This platform (hereinafter: „our website“, „Service“) is owned and operated by APS Recovery a.s., with its registered office at Pobřežní 394/12, Karlín, 186 00 Praha 8, Czech Republic, ID no. 03409422, registered in the Commercial Register maintained by the Municipal Court in Prague, section B, insert 20011 (hereinafter: “APS” or “we”) as data controller within of meaning GDPR which assumes responsibility for protecting and maintaining the confidentiality of your data during your visit in our website.
We act as an intermediary between the real estate broker and the market. By creating a technological background and communication paths, we provide users with the opportunity to offer for sale real estate assets and the opportunity to buy these assets by buyer.
Please direct your questions about data protection to our group DPO: firstname.lastname@example.org.
We expressly point out that when using this e-mail address, the contents are not exclusively noted by only our data privacy officer. If you would like to exchange confidential information, please contact us directly via this e-mail address without giving us a detailed description of the facts.
Our service process your personal data in in the following cases:
If you call up our websites in order to obtain information about our real estate offers and services, your personal data will be processed for the following purposes and on the basis of the following legal bases:
I. in order to improve the quality and convenience of services and to provide a correct service to users basis of Art. 6 Para. 1 S.1 lit. f) GDPR;
II. to ensure the stability and security when you visit our website on the basis of Art. 6 Para. 1 S.1 lit. c) GDPR and / or on the basis of our legitimate interest in answering your request on the basis of Art. 6 Para. 1 S.1 lit. f) GDPR;
III. in providing you with information on our products and services on our website;
IV. we may monitor and analyse how you use our website, e.g. your surfing habits on our website and which properties you are interested in;
V. carry out marketing activity of the brokerage of our real estate. If you are interested in our properties, you can subscribe to our information e-mails. These e-mails will inform you about real estate properties. We process your personal data if you give us your consent to do so within the meaning of Art. 6 Para. 1 S. 1 lit. a) GDPR;
VI. if you have any questions about properties listed in our platform, require assistance in finding properties, would like to arrange appointments, you can contact our customer service. You may contact us by telephone or e-mail,. We process your personal data based on the nature of your request. If necessary, we may also use personal data stored in our systems as part of other data processing. Depending on your request, your personal data will be processed for the purpose of initiating, implementing or, if necessary, processing the contract with you on the basis of Art. 6 Para. 1 S.1 lit. b) GDPR, in order to fulfill our legal obligations towards you on the basis of Art. 6 Para. 1 S.1 lit. c) GDPR and / or on the basis of our legitimate interest in answering your request on the basis of Art. 6 Para. 1 S.1 lit. f) GDPR;
VII. we use various social media channels (currently Facebook, Instagram and Twitter) where we regularly publish reports and photos to inform you about us and our assets. The social media channels give you the opportunity to respond to our "posts" and communicate with us. We may process your personal data on the basis of our legitimate interest in answering your comments / questions / suggestions and advertising real estate on the basis of Art. 6 Para. 1 S. 1 lit. f) GDPR. For the use of social media, the data protection information of those channels you use applies. Please refer to the corresponding data protection information for further details in social media policies.
VIII. to perform compliance audits and measures and internal audit and lefal agenda (e.g document infringements, special investigation) on the basis of Art. 6 Para. 1 S. 1 lit. c) GDPR or Art. 6 Para. 1 S. 1 lit. f) GDPR.
IX. tax, billing & accounting purpose. In order to comply with tax, billing and accounting regulations we must process certain limited scope of personal data. We do this because we are obliged to do so pursuant to the Art. 6 Para. 1 S. 1 lit. c) GDPR;
X. we keep anonymous or aggregated statistics like number of users, campaigns or users, number of visit certain pages, average conversion rate and similar. We ensure such statistics are not personal data, however, these statistics might be made by conversion from the personal data about visitors. In line with Art. 89 of the GDPR, statistical processing is performed on this basis of any of above-mentioned legal bases.
The data you can provide us as user or visitor:
When you access our website, contact us, or otherwise interact with us, we collect personal information about you. Personal information is information about an individual from which that person can be identified. It does not include information where the identity has been removed (anonymous data). We may also receive personal information about you from other sources. We may combine the personal information you provide to us with information that is collected through automated methods and with information we receive from other sources. Information we collect about you may include:
- • email and / or phone number;
- • name and surname;
- • other information you feel free to share.
