This privacy notice replaces all previous privacy notices published on this website and is effective from 16th November 2022 in accordance with General Data Protections Regulations (GDPR).
We also tell you about your privacy rights and how the data protection law protects you.
- WHO WE ARE AND IMPORTANT INFORMATION
Exclusive Property Finders is a trademark of crossbrook group s.r.o., a Limited Liability Company registered in Slovakia under registered no. 48106232. Registered office is Plynarenska 3A, 82109, Bratislava, Slovakia.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This privacy notice is issued by crossbrook group s.r.o. so when we mention “crossbrook group s.r.o.”, “Exclusive Property Finders”, or more generally “we”, “us” or “our” in this privacy notice, we are referring to crossbrook group s.r.o as the company responsible for processing your data.
For all data matters contact us at firstname.lastname@example.org.
crossbrook group s.r.o is the controller and responsible for this website.
- THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information from which a person can be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
We may collect, use, store and transfer different kinds of personal data about you which can be grouped together as follows:
- Identity data, including your title, first name and surname, gender and marital status, date and place of birth;
- Contact data, including email address and telephone numbers, your home, work and/or billing address;
- Technical data, including your login data, internet protocol addresses, browser type and version, social media handles, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site;
- Profile data, including previously used services, your interests, preferences, feedback and survey responses;
- Usage data, including information about how you use our website, services and operating systems;
- Marketing and Communications data, including your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union memberships, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
- HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you:
- Directly, providing us your identity and contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you enquire about services and/or fees, subscribe to our services or publications, request marketing to be sent to you;
- By means of automated technologies, where we may monitor your use of this website including how many times you visit, which pages you go to, traffic data, location data, weblogs and other communication data whether required for billing purposes or otherwise, the originating domain name of a user’s internet service provider, IP address, operating system, browser type, or by using cookies. This information helps us to build a profile of our users. Most of this data will be aggregated or statistical, which means that we will not be able to identify you individually;
- Through third parties or publicly available sources, where we may receive personal data about you from various third parties and public sources as set out below:
- Analytics providers such as Google based outside the EU;
- Advertising networks such as Google AdWords based outside the EU;
- Search information providers such as Google based outside the EU;
- Contact, financial and transaction data from providers of technical, payment and delivery services based inside the EU;
- Identity and contact data from publicly available sources such as Companies House and the Electoral Register based inside the EU;
- Identity and contact data from providers to enable us to comply with anti-money laundering regulations.
- HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. In particular, we will use your personal data in the following circumstances:
- Performance of contract, processing your data where it is necessary for the performance of a contract to which you are a party (i.e. to provide you with our professional services);
- Marketing and communications, including your preferences in receiving marketing communications from us and our third parties (these communications may include industry news and insights, newsletters, invitations to events or seminars, surveys, information on new services or other initiatives, etc.);
- Technical interests, studying how customers use our products/services, in order to better develop them, to define types of customers for our products and services, to keep our site updated and relevant, to grow up our business and to inform customers about our marketing strategies;
- Legitimate interests, meaning the interests of our business in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law);
- Comply with a legal or regulatory obligation, processing your personal data where it is necessarily required for compliance with a legal or regulatory obligation that we are subject to, including anti-money laundering regulations.
We will use your personal data also for providing you with information regarding certain marketing and advertising related matters.
We will send you information about services, events and news which we believe may be of your interest. You will receive marketing communications from us if you have:
- Requested information from us or have used our services;
- Completed and online web form and ticked the consent box;
- Attended an event of ours previously;
- Signed up to receive a newsletter;
- Are a professional intermediary/broker.
In order to stop receiving marketing emails from us:
- email us at email@example.com
- use the ‘Unsubscribe’ button on template email messages we may share with you from time to time.
Whereas you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a service experience.
