provided under Regulation (EU) 2016/679 of the European Parliament and of the Council on the Protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, “GDPR”) and under Act No. 18/2018 Coll. on Personal Data Protection, and the amendment of certain Acts (“Personal Data Protection Act “).
Controller:
CORWIN SK a. s.
Registered office: Námestie Mateja Korvína 1, 811 07 Bratislava
ID No.: 45 500 126
(hereinafter referred to as „CORWIN SK a. s.“ or „Controller“)
ensures the sale of real estate located in the Blauberg project in Dúbravka www.blau-berg.sk. Since you have shown interest in purchasing property in the Blauberg project in Dúbravka, or you have shown an interest in being informed about news and current information regarding offers related to our Projects and other activities carried out by CORWIN SK a. s., CORWIN SK a. s. therefore processes your personal data as a data subject to the following extent: a) name and surname, b) email address, and c) telephone number (the data mentioned in points a) to c) together referred to as “Personal Data”).
I. Identification of the Controller and contact details
The Controller, on whose behalf Personal Data is processed, is CORWIN SK a. s., with its registered office at: Námestie Mateja Korvína 1, 811 07 Bratislava – city district Staré Mesto, ID No. 45 500 126, registered in the Commercial Register of the Bratislava III Municipal Court, section: Sa, file No. 5015/B. Contact details are as follows: phone: +421 2 5441 6009, 5441 6007, fax: +421 2 5441 6011, e-mail: corwin@corwin.sk.
II. Definition of the purposes of processing and determination of the legal basis
CORWIN SK a. s. processes Personal Data to the extent in which you as a data subject provided it for the following purposes:
- direct marketing; informing the data subjects as clients or potential clients about news concerning individual Projects carried out by CORWIN SK a. s. and to contact data subjects with additional marketing offers from CORWIN SK a. s. through direct mail, newsletter, tailored offers, or other appropriate forms. The legal basis for processing Personal Data is consent if the client or potential client provides their name, surname and email address and agrees to the processing of their Personal Data for the purpose of being sent business and marketing information by CORWIN SK a. s.;
- the purpose of record-keeping and supporting communication during the sale of properties; The legal basis for processing Personal Data is the legitimate interest of CORWIN SK a. s. (Article 6 (1) (f) of the GDPR Regulation);
- the purpose of preliminary communication in the event of a potential contract between the data subject and the Controller for the purchase of property; The processing of Personal Data is necessary for the performance of a contract to which the data subject is a party and/or to take steps at the request of the data subjects prior to entering into a contract, including agreeing on contractual terms, drafting, communicating, and subsequently concluding the relevant contracts; The legal basis for processing Personal Data necessary for the performance of a contract is (Article 6 (1) (f) of the GDPR Regulation);
- statistical purposes; to combine the Personal Data with data of other clients to create reports to improve the services provided by CORWIN SK a. s., while adhering to technical and organisational measures to ensure compliance with the principle of data minimisation. The legal basis for the processing of Personal Data is the further processing of Personal Data (Article 5 (1) (b) in connection with Article 89 (1) of GDPR Regulation);
- the purpose of maintaining records of requests from data subjects and their processing by CORWIN SK a. s.; The legal basis for processing Personal Data is the legitimate interest of CORWIN SK a. s. (Article 6 (1) (f) of the GDPR Regulation;
- the purpose of proving, claiming, and defending legal claims; The legal basis for processing Personal Data is the legitimate interest of CORWIN SK a. s. (Article 6 (1) (f) of the GDPR Regulation);
- the purpose of fulfilling obligations of CORWIN SK a. s. according to relevant legal regulations, such as tax obligations or obligations concerning consumer protection in the internal market. The legal basis for processing Personal Data is the performance of legal obligations (Article 6 (1) (c) of the GDPR Regulation).
III. Categories of data subjects
CORWIN SK a. s. processes Personal Data for the purposes specified in Article II of interested parties as data subjects who have expressed their interest to CORWIN SK a. s. about project Blauberg located in Dúbravka.
