Privacy Policy

This Privacy Policy contains the details of the data processing activities on personal data and related information concerning the activities carried out by Adriatic Advisors group (hereinafter: “Adriatic Advisors”) and its members as data controller, including its activities available on the joint website at https://www.adriatic-advisors.com/ (hereinafter: “Website”).

On its website, Adriatic Advisors allows interested parties to contact it on the Website about its real estate investment activities and sign in for its newsletters.

Adriatic Advisors is entitled to amend this Privacy Policy at any time, which amendment shall be effective upon publication on the Website and shall apply to subsequent data processing.

The “GDPR” abbreviation referred to in the text refers to the Regulation (EU) 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.

name: Adriatic Appraisal Kft.

seat: Stollár Béla utca 22, 1055 Budapest, Hungary

company registry number: 01-09-273740

representative: Adam Zsolt Ragab

e-mail address: adam.ragab@adriatic-advisors.com

phone number: +36 20 4356677

The Adriatic Advisors group includes the following companies to whom as data controllers Adriatic Appraisal transfers the data:

name: Adriatic Appraisal d.o.o.

seat: Maglajska 1, 71000 Sarajevo, Bosnia and Herzegovina / BiH

company registry number: 202484670001

representative: Jasmina Maglajlija

e-mail address: jasmina.maglajlija@adriatic-advisors.com

phone number: +387 63 883302

name: Adriatic Advisors d.o.o.

seat: Sremska 4, 21000 Novi Sad, Serbia

company registry number: 21302341

representative: Darko Bogetić

e-mail address: darko.bogetic@adriatic-advisors.com

phone number: +381 60 670 9670

name: Adriatic Appraisal Montenegro d.o.o.

seat: Bul. Džordža Vašingtona 79, 81000 Podgorica, Montenegro / Crna Gora

company registry number: 5 – 0760169

representative: Milica Mirković

e-mail address: milica.mirkovic@adriatic-advisors.com

phone number: +382 67 440439

name: Adriatic Appraisal d.o.o.

seat: Ćira Carića 3/2, 20000 Dubrovnik, Croatia / Hrvatska

company registry number: 4761600

representative: Adam Zsolt Ragab

e-mail address: adam.ragab@adriatic-advisors.com

phone number: +382 67 800003

name: Adriatic Appraisal SEE d.o.o.

seat: Bul. Džordža Vašingtona 79, 81000 Podgorica, Montenegro / Crna Gora

company registry number: 5-0953035

representative: Adam Zsolt Ragab

e-mail address: adam.ragab@adriatic-advisors.com

phone number: +382 67 800004

name: Adriatic Appraisal nepremičninsko svetovanje d.o.o.

seat: Trg Republike 3, 1000 Ljubljana, Slovenia

company registry number: 7987144

representative: Adam Zsolt Ragab

e-mail address: adam.ragab@adriatic-advisors.com

phone number: +36 20 4356677

name: Adriatic Appraisal GmbH

seat: Bockkellerstraße 8/11, 1190 Wien, Österreich / Austria

company registry number: ATU77636523

representative: Alexander Schlader

e-mail address: alexander.schlader@adriatic-advisors.com

phone number: +436 9911398496

name: Adriatic Appraisal S.R.L.

seat: Bulevardul 21 Decembrie 1989, Nr. 16, Etaj 1, Jud. Cluj, Mun. Cluj-Napoca, Romania

company registry number: J12/3123/2018

representative: Attila Orosz

e-mail address: attila.orosz@adriatic-advisors.com

phone number: +40 741 012827

In accordance with the requirements of good faith and fairness and the applicable laws, Adriatic Advisors acts in cooperation with the user of the Service as the data subject (hereinafter: “Data Subject”) (hereinafter Adriatic Advisors and Data Subject jointly: “Parties”) during data processing. Adriatic Advisors only processes data defined by law or provided by the Data Subject, for the purposes defined below. Adriatic Advisors retains the data of the Data Subject only as long as it is absolutely necessary to achieve the purpose, is suitable for achieving the purpose, or as long as it is made possible or mandatory by an agreement or legal regulation.