Third party marketing
We will ask your express opt-in consent before sharing for marketing purposes your personal data with any third party.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- WHO WE SHARE YOUR PERSONAL DATA WITH
Providing services to international clients with global interests, we may have to share your personal data for the purposes set out in paragraph 4 above, with the following third parties set out below:
- Internal third parties such as group companies and associates;
- External third parties service companies (for example, IT software providers);
- Providers of IT and system administration services;
- Professional advisers acting as processors or intermediaries who may refer you to our services, including lawyers, bankers, auditors and insurers, who provide consultancy, banking, legal, insurance and accounting services;
- suppliers of professional services (like lawyers or surveyors) in connection with a property transaction;
- with the owner or representatives (like real estate agents) of properties that may or will be purchased or rented by you;
- third parties engaged for professional compliance, accountancy, legal services, administration, research as well as IT product and platform providers;
- with social media companies when you connect or communicate with us (on LinkedIn for example);
- Authorities and other bodies where we are subject to a legal or regulatory obligation;
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.
If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- WHERE WE SEND YOUR PERSONAL DATA
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, and whereas the transfer of your personal data is deemed necessary to fulfil our contract with you (including pre-contractual steps or a contract with another party in your interests), we may request your explicit consent to such specific transfer. You will have the right to withdraw this consent at any time.
- HOW WE PROTECT YOUR PERSONAL DATA
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Your personal data are stored within the EEA in a safe place. This means that they will be fully protected under the GDPR.
Employees, agents, contractors and other third parties who have a business related to us, will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- HOW LONG WE RETAIN YOUR PERSONAL DATA
We retain your personal data as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data and we may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice.
- THE LEGAL RIGHTS YOU HAVE OVER YOUR PERSONAL DATA
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request the cancellation of your personal data where it is no longer necessary to retain such data;
- The right to withdraw your consent at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable (i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics.
If you wish to exercise any of the rights set out above, please contact us.
No fees are required (with some exceptions). You will not have to pay a fee to access your personal data (or to exercise any of the other rights), however, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in such circumstances.
We may also need to request specific information from you to help us to confirm your personal identity and to ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you in order to collect further information in relation to your request and to speed up our response.
We aim to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We will reply electronically unless you ask us to send the information by post.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws, however you also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
- THIRD-PARTY LINKS
Our website may include links to third-party websites, plug-ins and applications, which fall outside of our control. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US
- QUERIES, REQUESTS OR CONCERNS
To exercise all relevant rights, queries or complaints in relation to any data protection matter between you and us, or to request whatsoever information to this privacy notice, please in the first instance contact us by email at firstname.lastname@example.org and we will investigate the matter and report back to you as soon as possible.
If this does not resolve your complaint to your satisfaction, you have the right to submit a complaint to your local data protection authority.
A cookie is a small file sent from a website and stored on your computer while you are browsing. It helps to remember information or to record your browsing activities. It can also be used to remember information that you previously entered into form fields such as names, addresses, passwords, and credit card numbers.
A cookie no gives us access to your computer or any information about you, other than the information you choose to share with us.
You can choose to decline cookies but this may prevent you from taking full advantage of our website. Most browsers automatically accept cookies, and you can easily modify your browser setting to decline cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
We may use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They may include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They may allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This may enable us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
These cookies help the third parties to:
- count the number of users who clicked on a website, allowing them to calculate the amounts of traffic and thereby establish statistics;
- recognise your device at any subsequent browsing of any other site or service on which these third parties also place these cookies and, if necessary, adapt these third party sites and services to your device.
Third party cookies on our website include:
- Google Analytics, a web analytics service provided by Google Inc., which uses its own cookies to gather information about how visitors use our site. This information is then used for the purpose of compiling statistical reports to enable us to measure and analyse the number of visits to the site and its pages, the average time spent on the site and the pages viewed.
- Social Network cookies, of whom social buttons are visible on our website in order to allow you to share content via the main social networks, including Facebook, Pinterest, Twitter and Instagram. Cookies are placed by these platforms on our site, and allow them to collect information about your browsing.
Except for essential cookies, all cookies will expire after 30 days.