Privacy Policy

Last updated: November 2022

I. General information

The privacy of your personal data is one of the main concerns of [website owner], based in 201a Victoria Street, London SW1E 5NE, as data controller.

This document is intended to inform you about the processing of your personal data, in the context of using the golemestate.com website (the "Site")

II. The categories of processed personal data

II.1. If you are a user of the Website, St Publius Estate LTD will process your personal data, such as name and surname, telephone, email address, billing address, delivery address, data related to how you use the Website, for example your behavior/preferences/habits within St Publius Estate LTD, as well as any other categories of data that you provide directly in the context of creating the user account, in the context of placing an order through the website or in any other way resulting from the use of the website.

If you use your Facebook or Google account to create a user account on the Site, St Publius Estate LTD will process the following public profile data displayed by the respective applications: username, email address, phone number.

III.2. If you are a visitor to the Website, St Publius Estate LTD will process your personal data that you provide directly in the context of using the Website, such as the data you provide in the contact / questions / complaints section, to the extent that you contact us in this

III. Purposes and grounds of processing

III.1. If you are a customer of the Website, St Publius Estate LTD processes your personal data as follows: to facilitate your access to the best real estate offers available on the planet. To fulfill the legal obligations incumbent on St Publius Estate LTD in the context of the services provided through the website, including the obligations in fiscal matters, as well as in matters of archiving.

Grounds: The processing of your data for this purpose is necessary based on legal obligations. Providing your data for this purpose is necessary. Refusal to provide data may result in the impossibility of St Publius Estate LTD to comply with its legal obligations and therefore in the impossibility of offering you services through the website.

- For marketing activities, respectively for the transmission, by means of remote communication means (e-mail, sms) of commercial communications regarding the products and services offered by St Publius Estate LTD through the website.

Grounds: The processing of your data for this purpose is based on your consent, if you choose to provide it.

You can express your consent to the processing of data for this purpose by accepting the privacy policy.

Providing your data for this purpose is voluntary. The refusal to provide consent for the processing of your data for this purpose will not have negative consequences for you.

- In order to carry out various analyses, reports on the operation of the Website, the creation of profiles of consumer preferences, mainly in order to improve the experience offered on the Website.

Grounds: The processing of your data for this purpose is based on the legitimate interest of St Publius Estate LTD to permanently improve the customer experience on the Site. The supply of your data for this purpose is voluntary. The refusal to provide data for this purpose will not have negative consequences for you.

III.2. If you are a visitor to the Website, [website owner] processes your personal data as follows:

- For marketing activities, respectively for the transmission, by means of remote communication means (e-mail, sms), of commercial communications regarding the products and services offered by St Publius Estate LTD, through the Site.

Grounds: Processing your data for this purpose is based on your consent, if you choose to provide it.

Providing your data for this purpose is voluntary. The refusal to provide consent for the processing of your data for this purpose will not have negative consequences for you.

- To resolve complaints, complaints and to monitor traffic and improve your experience on the website.

Grounds: The processing of your data for this purpose is based on the legitimate interest of St Publius Estate LTD to ensure the proper functioning of the Website, as well as to permanently improve the experience of the Website visitors, including by solving various comments, questions or complaints. Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will have no negative consequences for you.

IV. How long we process your data

As a matter of principle, St Publius Estate LTD will process your personal data as long as it is necessary to achieve the processing purposes mentioned above.

If you become a customer, we will process your data for the entire duration of the contractual relationship and thereafter in accordance with the legal obligations incumbent on [the website owner] (e.g., in the case of financial and accounting supporting documents for which the retention period provided for by law is 10 years from the end of the financial year during which they were drawn up).

If you withdraw your consent for the processing of data for marketing purposes, St Publius Estate LTD will stop processing your personal data for this purpose, but without affecting the processing carried out by St Publius Estate LTD based on the consent expressed by you before its withdrawal.