If you cooperate with us like real estate professional (broker, agent, agency, you name it) you may also provide additional information:
- • company name;
- • legal name;
- • license number;
- • licence number period;
- • employee information: name, surname, email, phone number, employee group;
- • other information you feel free to share;
The data we collect by technology (mainly cookies):
- • IP-address of connection;
- • timezone;
- • location;
- • preferencies.
- • We may take information about you from applications in accordance with their own privacy policies. Information we receive from third party services (e.g. analytics platforms and tools).
Recipients of your personal data and sub-processors
- • providers of standard software solutions (such as Microsoft and Google, Teamviewer)
- • hosting or cloud services providers (Google);
- • marketing and analytics software service providers and social media platform operators (such as Google and Facebook, LinkedIn, Twitter Instagram);
- • providers of cybersecurity tools and solutions
- • legal, audit, billing and accounting advisors;
- • public authorities if required based on local law.
- • International transfer
Usually, we do not to transfer your personal data outside the European Economic Area (hereiafter „EEA“) where not necessary. By default, we have all cloud and servers located in the EEA. If some of our sub-processors or the recipients of personal data are based, or their servers are located in USA. Because of abolishing the EU-US Privacy Shield in July 2020 by the Court of Justice of the EU any transfer of personal data outside the EEA is done by us under compliance with the GDPR. We ensure the third-party recipients in non-adequate countries concluded the EU standard contractual clauses (EU SCC) or follow equivalent safeguards such binding corporate rules (BCRs). EU SCC are concluded with all US-based sub-contractors or recipients (such as Microsoft, Google, Facebook, Twitter, LinkedIn) together with additional safeguards according to recommendation of European Data Protection Board which follows Court of Justice of the EU decision mentioned above.
In addition, if case you are interested in a property outside the EU (eg. Montenegro, Bosnia, Serbia) contact details provided by you will be shared with a partner´s broker in order to provide more information about such a the property.
We transfer you personal data outside of EEA to following suppliers:
|DPA with EU SCC avaiable here||https://policies.google.com/privacy?hl=en-US|
|DPA with EU SCC available here||https://www.facebook.com/legal/terms/dataprocessing|
|DPA with EU SCC available here||https://www.linkedin.com/legal/privacy-policy|
|DPA with EU SCC avaiable here||https://twitter.com/en/privacy|
|Microsoft||EU SCC – available here||https://privacy.microsoft.com/en-us/privacystatement|
|Teamviewer||Conditions set out in EULA||https://www.teamviewer.com/en/gdpr/#1534251422746-6ccc2218-92f9|
How long do we store your personal data?
We keep your personal data for the time necessary to meet the defined purposes of processing, but not longer than for the duration of the contract. We keep invoices as well as other tax and accounting documents in accordance with the relevant legal regulations for a period of 10 years after the year to which they relate. We store personal data processed for advertising and marketing purposes for a period of 3 years from their collection. After this time, your personal data will be deleted. For statistics, we store your data as long and only if other purposes of processing are relevant. As soon as the data is not personal, GDPR does not apply and retention periods are unlimited. In the event that at any time you object to the processing of your personal data for direct marketing of our Services, we will stop processing your personal data for this purpose.
What rights do you have?
- When we process your personal, you have following data subject rights under the Article 15 to 22 of the GDPR:
- • right to request information and access to your personal data (Art. 15 GDPR);
- • right to rectification of inaccurate data (Art. 16 GDPR);
- • right to erasure of personal data (right to be forgotten) (Art. 17 GDPR);
- • right to restriction of processing (Art. 18 GDPR);
- • notification right regarding rectification, erasure or restriction (Art. 19 GDPR);
- • the right to data portability (Art. 20GDPR);
- • right to object against profiling (Art. 21 GDPR);
- • right not to be subject to individual decision making (Art. 22 GDPR).
“You have right to object to any processing that is based on legitimate interest or public interest including to profiling pursuant to the Article 21 GDPR. You also have a right to object to any direct marketing processing of your personal data including profiling.”
As regards consent (including cookie consent): “You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.”
How to access your data?
To access data directly or indirectly relating to you, please write to email@example.com. If you believe that any information about you is unreliable or misused, or if you want to change, delete this information, contact us at the above email address.
You have also a right to lodge a complaint to the relevant data protection supervisory authority. Please note that our lead supervisory data protection authority is the Data Protection Authority (https://www.uoou.cz/) with its office at Pplk. Sochora 727/27, 170 00 Praha 7, Holešovice.