IV. Legitimate interests pursued by CORWIN SK a. s.
The legitimate interest of CORWIN SK a. s. consists of such interests that are essential for the effective execution of its business activities, which include among other things, real estate operations, particularly in the form of record-keeping and facilitating communication in the sale of real estate, which forms one of the business activities of CORWIN SK a. s.. In this case, the data subject provides their personal data voluntarily, as they request information/services from the Controller in which they are interested. The Controller, as part of its business activities, does not undertake any additional activities to obtain the personal data of the data subject; instead, the data subject themselves contacts the Controller to obtain additional information regarding the purchase of real estate from the Controller and its current offers. The Controller does not actively seek anything; only responds to the request of the data subject and subsequently, if necessary, develops communication regarding the specific request of the data subject, which is essential for the execution of real estate activities. Without processing the aforementioned personal data (voluntarily provided by the data subject) for the purpose of record-keeping and supporting communication in the sale of real estate, the Controller would not be able to receive and record requests from data subjects and respond to them. This would significantly limit its ability to sell real estate, which is not in its interest and not aligned with one of the frameworks for the performance of its business activities, specifically real estate operations. Within the scope of CORWIN SK a. s. legitimate interest in the proper conduct of its business activities, the proving, applying and defending of legal claims by the company, which may arise from potential legal relationships (e.g., sales) between the Controller and the data subject, are considered legitimate interests. In these cases, there may be a need to use the data and information provided by the data subject to CORWIN SK a. s. specifically within the pre-contractual communication and negotiation of specific terms of the contractual relationship. The legal basis for processing personal data for the purposes specified in Article II is therefore the legitimate interest of CORWIN SK a. s., in accordance with the relevant article of the GDPR Regulation and the applicable provisions of the Data Protection Act, provided that in this case, such legitimate interest of CORWIN SK a. s. does not override the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data.
CORWIN SK a. s. also has a legitimate interest in informing clients and potential clients about beneficial offers related to the Blauberg project located in Dúbravka, or other projects from the portfolio of CORWIN SK a. s.. The legal basis for processing personal data for the purposes specified in Article II is therefore the legitimate interest of CORWIN SK a. s., as provided by the relevant article of the GDPR Regulation and the applicable provisions of the Data Protection Act, provided that in this case, such legitimate interest of CORWIN SK a. s. does not outweigh the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data. If you are not interested in receiving news and current information about offers related to the Blauberg project in Dúbravka or other projects from the portfolio of CORWIN SK a. s., you can enforce your right to object to the processing of personal data by CORWIN SK a. s. at any time, free of charge. You can do so by:
- Sending a letter to the address of CORWIN SK a. s.’s registered office,
- clicking on the appropriate link provided in each newsletter,
- Sending an email to CORWIN SK a .s.,
- contacting CORWIN SK a. s. via telephonen.
If you object to the processing of your personal data by CORWIN SK a. s., your personal data will no longer be processed. Upon receiving at least one of the expressions of will, as outlined in points a) to d) of this article, you will no longer receive any updates or information from CORWIN SK a. s.
The right of the data subject to object to the processing of personal data
The data subject has the right to object, at any time and for reasons relating to their particular situation, to the processing of personal data concerning them, which is carried out based on the legal basis of the legitimate interest of the controller – CORWIN SK a. s.. CORWIN SK a. s., as the controller, may not further process the personal data unless it demonstrates legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the proving, applying, or defending of legal claims.
The person concerned also has the right to process personal data for direct marketing purposes that concern him. If the data subject objects to processing for direct marketing purposes, personal data is already processed for such purposes.
V. Instruction on voluntary or mandatory provision of consent to processing
If the data subject expressed interest to be contacted by CORWIN SK a. s. for the purpose of receiving offers regarding property purchases in the Blauberg project located in Dúbravka and for related communication potentially leading to the conclusion of a property purchase agreement, the data subject is required to provide CORWIN SK a. s., as the controller, with their Personal Data (at least their name, surname, email address, and telephone number) for the purpose of further communication. Otherwise, CORWIN SK a. s. does not have the opportunity to contact the data subject, and the data subject will not receive necessary information regarding the purchase of real estate in the Blauberg project located in Dúbravka. Whether the data subject decides to provide their Personal Data for the purpose of being contacted and communicating regarding the purchase of real estate in the Blauberg project is their voluntary decision, and any refusal to provide this data should not have any significant consequences for them. In the event that the data subject expressed interest to receive updates and marketing information from CORWIN SK a. s., the data subject is required to provide CORWIN SK a. s., as the controller, at least their name, surname, email address, and telephone number, and to give consent for the processing of their Personal Data for the purposes of direct marketing. Otherwise, it is not possible to subscribe to newsletters and marketing communications sent by CORWIN SK a. s. Providing consent for the processing of personal data for direct marketing purposes is a legal requirement.
