PRIVACY STATEMENT PURSUANT TO ART. 13 G.D.P.R.



In compliance with the provisions contained in art. 13 of the New General Data Protection Regulation (GDPR 2016/679), the Client (hereinafter “the party concerned”) is informed that:

1. Data-holder and other authorized persons
The data-holder of the personal data processing is 18 Montenapoleone S.r.l. (the Company), with its registered office in Milan, in via Monte Napoleone 18, where Ms. Antonietta Mastrototaro is the acting legal representative. The Client wishing to exercise any of their rights may contact her by email at 18@18montenapoleone.it

2. Data processing and the legal basis
Any personal data freely provided by the Client to the Company in connection with the activities carried out to fulfill our contractual requirements to you, will be processed legally and correctly, and in full compliance with the provisions contained in the Regulation regarding:
- compliance with legal obligations to which we are subject, including regulations and European legislation as well as any directives issued by any supervisory authorities
- fulfillment of our contractual obligations, in order to establish and manage our relationships with clients, such as the collecting of preliminary information up to the conclusion of the contract.
- communication of personal data to potential buyers/sellers/users, either by traditional or electronic means, for the promotion of real estate proposals or connected to retail commercial companies, as well as to any services offered by the Company (such as market analysis and appraisals).
- Compliance with current legislation governing anti-money laundering regulations(Leg. Decree Law 231/07 and any subsequent modifications

By providing the personal data described above, 18 Montenapoleone, as data-holder , can fulfill its contractual obligations. Should the Client refuse to supply the personal data requested, then the Company will be unable to perform the foreseen contractual obligations.
The Company will collect the consent to processing of personal data either by electronic or paper means

3. How we process and retain your personal data
The processed personal information (which is common information permitting identification) is updated, complete, pertinent and used only for the above-mentioned purposes of processing.
This information will be processed, collected, recorded and stored for pre-determined, specific and legitimate purposes with all due security and confidentiality. This information will be processed electronically and in paper form.
This personal information will be processed by 18 Montenapoleone, as data-holder of the processing, as well as by authorized employees and third party providers acting on our behalf.
This information may be disclosed to public authorities requiring communication/declarations regarding the contractual relationship, as well as to authorized inspection agencies who carry out checks and controls on the regularity of performance.
The information , subject in this privacy statement, may be shared with professionals and/or third party providers in the fulfillment of obligations on our behalf. This information will not be shared beyond specified limits, unless consent in writing is provided by the party concerned.
18 Montenapoleone, as data-holder of the processing, may share the personal information with a country outside the EEA or to an international organisation, for the sole purpose of fulfilling its contractual obligations, in accordance with art.49, comma 1, letter “b” of the Regulation 679/2016. It should be noted that our external backup is carried out by an Italian company, and we require them to adopt adequate technical and organisational measures to maintain the data in compliance with security requirements, by means of servers situated within the EEA or in a country outside the EEA which is in accordance with art 45, comma 1 of the G.D.P.R.
There is no automated decision-making processing procedure.
We have implemented generally accepted standards of technology and operational security to protect information from the risk of loss, misuse, alteration or destruction.

4. Data retention period
Any personal data, subject to this privacy statement, will be retained:
- for a period of 5 years following the conclusion of the contractual relationship, for processes of a legal nature
- until consent is withdrawn for processes of a consensual nature.

5. Rights of the party concerned
The party concerned has the right to:
- ask the data-holder to confirm that their personal data has been retained, including data still to be recorded, and to receive clear and plain communication of any request. The party concerned has the right to verify the data and any updates or additions, amendments or cancellations made to the information. They may object to specific processing activities and restrict how the information is processed, retained or shared, including any processing by electronic means.
- Oppose, in whole or in part, the processing of the information.
- Withdraw consent at any time, without undermining the lawfulness of the processing performed prior to the withdrawal, as well as the right to make a complaint to the data protection authority.