INFORMATION ABOUT PROCESSING OF PERSONAL DATA  

(EU REGULATION 2016/679) 

I, the undersigned FERRUCCIO PELLEGRINI, born in Milano (Milano) on 13th November 1951, for the purpose hereof domiciled at the real estate company IMMOBILIARE Studio13 with headquarters in Milano 20122 (Milano), Via Conservatorio 22, C.C.I.A.A. MILANO, Rea N. 1902572, VAT No. 09142530964, email: ferruccio.pellegrini@fastwebnet.it, PEC ferrucciopellegrini@pec.it, (hereinafter “Agent”), in my quality of legal representative thereof and “Processor for the processing of data” (hereinafter “Processor”) of your personal data (hereinafter cumulatively “Data”), in compliance with the EU REGULATION 2018/679 (hereinafter ‘Regulation’) and of which the Agent has become or will become acquainted with in connection with the real estate brokerage of your property in which you are the “Interested Party”, according to UE Regulation 2016/679 (hereinafter “Regulation”), supply you with the following information so that you may give your specific, unequivocal, informed, free and conscious consent to the Processing of the Data, which may take place including but not limited to IT tools and/or by other electronic means. 1. Origin of Data – All data necessary to carry out the Agency’s activity as agreed between the Parties, as well as data otherwise acquired within the scope of said activity, are collected by the Agency directly from the Interested Party and/or through third parties, and/or by consulting external public and private databases. 

2. Availability of the Information – The Agent provides the possibility to consult this Information: a) each time a customer’s personal data are collected; b) each time the Processor is specifically requested to; c) through surfing the Agent’s home page ww.immobiliarestudio13.com.

3. Scope of Data Processing – The Agent processes your data for its own institutional purposes, when connected or instrumental to the Agent’s activity, for the following purposes: a) to comply with the laws, regulations, EU laws and regulations, directives issued by Public Authorities or supervisory authorities, as in force from time to time; b) contractual purposes related to the establishment of a relationship with the customers, including but not limited to the acquisition of information in view of stipulating a contract; c) customer  satisfaction survey on quality of the services rendered, directly carried out by the Agent or through specialized third parties, through personal or phone interviews, interactive surveys, market analysis;  d) promotion of the Agent’s products and services through advertising material, phone contacts and any other form of electronic communication (email, sms, mms, social network); e) communication and/or transfer of data to third parties to promote and/or to sell products and services with traditional or straight-through processing. 

With reference to the scopes listed in paragraphs c), d), e), we inform you that you will be free at any time to revoke your consent given according to the provisions hereof.

4. Data Communication – You have a right to know that the provision of data may be mandatory or optional, and that a refusal to provide them may have consequences. In fact: a) your consent for the purposes of provisions of paragraphs a) and b) of point 3 is mandatory in compliance with the law or with contractual obligations (see article 6, paragraph 1, letters b) and c) of the Regulation). Should you refuse your consent for the purposes indicated in letter b) of point 3) Agent will not be in a position to operate or to reach the conclusion of the contract of which you are a party; b) on the contrary your refusal to the data processing for the purposes of letters c), d), e) of point 3 is optional, without any prejudicial consequences, and may be revoked at any time as far as the delivery of advertising material, customer satisfaction survey, market research or commercial communication through market research or commercial communication, telephone contacts or any other form of electronic communication (e-mail, sms, mms, whatsapp, publication on websites, social networks, etc.) is concerned, performed directly by the Agent or by specialized companies through by means of personal or telephone interviews, interactive questionnaires.

5. Processing of special categories of personal data – Article 9 of the Regulations defines as particular those data suitable to reveal racial and ethnic origin, political opinions, religious or philosophical beliefs, or union membership, as well as genetic and biometric data, data related to a person’s health or sexual life or sexual orientation. It is possible that the Agent will get in possession of particular data in relation to the specific services requested by the Interested Party. In this case, the Interested Party has the right to express a specific consent to the processing of his/her sensitive data and the Agent may use them exclusively to the extent necessary to perform the services and operations required.

6. Data Storage – The Data will be retained for the time necessary to manage the relationship and to fulfill any legal obligations, including the anti-money laundering legislation. The Data are always processed in compliance with the principle of proportionality (Article 5, paragraph 1, letter c) of the Regulations), according to which all Personal Data and the various modes of their processing must be relevant and not exceeding the scopes pursued, so as to ensure adequate security and confidentiality, as well as lawful and correct processing, and to prevent unauthorized access or use of personal data and processing equipment.

7. Data Storage – In compliance with Article 13, paragraph 2, letter a) of the Regulations, the data retention time is indicated hereunder according to the different processing purposes:

• with reference to letters a) and b) of point 3, the Data are kept for the period necessary to manage the

   contract or the relationship and to comply with legal obligations;

• with reference to letters c), d) and e) of point 3, storage times are set in 10 years.

