PRIVACY POLICY – PERSONAL DATA PROCESSING

This privacy policy is provided in relation to the processing of personal data collected in the context of information requests, service offers, and/or assignment of tasks to MARTINA RE S.p.A.

1. Dxata Controller

For the purposes of this policy, the Data Controller is MARTINA RE S.p.A., with its registered office at Viale Bianca Maria, 25, 20122 Milan, registered in the Business Register of Milan Monza-Brianza Lodi under number 09888700961, REA-MI 2119915 (hereinafter referred to as the “Controller“).

The Controller is a company specializing in real estate consulting and management.

1. Collected Data

The personal data collected by the Controller may include: name, surname, residence and/or domicile address, tax code and/or VAT number, landline and/or mobile phone number, email address, social media accounts (hereinafter, the “Data“).

1. Purpose and legal basis of data processing

The data will be processed for the following purposes:

• a – to fulfil your requests for information;
• b – to execute the assigned mandate and comply with the related legal obligations;
• c – to send, via traditional mail, telephone, SMS, email, instant messaging (including social media), commercial, promotional, and advertising communications related to the services and products offered by the Controller and/or companies directly or indirectly controlled, controlling, under common control, affiliated, or invested in by the Controller;
• d – to send, via traditional mail, telephone, SMS, email, instant messaging (including social media), commercial, promotional, and advertising communications related to services and products provided by MARTINA RE S.p.A..

The legal basis for data processing is the legitimate interest of the Controller in responding to the requests of data subjects to provide its services and relevant information. This interest has been balanced with the one of the data subjects and is compatible with their reasonable expectations, as it is reasonable to assume that they wish to receive responses to their inquiries.

The legal basis for processing under point b) is the execution of a contract resulting from the assigned mandate, as well as compliance with legal obligations.

The legal basis for processing under points 3) is your consent.

Consent may be validly given and revoked for one or more of the processing purposes mentioned above. The given consent can be withdrawn at any time using methods similar to those provided for its provision, without affecting the lawfulness of the processing based on consent before its revocation.

Processing of personal data for purposes a) and b) is mandatory and necessary for fulfilling your requests for information and/or executing the assigned mandate and complying with the related legal obligations. Any partial or total refusal to provide Data for these purposes will make it impossible for the Controller to proceed with the related activities.

Processing of personal data for purposes c) and d) is optional. Any partial or total refusal to process Data for these purposes will prevent the Controller from carrying out the related activities.

1. Processing Methods

The Controller and its designated entities process the Data using paper-based, electronic or automated tools, stored on servers and/or archives and/or sites within the European Union, in accordance with procedures strictly related to the stated purposes, ensuring data security and confidentiality.

1. Data Communication (Recipients)

The Data will be processed by the Controller and its designated entities and may be communicated to third parties only when necessary for carrying out the activities described in Article 3. Third-party recipients of the Data may process it either as autonomous controllers or as data processors duly appointed by the Controller. The full list of Data Processors is available at the Controller’s registered office and can be requested by contacting the details indicated in Article 8.

1. Data Disclosure

The Data will not be disclosed. However, Data may be shared with entities designated by the Controller for performing the activities described in Article 3.

1. Data Retention Period

Data is processed only for the time strictly necessary to achieve the purposes for which it was collected. In particular for purpose a) in Article 3, Data will be retained for the entire duration of the assigned mandate and for the statutory limitation period prescribed by applicable regulations from the date of collection; for purpose b) in Article 3, Data will be retained for the entire duration of the assigned mandate and for the statutory limitation period prescribed by applicable regulations; for purposes c) and d) in Article 3, Data will be retained for the entire duration of the assigned mandate and for the statutory limitation period prescribed by applicable regulations.

1. Data Subject Rights and Contact Details

You have the right at any time to: (I) obtain confirmation as to whether or not personal data concerning you exists; (II) know the purposes of the processing, the processing methods, the recipients of such Data, and the retention period; (III) obtain rectification or erasure of your Data and, where applicable, restriction of processing; (IV) object to processing; (V) where applicable, receive your Data in a structured, commonly used, and machine-readable format and transmit such data to another Data Controller without interference from the Controller; (VI) lodge a complaint with the Data Protection Authority; (VII) select the methods by which you wish to be contacted for the purposes specified in points c) and d) of Article 3, specifically indicating whether you wish to be contacted via traditional methods (postal mail, operator-assisted phone calls), automated methods (email, SMS, phone calls without an operator), or both categories.

The above rights may be exercised at any time by submitting a simple request to the Controller via:

• e-mail, at the addresses: info@martinare.com e sales.martinare.com

• Postal mail, by writing to the Controller at the following address: Viale Bianca Maria, 25, Milano 20122, addressed to the Legal & Corporate Affairs Department.