Data Protection

PERSONAL DATA PROCESSING NOTICE

This document comprises information that the controller has to be provide to a person whose personal data are being processed, in accordance with the Law on Personal Data Protection (“Official Gazette of RS”, no. 87/2018) and General Data Protection Regulation, Regulation (EU) 2016/67 (“GDPR”), if applicable

IDENTITY AND CONTACT DETAILS OF THE CONTROLLER

Your personal data are collected and processed by Beograd na vodi d.o.o., Beograd, Karadjordjeva 48, corporate id no 21033391 (“Belgrade Waterfront”), as further detailed in this Personal Data Processing Notice. This means that in accordance with the law Belgrade Waterfront is accountable for processing of your personal data.

For any questions about processing of your personal data and to exercise your rights you can contact us by email [email protected] or write to our office address:

Beograd na vodi d.o.o., Beograd – Savski venac,
Karadjordjeva 48,
11000 Beograd.

In certain cases, Belgrade Waterfront has a role of a joint controller. An example is joint liability with a social network operator. On social networks data are mostly processed by such a social network, and in that regards our influence is limited. Detailed information on data processing by operators of social network platforms and options to object can be found in their respective privacy policies.

CATHEGORIES OF DATA, GROUNDS FOR PROCESSING AND RETENTION

When you express interest in purchasing a property and get in touch with us regarding signing a contract, primarily an agreement related to sale and purchase of a property offered by Belgrade Waterfront or from the offer of our related parties, for example

• when on our website you fill in a registration form or request information on available properties,
• when you visit our sales centers or promotional stands,
• when you send us an email or give us a phone call,
• when you participate in our promotional activities, or
• when you sign with us an agreement related to sale and purchase of a property or another agreement,

we collect from you the data necessary for the purpose of particular type of the agreement, in accordance with by the law prescribed principles of personal data processing. Paying attention especially to what data is minimally necessary in relation to the purpose for which they are processed.   This means that we collect from you the data necessary for the preparation, entering into and performance of a contract.

Before contract signing, we process data such as your first name, last name and contact data (email and phone number), to enable communication with you in relation to your interest and understanding of your needs, and presenting you as best as possible our offer, terms of sale and other information we consider may be of relevance for your decision on purchasing a property. Legal basis for processing set out in article 12, paragraph 1, point 2) of the Law on Personal Data Protection, article 6 (1)(b) of the GDPR – taking steps at the request of the data subject prior to entering into a contract, and article 12, paragraph 1, point 6) of the Law on Personal Data Processing, article 6 (1)(f) of the GDPR – pursuing legitimate interests. Providing data is voluntary. Data are processed only if you express interest in purchasing a property.

When you sign with us a reservation agreement regarding a property, beside your name and contact data, you need to provide us with your address. And, when you sign with us a property sale and purchase agreement you need to provide us with the data that are by the law prescribed as mandatory in this regard, including among other your personal id. number and copies of your identification documents.

Legal basis for processing is preparation for contract signing and performance of contractual obligations, as well as compliance with a legal obligation to which the controller is subject.

QUESTIONNAIRES, SURVEYS AND THE LIKE – Legal basis for processing data that you optionally and voluntarily share with us is your consent that can be revoked at any time. Revocation produces effect for the future and does not make unlawful the processing that took place before revocation of consent. If there is no other legal basis for processing, after you revoke consent, we will stop processing your data.

COMMERCIAL MESSAGES – If you subscribed to commercial messages (such as “newsletter”) consent is legal basis to contact you in that way and to inform you on the latest in our and our related parties offer, current and future projects, promotions, and to send you event invitations. At any time, you can unsubscribe by clicking on an “unsubscribe” link available in each such message. If there is no other legal basis for processing, after you revoke consent, we will stop processing your data.

LEGITIMATE INTEREST – In accordance with the law and if your interests do not prevail, we process your data for the legitimate interest pursued by us or by a third party, such as protection of our systems, discovery and prevention of attacks to our web site, prevention of fraud and malicious use, resolving problems, response to your questions, direct marketing (outside of situations when consent for receipt of commercial messages is required), video surveillance, and the like. In this context, we have legitimate interest to process data from publicly available records.

You have the right to object to this type of processing at any time. To exercise this right please send us an email or write to the address stated at the beginning of this document. If there is no other legal basis for processing, after you object, we will stop processing your data, unless there are compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

RETENTION

Generally, we keep your data for the period necessary to achieve purpose of the processing, or for the period required by the applicable laws. If you signed an agreement with us, this means that we will keep your data for the duration of contractual rights and obligations, and thereafter for the period set out in applicable laws.

We retain your data even after the termination of our contractual relationship if we need your data for the establishment, exercise, or defense of legal claims or for compliance with a legal obligation. To the extent possible, we will limit processing of your data to such limited purposes after the termination of contractual relationship.   Data are kept on our server in the Republic of Serbia.

WHO ELSE HAS ACCESS TO THE DATA

In our operations we use various service providers who, in accordance with our instructions, have access to your data as so-called processors.

Our related parties with whom we share IT systems, who provide us with or to whom we provide business and operations support and with whom we have signed an agreement have access to your data:

• Eagle Hills Properties LLC, Abu Dhabi, UAE, PO Box 34888
• BW Kula d.o.o., Karadjordjeva 48, Beograd
• BW Galerija d.o.o., Karadjordjeva 48, Beograd

We can reveal your data to the competent authorities and institutions upon their order or when we believe that is necessary for compliance with legal obligations, or to protect our interests.

We can disclose your data to third parties in case of corporate reorganisation, transfer, or other disposal of any part of busines or assets of Belgrade Waterfront (including mortgage foreclosure, bankruptcy or similar proceeding) or in other case of compliance with legal obligations.

TRANSFER OUTSIDE OF REPULIC OF SERBIA – In compliance with by the law prescribed rules, data are transferred and processed out of Serbia. If data are transferred to recipients outside of the countries members to the Convention of the Council of Europe for the Protection of Individuals with regard to Automatic Processing of Personal Data, transfer is done in compliance with by the law prescribed measures (e.g. by way of standard contract clauses).

COOKIES

Read about our Cookie Policy here.

SECURITY MEASURES

We use security measures that we continually optimize according to technical and legal developments in order to make sure that your data is protected from accidental or intentional manipulation, loss, destruction or access by unauthorized third parties.

However, please note that such protection measures do not cover information you choose to share in public e.g. through social networks or messaging applications.

YOUR RIGHTS

Upon request, you have the right to receive information about your personal data processed by us free of charge. You have the right of rectification and deletion of your personal data, a right to limitation of processing and a right to data transferability. You have the right to object to processing done by us for our legitimate interests. You have the right not to be subject to a decision based solely on automated means including profiling, if the decision produces legal effects concerning you or significantly affects you. If our processing of your personal data takes place on the basis of your consent, you have the right at any time to revoke this consent. This revocation does not make unlawful the processing that took place before you revoked consent.

In addition, you may complain to the Commissioner for Information of Public Importance and Personal Data Protection, address: 15, Bulevar kralja Aleksandra str, Belgrade 11120, Serbia о[email protected] and you may file lawsuit to the competent court.

For any questions about processing of your personal data and to exercise your rights, you can contact us by email or by mail to the address at the beginning of this document.