8. Data Processing Modes – For the purposes indicated in point 3 hereof, Personal Data may also be processed by a ‘Data Manager’, i.e. a natural person or a company, even external to the Agency,  who may be entrusted with specific and defined tasks related to data processing, and by one or more “Processor(s)”, who will process or use the data according to the instructions received from the Data Controller or the Data Processor (subjects that, if not expressly indicated in this Information, are considered as not yet designated, and not necessarily to be designated if the processing is occasional, and whose details will be provided to you in the event of their designation). Always in relation to the aforementioned purposes, the Data may be processed through manual, computerized and/or otherwise automated tools according to logics strictly connected to the purposes of the data processing and, in any case, in order to guarantee their security and confidentiality, even in case of treatment through means of distance communication.

9. Transfer of Data Abroad – The Data can be transferred to EU or extra EU countries exclusively within the scope of letters a) and b) of point 3 hereof. In such case, the intention to transfer the personal data shall be previously communicated and authorized only if an adequate data protection level similar to the EU’s is guaranteed.

10. Data Communication – In consequence of the established relationship and to facilitate and allow the conclusion of a deal the Data may be communicated to: i) external consultants; ii) other agents (natural persons or companies) selected by the Agent to cooperate to ensure the accomplishment of the assignment given by you; iii) banks and other financial subjects; iv) contractual counterparts and their technical and professional advisors; v) notary publics for the drafting of deeds and/or activities related to the Agent’s assignment; vi) companies and/or consultants to obtain the necessary technical/cadastral/construction/urban permits; vii) insurance companies for the stipulation of policies relating to the Agent’s assignment; web site for the advertising of real estate; ix) boards of arbitrators and, in general, public and private subjects to whom communication is necessary for the correct fulfillment of the purposes indicated in point 3; x) Supervisory/Control bodies and other Authorities for purposes related to the compliance with law provisions (illegal interest rate law, anti-money laundering law)  and/or regulations, and provisions by the same Authorities. All subjects belonging to the categories to which the Data may be communicated will use the Data as “Processors” in compliance with the law or with a specific consent, and autonomously, being unrelated to the original processing carried out by the Agency, or as “External Managers”. You may request an updated list of the subjects whom your data will be communicated at any time by  writing to the Data Controller at the Agency’s headquarters. Finally, your data will be known by all employees and collaborators of the Agency, designated managers and/or in charge of data processing, each to the extent defined by his/her postion. The Data processed by the Agency will not be disclosed.

11. Rights of the Interested Party – Within the limits and under the conditions set out in articles 15 – 23 of the Regulations, the Agency guarantees and acknowledges to the Interested Party the exercise of the following rights: • the right to access to personal data stored in the Agency’s paper and/or electronic archives; • the right to request correction, updating and cancellation, if incomplete or erroneous, and to oppose your data processing for legitimate and specific reasons; • the right to obtain the correction of inaccurate personal data without unjustified delay. Taking into account the purposes of the data processing, the Interested Party is entitled to the integration of incomplete personal data, also by means of an additional statement; • the right to obtain the cancellation of personal data without undue delay if any of the reasons set out in art. 17, paragraph 1 of the Rules occurs; • the right to obtain a limitation of data processing when one of the cases referred to in art. 18, paragraph 1 of the Rules occurs; • the right to the portability of data to the extent and in the manner prescribed by art. 20 of the Regulation.

You also have the right to withdraw your consent to the processing of your data at any time, without any prejudice to the lawfulness of the processing based on your consent given before the revocation, as well as to object to processing for marketing purposes (right of opposition).

You have the right to be duly informed regarding any action taken following to one of the aforementioned requests or the effects as a consequence of the exercise of one of the aforementioned rights, without unjustified delay and, in any case, not later than one month after receipt of your request extendable by two months if necessary; you are also entitled to file a complaint with a supervisory authority and to apply for judicial review.

Without prejudice to the case in which the Data Processing violates the general principles of the Regulation, the exercise of these rights must be relevant and justified and cannot imply the revocation of the consent given or the request for Data cancellation provided in connection with the execution of the contract referred to in point 3) letters a) and b), in so far as and as long as the data are necessary for this purpose. Said rights may be exercised also through a designated person by submitting a request to the Data Controller or Data Processor at the following address:

Address      Immobiliare Studio13

                    Via Conservatorio 22

                    20122 Milano (MI)

                    Italy

Tel.              (+39) 02 77297543      

Mobile        (+39) 335 6931244

Email           ferruccio.pellegrini@fastwebnet.it          

PEC              ferrucciopellegrini@pec.it                 

In exercising your rights, you may grant a written proxy or power of attorney to individuals, associations or organizations; you may also be assisted by a trusted person. In order to guarantee the effective exercise of your rights, the Agency will adopt appropriate measures to facilitate the access to the Data, simplifying the procedures and reducing the time required to address your request.

Finally, you may file a complaint with the supervisory authority or with the Personal Data Protection Authority through the following means: a) registered letter A/R addressed to the Data Protection Authority, Piazza di Monte Citorio n. 121 00186 Rome; b) e-mail to: garante@gpdp.it, or protocollo@pec.gpdp.it; c) fax to +39 06 696773785. All related information on complaints submitted by the Interested party are available on the website of the Data Protection Authority at www.garanteprivacy.it.

12. Processor and Responsible for the Data Processing in compliance with article 24 of the Regulation is Mr. FERRUCCIO PELLEGRINI.