VI. Recipients or categories of recipients of Personal Data
It is assumed that Personal Data processed on behalf of CORWIN SK a. s. for the purposes outlined in Article II will also be provided to the following recipients:
- Intermediaries who have been formally authorized in writing by the Controller to process Personal Data. This primarily includes providers of IT services and other individuals whose services we use during the execution of our activities. Intermediaries are selected to ensure compliance with all data protection requirements.
- CC THETA, s. r. o, registered office at Mýtna 48, 811 07 Bratislava – Staré Mesto, ID No.: 50 286 421, registered in the Commercial Register of the District Court Bratislava III, Section: Sa, Entry No. 110911/B, as the owner of the real estate on which the properties are located,
- Public authorities, especially courts, authorities conducting criminal proceedings,
- Other directly affected individuals (hereinafter referred as “recipients“).
VII. Retention period of Personal Data
Personal data will be processed until the purpose for which the Personal Data were obtained ceases to exist, but no later than when the legal basis for processing Personal Data under the GDPR Regulation and the Data Protection Act expires. Personal data processed for the purpose of record-keeping and supporting communication during the sale of real estate will be processed for the duration of communication regarding the interest of a client or potential client in a property within the residential building in Dúbravka at the Blauberg project. Additionally, they will be processed during negotiations for the conclusion of contracts, as well as any related communication. In the event of concluding a relevant contract (reservation agreement, agreement on future purchase contract, purchase contract, etc.), these data will be retained in connection with the execution of the transaction for at least the period required by applicable legal regulations for the enforcement and/or defence of rights arising from the respective contractual relationship. Personal data processed for the purpose of proving, applying and defending legal claims of data subjects will be processed for a minimum period as required by relevant legal regulations, or they will be processed for the duration of the rights and claims of the Controller, particularly for the statutory limitation periods set by legal regulations, typically up to 10 years after the termination of the contractual relationship (if such exists), or until the resolution of disputes and other proceedings related to the claims of the Controller or the defence of the rights of the Controller. Personal data processed for the purpose of fulfilling obligations of CORWIN SK a. s. will be processed for the duration required by applicable legal regulations governing accounting, archiving, consumer protection, and other obligations that necessitate the processing of Personal Data. Personal data processed for statistical purposes will be processed for the duration of the above-mentioned retention periods for other purposes.
VIII. Information on automated individual decision-making
CORWIN SK a. s. does not use any automated individual decision-making or profiling when processing Personal Data.
IX. Information on other rights of clients and potential clients
Subject to compliance with the terms and conditions set by the legal regulations concerning Personal Data protection, you, as a data subject, have the following rights:
Right to request access from the Controller to Personal Data concerning you
The data subject has the right to obtain from CORWIN SK a. s. confirmation as to whether or not Personal Data concerning them are being processed, and, where that is the case, access to the Personal Data and the following information: the purposes of the processing; the categories of Personal Data concerned; the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organisations; where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the Controller rectification or erasure of Personal Data or restriction of processing of Personal Data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; where the Personal Data are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of GDPR and, in these cases, at least meaningful information about the procedure used, as well as the meaning and expected consequences of such processing for the data subject. CORWIN SK a.s. shall provide a copy of the Personal Data being processed. For any additional copies requested by the data subject, the Controller may seek adequate compensation corresponding to the administrative costs of processing the application.
Right to rectification
The data subject shall have the right to have CORWIN SK a. s. rectify any inaccuracies in their Personal Data without undue delay. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
Right to erasure (right to be forgotten)
The data subject shall have the right to have CORWIN SK a. s. erase their Personal Data without undue delay and CORWIN SK a. s. shall erase this Personal Data without undue delay if any of the following reasons are met:
- the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws their consent on which the processing is based according to Article 6(1)(a) or Article 9(2)(a) of GDPR, and where there is no other legal ground for the processing;
- the data subject objects to the processing pursuant to Article 21(1) of GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of GDPR;
- the Personal Data have been unlawfully processed;
- the Personal Data have to be erased for compliance with a legal obligation in Union or Member State law to which the Controller is subject;
- the Personal Data have been collected in relation to the offer of information society services referred to in Article 8(1) of GDPR.
