Privacy Policy

This information (hereinafter, “Privacy Policy”) relates to the processing of your personal data while browsing the website www.isola4fregene.it (hereinafter, the “Site”) carried out by Savills Residential Italy Srl, with registered office and administrative office in Via di Montoro, 8 00186 Rome, telephone number +39 06456501112, VAT number IT12353811008, e-mail amministrazione.resi@savills.it PEC savillsresidential@pec.it (the company DPO can be contacted at the e-mail address: dpoitaly@savills.it) (hereinafter, the “Data Controller”), in compliance with the regulations in force regarding the protection of personal data, including EU Regulation GDPR 679/16, Legislative Decree 196/03 and Legislative Decree 101/18.

1. Identity and contact details of the Representative

The Data Controller is Savills Residential Italy Srl.
As the Data Controller is established in the EU, no representative has been appointed.

2. Means of processing

To complete the connection to the Site, some of your personal data are acquired. This set of data includes, for example:

• the IP address of the device you use;

• the date and time of access;

• the type of navigation browser;

• the operating system used.

To provide you with information on the Isola 4 Fregene project that you can request via the “Contact Us” form on the site and to sign up for the newsletter with updates on Savills’ commercial initiatives relating to real estate sales, some of your personal data are acquired. This set of data includes:

• your Name and surname

• your minimum contact details (telephone or e-mail)

For re-marketing activities, the following data will be processed:

• name, surname;

• e-mail.

3. Purpose of processing and legal basis of processing

Your personal data will be processed for the following purposes:

a) Personal data processed while browsing the Site: the communication of such personal data is a contractual obligation, without which the services of the Website could not be made available properly.

b) Personal data processed through subscription to newsletters to send commercial communications, through traditional and remote means of communication including email, SMS, social networks, instant messages, mobile applications, banners, post and telephone, for the promotion and/or sale of products and/or services marketed by the Data Controller: the communication of such personal data is optional, and is based on your consent, without which you could not finalize the subscription to the newsletter service offered by the Data Controller.

c) Personal data processed via the “Contact Us” Form: the communication of such personal data is optional, and is based on the legitimate interest of the Data Controller to follow up on your contact requests via the appropriate form on the Site. In the absence of this, the Data Controller will not be able to respond to such requests.

d) Personal data collected via the “Contact Us” Form for individual or aggregate profiling and market research activities by communicating the data to Google Analytics: the communication of such personal data is optional and is intended to analyze habits, interests and purchasing behaviors, and the processing of statistics on the same in order to develop products and/or services, improve the commercial offer in a specific way and send proposals in line with your preferences. This processing will take place exclusively after your consent, without which it will not be possible to proceed with the aggregate profiling and market research activities (“Re-Marketing Purposes”).

4. Source from which the personal data originate

Only the personal data provided in accordance with the Privacy Policy will be processed. The Data Controller will not process personal data from publicly accessible sources.

5. Recipients and categories of recipients of personal data

The following may be recipients of personal data:

• companies that offer information society services, including, in particular, those that offer hosting services, newsletters;

• companies that provide commercial and marketing services on behalf of the Data Controller;

• companies that make cloud software available;

• the website management and maintenance company.

• third-party service providers for the analysis of the so-called client insight, for Re-Marketing Purposes, such as Google Analytics.

The subjects belonging to the categories mentioned above may act as data controllers where carried out on behalf of the Data Controller, or operate independently as separate data controllers. The Data of the Interested Party processed by the Data Controller will not be published or disseminated in other ways.

6. Categories of personal data

Personal data necessary to complete your connection to the Site, subscription to the newsletter and sending the request via the “Contact us” form will be processed. In no case will the special personal data defined in Article 9 of the GDPR be processed.

7. Data Transfer

The Data Controller intends to transfer Personal Data to entities established in a third country outside the European Union in compliance with the applicable regulations, specifically: the United States of America and Canada. Any transfer of your Data to countries located outside the European Economic Area will, in any case, take place in compliance with the appropriate and suitable guarantees for the purposes of the transfer itself, pursuant to Articles 44 et seq. of the GDPR.

Such entities could be represented, by way of example, by:

• communications companies that carry out communication activities on behalf of the Controller;

• companies that offer information society services;

• companies that offer hosting services;

• communication company service providers;

To obtain a copy of such data or the place where they have been made available, simply send the relevant request to the Controller, at the addresses in the epigraph.

8. Period of retention of personal data

• The personal data processed and stored for the purposes referred to in point 3.a (contractual purposes) are processed and stored by the Data Controller in accordance with the provisions of current legislation, in any case for a period of time not exceeding 10 years from the termination of the effects of the contract in the event of its conclusion, unless otherwise required by law.

• The personal data processed and stored for the purposes referred to in point 3.b (marketing purposes) are processed and stored by the Data Controller until the consent is revoked, unless otherwise required by law.

• The personal data processed for the purposes referred to in point 3.c (purpose of responding to requests) provided voluntarily via email or form and processed to respond to your requests will be stored for a period of time strictly necessary to achieve this purpose and, in any case, not exceeding 16 (sixteen) months from the date of the individual collection.

