1. GENERAL PROVISIONS
Trevi Elite S.R.L. respects the rights and freedoms of all persons, including those located in the European Union, and therefore takes all necessary and sufficient legal, organizational and technical measures to ensure the confidentiality of personal data, as well as the security during its processing in accordance with general principles and rules for personal data processing and under the applicable law.
1.3. We have the right to periodically amend this Policy, specifying the date of latest revision at the beginning of the document. If You use our Website after the revised version is published, it means that you agree with it. Please, check this page from time to time.
1.4. If you have any questions or if you think that not all information of interest is presented in this Policy, please, contact us: email@example.com.
2. WHO ARE WE?
2.1. Trevi Elite S.R.L. is an Italian Company registered at the Chamber of Commerce of Rome (number of registration role agents subjects in mediation 9683), as well as a member of the Italian Federation of Real Estate Agents FIMAA with professional policy № 44331710, directed by bilingual (Russian-Italian) professionals with many years of experience and specific expertise in the field of luxury real estate. We specialize in providing services in the luxury real estate sector since 2005, offering customers selected high-status real estate properties in the most prestigious regions of Italy. In addition to making all necessary arrangements for the purchase of the selected property, we can provide the would-be owner with a full range of services to make his ownership of property a more enjoyable experience. This includes administrative and utility services support, making arrangements for possible alterations and repairs with the employment of local Italian contractors, commercial use of the property, legal advice, and other services.
2.2. Our Website is a collection of web pages hosted on the Internet, united by a single theme, design and address space of the trevi-elite.com domain. Our home page providing a Visitor with the access to all other Website pages is available at trevi-elite.com.
Website Visitor is a person who has downloaded any page of our Website trevi-elite.com onto his device (computer, laptop, mobile), as well as the page of any of its sub-domains.
3. WHAT INFORMATION DO WE COLLECT?
3.1. We will not be able to find an appropriate property that could be interesting for you, as well as provide any other services without your comments and some personal data. According to services you request, we may ask you to enter or inform:
- name and surname;
- contacts (telephone, email);
- passport details;
- professional, business and financial information – if the object owner requires financial guarantees;
- details of your request (for example, the purpose of the purchase, dates of planned views, etc.).
3.2. In addition to the information that you provide on a voluntary basis, we also collect data:
- on domain names and IP addresses of Visitors;
- usage statistics (for example, the site’s URL from which the transition was made; the number of visited pages, their names, duration of page view; date and time of visiting our Website, the type of browser and operating system used). These data are used to promote our services and improve its quality. We can combine these data with personal and other collected information;
- publicly available information about you – which you have disclosed or which has an open access.
3.3. Trevi Elite S.R.L. does not verify the accuracy of information provided by the Website Visitor, and is not able to evaluate the legal capacity of the Website Visitor.
4. WHAT IS THE PURPOSE OF PERSONAL DATA PROCESSING?
4.1. Personal data of Website Visitors are processed to:
- search for a property/project in the country of your interest; to get acquainted with our Partner – a local real estate agency, private agent, developer, lawyer, accountant, any other professional consultant, whose services you are interested in; provide consulting services;
- improve the content and usability of our Website (trevi-elite.com);
- notify of new functions, special events and services;
- improve the quality of customer service and estimate the work of our employees. Please note that we can record and analyze your conversation with our employee (written, by phone). If you do not agree, please, let us know (firstname.lastname@example.org) or address claims to your personal manager.
5. WHAT RIGHTS DO YOU HAVE?
5.1. We guarantee you:
- the right of access – that is, you have the right to know what information about you is stored and how it is processed;
- the right to rectification – that is, you have the right to change or add your personal data that we process;
- the right to erasure (‘right to be forgotten’) – that is, you have the right to erasure your personal data without giving any specific reason;
- the right to restriction of processing – that is, you have the right to restrict us in the processing of your personal data, subject to the circumstances provided for in Article 18 of Regulation (EU) No. 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)”).
- the right to transfer data – that is, you have the right to request a list of your personal data in a structural, common or machine-readable format, and ask us to transfer your personal data to a third party, if it will be technically possible to do. In this case, we are not responsible for the following actions with your personal data performed by a third party.
- the right to object – that is, you have the right to be against the use of your personal data (for example, for the purpose of our internal assessment of the quality of services provided).
- the right to require notification of all persons who were previously provided with incorrect or incomplete personal data about all changes or additions made;
- the right to duly appeal against any unlawful actions or inactions during personal data processing.
