies through our website.
   • Any information regarding the processing of your personal data can be requested at dpo@impactsa.ro, belonging to the Data Protection Officer appointed in accordance with the provisions of the GDPR.

2. Agreement
   • Your use of our services is subject to the provisions of the Policy and the Cookie Policy. By using our services, you agree to the terms of this Policy. The purpose of the Policy is to inform our clients about the collection, storage, and use of personal data.
   • If you do not agree with the Policy, please stop using our services.
   • The use of the site greenfieldresidence.ro does not necessarily imply the provision of personal data. However, if you decide to provide us with personal data, we would like to explain the way we process the data you provide us.

3. Categories of Personal Data Collected

The personal data we process as a result of your use of thewww.greenfieldresidence.ro site may include:

• contact information, such as your first and last name, e-mail address, telephone number;
• details about the type of housing you want or other information about the project
• Your IP address, which is processed when you contact our site operator;
• details of your visits to our website (in this regard, we recommend that you read our Cookies Policy);
• Other information you send to us when you make a request on the site or as a result of sending it by email or phone.

4. Ways we collect your personal data

• We collect your data from an email or phone request
  • We collect personal data including your last name, first name, email address, and telephone number to maintain correspondence or communication with you. Therefore, if you make a request via email or phone, we will process your data to resolve it.
  • In this context, if required by your request, we may send your contact details to financial and governmental institutions, transport companies, or the post office.
  • Except as set forth above, the data provided by you while browsing the greenfieldresidence.ro will be used solely for your own benefit and will not be shared with third parties without your prior consent.
• We collect your data as a result of a request to be contacted by a consultant.
  • We collect personal data including your last name, first name, email address, telephone number, and interest in contracting (the type of home you want). This data is provided as a result of your request to be contacted by a consultant, by filling in the fields on the site.
  • In this regard, our consultants will contact you to provide you with more information and to send you a personalized offer.
  • If you have expressly consented to your personal data being processed for marketing purposes in order to receive newsletters, information about products and services, or events and contests organized by us, our company will process your data for marketing purposes.

5. The purposes for which we process your personal data

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

• offering our products and services consisting of apartment-type houses or villas in residential complexes built by Impact Developer & Contractor SA and the affiliated companies within the Group;
• sending invitations for events organized by Impact Developer & Contractor SA and the companies within the Group;
• compliance with our legal obligations (such as obligations to keep records and supporting documents);
• analyzing and improving our services and communications to you;
• Protecting security and managing access to our headquarters, IT and communication systems, online platforms, websites, and other systems; preventing and detecting security threats, fraud, or other criminal or malicious activities.;
• to identify the persons authorized to trade on behalf of our clients, beneficiaries, suppliers and/or service providers;
• their transmission to third parties, if you have expressly consented;
• marketing campaigns, client surveys, market reviews, raffles, contests, or other promotional activities or events, if you have expressly consented;
• for any purpose related to 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
   • We promote our services to you and others. We use customer information to send out invitations and communications that promote the products and services we provide. To the extent that you have agreed to this by checking the box on the contact form, we will be able to use the personal data you provide to send communications about the products and services we provide.
   • In all cases, you will be able to unsubscribe from receiving marketing information by accessing the unsubscribe link that you will find in each such communication.
   • Please note that in the event of an unsubscribe request, there may be a time limit of up to 48/72 hours in which you may receive further information or marketing communications for reasons related to the operation of system changes. Unsubscribing from marketing emails does not preclude further transmission of transactional emails through which we can inform you of the status of the transaction that we may conclude.

7. Sharing and transferring your personal data
   • We may provide access to the personal data you provide to companies within the IMPACT Group, specifically Bergamot Developments SRL and Actual Invest House SRL, who are our authorized representatives. This access is primarily for service providers, but we will maintain control over the data and implement appropriate safeguards in accordance with applicable law to ensure the integrity and security of your personal data. Regarding access by other companies in the Group, it will always be limited to the personal data they require to provide a service to you.
   • We may also disclose personal data when you instruct or permit us to do so, when required by applicable law, upon request from judicial or official bodies, or for the purpose of investigating fraudulent or criminal activities, whether actual or suspected.
   • We will not transfer personal data outside the EEA, unless one or more specified safeguards or exceptions apply to the transfer, i.e. an adequacy decision or Binding Corporate Rules.
   • In the absence of a decision on adequacy or of binding corporate rules, the transfer of personal data to a third country or to an international organization shall only take place subject to appropriate safeguards.
     • the data subject has explicitly agreed to the proposed transfer after being informed of the possible risks of such transfers for the data subject, due to the lack of an adequacy decision and appropriate safeguards;
     • 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;
     • 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;
     • The transfer is necessary for important reasons of public interest;
     • the transfer is necessary for the establishment, exercise, or defense of legal claims; and / or

8. Storage and security of personal data
   • 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 to personal data. Personal data may be stored on our personal data technology systems, those of our contractors, or in print.

9. Your rights
   • We want to inform you that, in accordance with the new regulations on the protection of personal data provided by the General Data Protection Regulation (EU) 2016/679, you have the following rights when we process your personal data:

• the right to access, provided by Art. 15 of the GDPR, based on which you can ask us, free of charge, to confirm whether or not we process personal data concerning you. You may also request a copy of the data about you that we process. Requests must include relevant information in order to be able to identify you in our database. We will resolve your request within a maximum of 30 days.;
• the right to information – implies providing data subjects with clear, transparent, and easily accessible information regarding the processed data;
• the right to rectification, provided for by Article 16 of the GDPR, which you can exercise by submitting a request 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;
• the right to restrict processing, provided for by Article 18 of the GDPR, which you may 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 may still store your data, with other processing operations being possible only with your consent, except as expressly provided for by law;
• the right to portability, provided by art. 20 of the GDPR, which you can only exercise in cases where the processing is based on your consent or contract and only if your data is processed by automated means. If you meet the conditions, you can send us a data portability request to the operator of your choice;
• the right to object to the processing of data for marketing purposes, provided by Art. 21 of the GDPR. You may exercise this right at any time, and we guarantee that your data will no longer be processed for this purpose. However, it may take a reasonable amount of time (up to 72 hours) to register and resolve your request, and during this time you may still receive marketing information from us.;
• the right to delete, provided by Art. 17 of the GDPR, based on which we have the obligation to delete the personal data about you that we process. This right is not an absolute one, being applicable only in certain situations expressly provided by law. When requesting a deletion, please note that deleting the data can be a complex process.
• the right to address the National Supervisory Authority For Personal Data Processing, the Romanian public authority, based at 28-30, G-ral Gheorghe Magheru Blvd., District 1, postal code 010336, Bucharest, Romania, website http://www.dataprotection.ro, which aims to protect the fundamental rights and freedoms of individuals, especially their right to privacy, family, and private life, with regard to the processing of personal data and the free movement of such data.„ANSPDCP„), in case you report a GDPR breach.
  • 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 the way we handled your request, you can contact the National Supervisory Authority For Personal Data Processing.

10. Our Privacy Policy Update

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

11. Contact

For additional information on the content of the Data Protection Policy, please contact us at the e-mail address dpo@impactsa.ro.