Privacy Policy

Subject: Information pursuant to Article 13 of Legislative Decree No. 196/2003 (Privacy Code) and EU Regulation 679/2016 – General Data Protection Regulation (GDPR)

Pursuant to and for the purposes of the above-mentioned legislation, we hereby wish to inform you in advance both about the use of your personal data and about your rights, providing the following information:

DATA CONTROLLER
The Data Controller is ABITARE AGENCY Srl, with registered office at Via Voghera, 7 – 20144 Milan. The updated list of data processors and their areas of responsibility is available at the Controller’s office and through the contact details provided in this notice.

PERSONAL DATA SUBJECT TO PROCESSING
For the purpose of carrying out real estate brokerage activities and fulfilling your service request, we use certain personal data. This includes identifying data, contact details (address, landline, mobile phone, fax, email), property-related data, economic capacity, property origin and cadastral certificates, and data related to your household composition.

PURPOSES, LEGAL BASIS, AND MANDATORY OR OPTIONAL NATURE OF PROCESSING
These data are provided by the data subject and may be collected by our staff, collaborators, or third parties (e.g., real estate portals), including electronically or digitally, in order to carry out real estate brokerage activities related to sales or rentals, to execute a service or contractually agreed operation, to monitor contractual relations and related risks, and to improve the services initiated by the contact.

The provision of such data is mandatory, otherwise we may be unable to fully or partially carry out the aforementioned mandate. Your data may also be collected from third parties. Some information may also need to be provided by you or others to comply with legal obligations (e.g., anti-money laundering laws).

Your identifying data may also be processed to comply with obligations required by national laws, regulations, EU legislation, or directives issued by legally authorized authorities or oversight bodies. This processing does not require your consent.

Processing may also be carried out based on the legitimate interest of the Controller in providing the best possible services related to the data subject, including for future interactions.

Information relating to properties, including photographs, will also be processed for promotional and commercial purposes necessary for fulfilling the assigned mandate. This may involve publication on websites, social media, and/or print materials, subject to your explicit consent.

Your email address may be used by the Controller to send you commercial communications about products and services similar to those you requested, pursuant to Article 130, paragraph 4 of Legislative Decree 196/2003. You may object to this processing at any time. Your objection will not affect the main purpose of carrying out real estate brokerage activities.

RECIPIENTS
Your data will be made accessible to our internal administrative staff and external collaborators, whose list is available at our office. Your data may also be communicated to our service providers, such as IT service companies, outsourcing firms, consultants and freelancers, insurance companies, debt recovery agencies, fraud control companies, institutions or patronages, and any companies or bodies designated by us as data processors. The full list is available at our office.

Additionally, your data may be shared with technicians for property inspections at the Land Registry or other institutions, entities, or registries.

TRANSFERS
Some of your Personal Data may be transferred to recipients located outside the European Economic Area. The Controller ensures that both digital and paper-based processing of your Personal Data by such recipients complies with applicable regulations. In such cases, transfers will be based on either an adequacy decision or the Standard Contractual Clauses approved by the European Commission. More information and copies of such agreements are available from the Controller. Upon request, you may obtain a copy and details on where the data have been made available, using the contact information in this notice.

DATA RETENTION
All personal data will be processed in accordance with the principles of lawfulness, fairness, relevance, and proportionality, using methods—also electronic and digital—strictly necessary for achieving the purposes outlined above.

In any case, personal data will be retained for no longer than strictly necessary to achieve the stated purposes or to meet legal requirements. Any personal data no longer necessary will be deleted or anonymized. The information systems used for managing collected data are configured, by default, to minimize data use.

YOUR RIGHTS
As a data subject, you have the rights set forth in Article 7 of the Privacy Code and Article 15 of the GDPR, specifically the rights to:

i. Obtain confirmation as to whether or not personal data concerning you exists, even if not yet recorded, and receive communication of such data in an intelligible form;

ii. Be informed about any ongoing processing of your personal data, including:
a) the source of the personal data;
b) the purposes and methods of processing;
c) the logic applied if the processing is carried out using electronic tools;
d) the identification details of the controller, processors, and designated representative (under Article 5, paragraph 2 of the Privacy Code and Article 3, paragraph 1 of the GDPR);
e) the entities or categories of entities to whom the personal data may be disclosed or who may become aware of it as designated representatives, data processors, or authorized persons;

iii. Obtain:
a) updates, rectification, or, when necessary, integration of the data;
b) deletion, anonymization, or blocking of data processed unlawfully, including those that are no longer required for the purposes for which they were collected or subsequently processed;
c) certification that the operations mentioned in (a) and (b) were communicated to third parties to whom the data were disclosed, unless this proves impossible or involves disproportionate effort;

iv. Object, in whole or in part:
a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the collection purpose;
b) to the processing of personal data for the purpose of sending advertising materials, direct sales, market research, or commercial communication, through automated means (e.g., emails, calls without operator) or traditional methods (e.g., phone, postal mail).

Where applicable, you also have the rights set out in Articles 16–21 of the GDPR (Right to rectification, right to erasure, right to restriction of processing, right to data portability, right to object), as well as the right to withdraw consent at any time (without affecting the lawfulness of processing based on consent before its withdrawal) and the right to lodge a complaint with the Data Protection Authority (www.garanteprivacy.it).

To exercise your rights, please contact our appointed Data Processor using the contact details provided in the header/footer of this document.