V. Disclosure of personal data

In order to fulfill the processing purposes, [website owner] may disclose your data to partners, to third parties or entities that support St Publius Estate LTD in carrying out its activity through the Website (for example courier companies, IT service providers), or to real estate developers, central/local public authorities, in the following exemplary cases listed:

- For website administration;

- In situations where this communication would be necessary for awarding prizes or other facilities to the persons concerned, obtained as a result of their participation in various promotional campaigns organized by St Publius Estate LTD through the website;

- To maintain, customize and improve the Site and the services provided through it;

- To perform data analysis, testing and research, monitoring usage and activity trends, developing safety features and user authentication;

- For the transmission of commercial marketing communications, under the conditions and limits provided by law;

- When the disclosure of personal data is provided by law, etc.

VI. Personal data transfer

The personal data provided to St Publius Estate LTD may be transferred outside of Romania, to countries in the European Union or Dubai. [Note: If transferred outside the EU, states must be mentioned and what are the safeguards for data protection in the context of the transfer.]

VII. Your rights

Under the conditions provided by the legislation on the processing of personal data, as data subjects, you benefit from the following rights:

- the right to information, respectively the right to receive details regarding the processing activities carried out by St Publius Estate LTD, as described in this document;

- the right to access the data, respectively the right to obtain confirmation from St Publius Estate LTD regarding the processing of personal data, as well as details regarding the processing activities such as the manner in which the data are processed, the purpose for which the processing is done, the recipients or categories of data recipients, etc.;

- the right to rectification, respectively the right to obtain the correction, without justified delay, by St Publius Estate LTD of inaccurate/unjustified personal data, as well as the completion of incomplete data; The correction/completion will be communicated to each recipient to whom the data were sent, unless this proves impossible or involves disproportionate efforts.

- the right to delete data, without undue delay, ("the right to be forgotten"), if one of the following reasons applies:

- they are no longer necessary to fulfill the purposes for which they were collected or processed;

- if consent is withdrawn and there is no other legal basis for processing;

- if the data subject objects to the processing and there are no legitimate reasons to prevail;

- if the personal data were processed illegally;

- if personal data must be deleted to comply with a legal obligation;

- personal data were collected in connection with the provision of information society services according to Union law or the internal law under which the operator is subject.

It is possible that, following the request to delete the data, St Publius Estate LTD will anonymize these data (thus depriving them of their personal character) and continue processing them for statistical purposes under these conditions;

- the right to restrict processing to the extent that:

- the person contests the accuracy of the data, for a period that allows us to verify the correctness of the data;

- the processing is illegal, and the data subject opposes the deletion of personal data, requesting instead the restriction of their use;

- the operator no longer needs the personal data for the purpose of processing, but the data subject requests them for establishing, exercising or defending a right in court; or

- the data subject has objected to the processing (other than those for direct marketing), for the time interval in which it is checked whether the legitimate rights of the operator prevail over those of the data subject.

- the right to data portability, respectively (i) the right to receive personal data in a structured way, commonly used and in an easy-to-read format, as well as (ii) the right to have this data transmitted by to [the website owner] to another data operator, to the extent that the conditions provided by law are met;

- the right to opposition – regarding processing activities can be exercised by sending a request as indicated below;

- at any time, for reasons related to the particular situation in which the data subject finds himself, that the data concerning him be processed on the basis of the legitimate interest of St Publius Estate LTD or on the basis of the public interest, except in cases where St Publius Estate LTD can demonstrate that it has legitimate and compelling reasons that justify the processing and that prevail over the interests, rights and freedoms of the data subjects or that the purpose is to establish, exercise or defend a right in court;

- at any time, free of charge and without any justification, that the data concerning it be processed for direct marketing purposes.

- the right not to be subject to an automated individual decision, i.e. the right not to be the subject of a decision taken solely on the basis of automated processing activities, including the creation of profiles, which produce legal effects that concern the data subject or affect him in a similar way to a significant extent;

- the right to address the National Supervisory Authority for the Processing of Personal Data or the competent courts, to the extent you consider necessary.

For any additional questions about how personal data is processed and to exercise your rights mentioned above, please contact the email address: contact@golemestate.com