5.2. Persons, who provided Trevi Elite S.R.L. via the Website with information about another subject of personal data, without having the consent of this subject whose personal data have been transferred, are liable in accordance with applicable law.
6. WHOM CAN WE TRANSFER YOUR PERSONAL DATA TO AND WHAT ACTIONS CAN WE PERFORM?
6.1. As per parameters specified in your request, we can transfer your contact information (name, surname, phone number, email), as well as details of your request to our Partners – local real estate agencies, private agents, lawyers, accountants, and any other professional consultants, whose services you are interested in. You can get more detailed information about such third parties upon your request.
6.2. You agree to the cross-border transmission of your personal data to the territory of foreign countries, including those that do not provide adequate protection of rights for personal data subjects (if you are interested in acquiring any real estate on the territory of such countries and informed us about it in your request).
6.3. We never ask the Website Visitor for information about his racial, national identity, political views, religious and philosophical beliefs, state of health, or intimate life. We specify only the information that is necessary for the selection of properties and services, which you are interested in.
6.4. You agree that during Personal data processing, we may perform the following actions: collection; recording; structuring; accumulation; storage; clarification (update, change); retrieval; using; deleting; destruction; blocking; transmission (distribution, provision, access), depersonalization.
6.5. In case of your participation in our events, we can disclose the relevant personal data to persons who organize such events. This can be the organizers of the event (including websites of third-party companies), speakers, participants in discussions, our foreign partners – representatives of real estate agencies, etc.
7. HOW DO WE PROCESS YOUR PERSONAL DATA?
In order to ensure the security of your personal data, we apply necessary legal, organizational and technical measures aimed at protecting Personal data from unauthorized or accidental access, destruction, change, blocking, copying, provision, disclosure, as well as from other illegal actions in relation to Visitors Personal data. However, the transmission of information via the Internet or telephone is not completely secure. Although we take all reasonable measures to protect your personal data, we cannot guarantee the complete security of your information transmitted this way, and any transfer is carried out at your own risk.
8. DIRECT MARKETING
8.1. In order to ensure your constant awareness of interesting offers, changes in the foreign real estate market, events held by our company and our partners, and the range of provided services, we can send you certain marketing materials – newsletters, bulletins, presentations, and articles.
8.2. Anytime you can unsubscribe from receiving our newsletters by clicking “unsubscribe”, which you can find at the end of any marketing message, or by contacting your personal manager, either by writing us an email: email@example.com.
9. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
9.1. We process your personal data until we receive the relevant request for data deletion or upon completion of services, which you are interested in. If you need to change your data or delete it from our database, contact us by email and state your requirements: firstname.lastname@example.org (marked by “Withdrawal of consent to process (change) personal data”) or send it by post according to the following address: Via di Porta Pinciana, 34, 00187, Rome, Italy (when sending documents by post, we advise you to duplicate the message by email). Your personal data will be deleted within 30 days from the date we receive such a request.
9.2. If you or your representative withdraw the Consent to process personal data, we have the right to continue processing personal data without your consent only if there are grounds specified in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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) and in other applicable legal acts.
10. OTHER PROVISIONS
10.1. About children: we do not purposefully collect information about persons under 18 years old. If you are under 18, please, do not provide us with your own details. However, during the discussion of Your request, we can clarify information about the parental status, children age and any other information that you would like to tell us and/or which is necessary to find suitable properties or services (for example, to analyze an infrastructure – the presence of kindergartens, educational institutions; to organize a viewing tour, etc.).
10.2.1. A Cookie file is a small piece of data that a Website requests from a browser used on your computer or mobile device. Cookies reflect your actions or preferences. Cookies are stored locally on Your computer or mobile device. You can delete saved Cookies at your own wish.
10.2.2. Data on the Visitor’s actions on the website, as well as the date and time of the session are processed by us in order to improve Website operation (including the use of metric programs Yandex.Metrica, Google Analytics), determine the preferences of Visitors, provide targeted information on our products and services.
10.3. Our Website, newsletters and bulletins may sometime contain links to and from the websites of other parties. This Policy on the procedure for handling confidential information does not apply to personal data that you provide through such websites, whereas Trevi Elite S.R.L. does not control and is not responsible for such third party websites.
If you follow the link to any other sites, please keep in mind that such sites contain their own notifications on the procedure for handling confidential information, which describe their own way of collecting and processing your personal information when visiting those sites.
We respect your rights and freedoms, in particular those related to the processing of your personal data.
For more detailed information on personal data processing, please, contact us by email: email@example.com