• Personal data processed for the purposes referred to in point 3.d (re-marketing purposes) of this information notice are processed and stored until the interested party requests the cancellation and/or revocation. The Data Controller reserves the right to request, periodically, to renew the consents given.

9. Methods of expressing consent, optionality of consent and consequences of failure to consent

Consent may be expressed by signing a paper or computerized document, or even by means of specific flagboxes.

• In relation to personal data processed for the purposes referred to in point 3.a of this Privacy Policy (contractual purposes), the communication of personal data is an obligation. If you do not communicate such personal data, it will not be possible to provide the connection and navigation service to the Site.

• In relation to the personal data processed for the purposes referred to in point 3.b of this Privacy Policy (consent), the communication of personal data is optional. If you do not communicate such personal data, it will not be possible to provide the newsletter service.

• In relation to the personal data processed for the purposes referred to in point 3.c of this Privacy Policy (legitimate interest), the communication of personal data is optional. If you do not communicate such personal data, it will not be possible to respond to requests via the Contact Form.

• In relation to the personal data processed for the purposes referred to in point 3.d of this Privacy Policy (consent), the communication of personal data is optional and subject to your prior consent. Failure to provide consent will make it impossible for such third parties to keep you updated on new products or services, promotions, which may be in line with your interests.

• In relation to the personal data processed for the purposes referred to in point 3.e of this Privacy Policy (consent), the communication of personal data is optional and subject to your prior consent. Any failure to provide consent will make it impossible to provide you with and keep you updated on new products or services, promotions, which may be in line with your interests.

10. Right to object

As a Data Subject, you have the right to object under the following terms:

• the right to object at any time, for reasons relating to your particular situation, to the processing of Personal Data concerning you pursuant to Article 6, paragraph 1, letters e) or f) of the GDPR. The Data Controller shall no longer process your personal data, unless the Data Controller demonstrates compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims;

• where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, including profiling to the extent that it is related to direct marketing;

• where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. You may object to the processing of your personal data for direct marketing purposes even only in part, for example by objecting only to the sending of promotional communications carried out through automated and/or digital tools, or to the sending of paper communications and/or to the receipt of telephone communications;

• if your personal data are processed for scientific or historical research purposes or for statistical purposes pursuant to Article 89, paragraph 1 of the GDPR, for reasons related to your particular situation you have the right to object to the processing of personal data, unless the processing is necessary for the performance of a task of public interest.

11. Other rights

The Data Controller also wishes to inform you of the existence of the following rights:

Right of access: you have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning you are being processed and access your personal data and specific information, in accordance with Article 15 of the GDPR;

• Right to rectification: you have the right to obtain from the Controller the rectification of inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to obtain the integration of incomplete personal data, including by providing a supplementary statement, in accordance with Article 16 of the GDPR;

• Right to erasure of data, including the right to withdraw consent: you have the right to obtain from the Controller the erasure of your personal data without undue delay or to withdraw consent to the processing, if the reasons defined in Article 17 of the GDPR exist. You have the right to withdraw consent at any time, without prejudice to the lawfulness of the processing based on the consent given by you before the withdrawal;

• Right to restriction of processing: you have the right to obtain from the Controller the restriction of processing, when the hypotheses defined in Article 18 of the GDPR apply;

• Right to data portability: you have the right to receive your personal data provided to the Data Controller in a structured, commonly used and machine-readable format and you have the right to transmit them to another Data Controller without impediments from the Data Controller indicated in this Privacy Policy, as provided for by Article 20 of the GDPR;

• Right of opposition of the contractor to commercial communications: as a contractor, you have the right to object at any time, free of charge, to the receipt of commercial communications from the Data Controller;

• Right to lodge a complaint with the Guarantor Authority: you have the right to lodge a complaint with the Guarantor Authority for the Protection of Personal Data, to complain about a violation of the regulations on the protection of personal data, in accordance with Article 77 of the GDPR.

12. How to exercise your rights

You may exercise the rights indicated in the Privacy Policy by addressing requests directly to the Data Controller by contacting him/her through the following email addresses: amministrazione.resi@savills.it PEC savillsresidential@pec.it, furthermore the company DPO can be contacted at the email address: dpoitaly@savills.it ; or by sending the relevant communication by registered letter with return receipt to the address: Savills Residential Italy srl Via di Montoro, 8 00186 Rome. You may lodge a complaint with the Personal Data Protection Authority according to the methods provided by the official website, addressing it to the contact details available at https://www.garanteprivacy.it/home/footer/contatti.

13. Accessibility of the Privacy Policy

The Privacy Policy is available on the Site or at the Data Controller's premises. If expressly requested, the Data Controller may provide the information orally, provided that your identity is proven, with a telephone request to the following number: +39 06456501112.

14. Amendments

The Data Controller may modify the Privacy Policy, also to adapt to changes in national and/or European Union legislation, or to technological innovations. Any new versions of the Privacy Policy will be reported on the Site. We invite you to periodically check the Privacy Policy. Any changes will in any case be communicated to you through a pop-up on the Site or different methods and/or IT tools.

If the Data Controller substantially modifies the Privacy Policy, providing for new processing purposes and/or categories of personal data processed, the same will inform you, requesting the necessary consents, through a pop-up on the site or different methods and/or IT tools.