Where CORWIN SK a. s. has made the Personal Data public and is obliged to erase the Personal Data, it shall take reasonable steps, including technical measures, taking into account available technology and the cost of implementation, to inform controllers which are processing the Personal Data that the data subject has requested the erasure by such controllers of any links to, or copies or replication of, those Personal Data.
The right to erasure shall not apply to the extent that processing is necessary:
- to exercise the right of freedom of expression and information;
- to comply with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercising of official authority vested in the controller;
- for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) as well as Article 9(3) of GDPR;
- for archival purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of GDPR in so far as it is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- to establish, exercise, or defend legal claims.
Right to restrict processing
The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
- the accuracy of the Personal Data is contested by the data subject, for a period enabling the controller to verify the accuracy of the Personal Data;
- the processing is unlawful and the data subject opposes the erasure of the Personal Data and requests the restriction of their use instead;
- the controller no longer needs the Personal Data for the purposes of the processing, but they are required by the data subject for the establishment, exercising or defence of legal claims;
- the data subject has objected to processing pursuant to Article 21(1) of GDPR pending verification of whether the legitimate grounds of the controller override those of the data subject.
Where processing has been restricted under the provisions above, such Personal Data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercising or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State. A data subject who has obtained restriction of processing pursuant to the foregoing shall be informed by CORWIN SK a. s. before the restriction of processing is lifted.
Right to data portability
The data subject shall have the right to receive the Personal Data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the Personal Data have been provided, where: a) the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) of GDPR or on a contract pursuant to Article 6(1)(b) of GDPR; and b) the processing is carried out by automated means. In exercising their right to data portability, the data subject shall have the right to have the Personal Data transmitted directly from one controller to another, where technically feasible. The exercising of the right shall be without prejudice to Article 17 of GDPR. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercising of official authority vested in the controller. The right to portability of personal data shall not adversely affect the rights of others.
Right to object to processing including the right to object to profiling (if any)
The data subject has the right to object at any time, for reasons relating to their particular situation, to the processing of personal data based on Article 6(1)(e) or (f) of the GDPR Regulation, including profiling based on those provisions. The controller may not further process personal data unless it proves necessary legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the proving, asserting or defending of legal claims. If personal data are processed for the purposes of direct marketing, the data subject shall have the right to object at any time to processing of personal data concerning data subject for such marketing, which includes profiling to the extent that it is related to such direct marketing. If the data subject objects to processing for direct marketing purposes, personal data must no longer be processed for such purposes.
Right to lodge a complaint with the supervisory authority
The supervisory authority to which the data subject may address their complaint in justified cases is the Office for Personal Data Protection of the Slovak Republic, with its registered office at Hraničná 12, 820 07 Bratislava 27.
Right to withdraw consent to processing (if the personal data is processed based on consent
In the event that the legal basis for the processing of personal data is the consent of the data subject, The data subject may at any time withdraw their consent without affecting the lawfulness of processing based on consent before its withdrawal.
The right to withdraw the consent at any time, even before the expiry of the period for which the consent was granted, may be exercised by the data subject, in particular in the following ways:
- by post sent to the registered address of CORWIN SK a. s.,
- at any time and free of charge by clicking on the relevant link in each delivered newsletter;
- via email to CORWIN SK a. s.;
- over the phone.
CORWIN SK a. s. shall be obliged to adopt adequate measures and provide the data subject with information under the §19 and §20 of the Personal Data Protection Act and notices under the §21 – §28 and §41 of the Personal Data Protection Act, concerning the processing of their Personal Data in a concise, transparent, understandable and easily accessible form. CORWIN SK a. s. shall cooperate with the data subject in exercising their rights under §21 to §28 of the Personal Data Protection Act.
CORWIN SK a. s. shall be obliged to provide the data subject with information on measures taken on the basis of their application pursuant to §21 to §28 of the Personal Data Protection Act within one month of receiving the data subject’s request. CORWIN SK a. s. may extend the period in justified cases depending on the complexity, comprehensiveness and number of applications for another two months, even repeatedly. CORWIN SK a. s. shall, however, be obliged to inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the extension. If CORWIN SK a. s. does not take action on the request of the data subject, the controller shall inform the data subject without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint under §100 of the Personal Data Protection Act to the Office for Personal Data Protection of the Slovak Republic.