The provision and transfer of personal data is voluntary. The Data Subject can give his consent to data processing electronically by checking the “checkbox” on the Website.

The provision of personal data and data processing made by Adriatic Advisors shall serve the following purposes:

The Data Subject is solely responsible for having an appropriate legal basis for the personal data provided by the Data Subject relating to other persons. Adriatic Advisors excludes all liability in case of failure to do so.

In case of using the “Contact” menu item of the Website or the specified contact channels, the Data Subject may enter his personal data.

By freely providing personal data, the Data Subject allows his questions and requests to reach Adriatic Advisors, and to receive answers and information through the contact details provided by him. Adriatic Advisors is entitled to process the personal data provided for the purpose of contact until the Data Subject’s consent is withdrawn or for the period prescribed by law. The withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal. If further processing of the contact data is not justified, Adriatic Advisors shall erase it immediately.

Purpose of data processing: Informing and contacting the Data Subject

Legal basis of data processing: Free consent of the Data Subject (Article 6 (1) point a) of GDPR)

Scope of processed data: Full name, e-mail address, phone number of the Data Subject

Duration of data processing: until the Data Subject’s request for erasure or until erasure by Adriatic Advisors, if further processing of the data is not justified, and for the time period set forth by legislation on consumer complaint.

By freely providing personal data, the Data Subject allows Adriatic Advisors to notify the Data Subject of current Services, discounts, promotions, and other news through the contact details provided by the Data Subject. Adriatic Advisors is entitled to process personal data provided for the purpose of sending newsletters and commercial promotions until the consent of the Data Subject is withdrawn. The withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal. The Data Subject can unsubscribe from Adriatic Advisors’s newsletter at any time without giving any reason.

Purpose of data processing: sending newsletters and marketing materials, personalizing advertising, redeeming coupons

Legal basis of data processing: freely given consent of the Data Subject (Article 6 (1) point a) of GDPR)

Scope of processed data: name, phone number, e-mail address of the Data Subject

Duration of data processing: until the withdrawal of the consent or request for erasure of the Data Subject, or until erasure by Adriatic Advisors, if further processing of the data is not justified

The Data Subject, by giving his voluntary consent, allows the Adriatic Advisors group members to receive his data so that they can effectively inform him/her about current Services, discounts, promotions and other news. The Data Subject has the right to withdraw his/her consent at any time. Such withdrawal shall not affect the lawfulness of the processing carried out on the basis of the consent prior to the withdrawal.

The transfer of data may also be based on the legitimate interest of Adriatic Advisors.

Purpose of data processing: transfer data in order to provide effective and targeted information to the Data Subject

Legal basis of data processing: freely given consent of the Data Subject (Article 6 (1) point a) of GDPR)

Scope of processed data: name, phone number, e-mail address of the Data Subject

Duration of data processing: until the withdrawal of the consent or request for erasure of the Data Subject, or until erasure by Adriatic Advisors, if further processing of the data is not justified

Adriatic Advisors is entitled to use – for statistical purposes – such information which does not relate to an identified or identifiable natural person, as well as personal data that has been anonymized in a way that the Data Subject cannot or can no longer be identified. Such data is used and aggregated by Adriatic Advisors for the preparation of statistics and for the development of the Website and the Service.

Adriatic Advisors uses the following data processors:

name: Cloudways Ltd.

seat: Junction Business Centre, 1st Floor, Sqaq Lourdes, St. Julians, STJ 3334, Malta

website: www.cloudways.com

data processing task: hosting service, data storage

name: The Rocket Science Group, LLC d/b/a MailChimp

seat: 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA

website: www.mailchimp.com

contact: personaldatarequests@mailchimp.com

DPA: https://mailchimp.com/en/legal/data-processing-addendum/

data processing task: storage of the newsletter database and operation of the newsletter system

Adequate and appropriate safeguards to ensure the security of data transfers: the application of the standard data protection clauses adopted by the European Commission (Article 46(2)(c) GDPR) and adequacy decision (Article 45(3) GDPR).

Adriatic Advisors makes the data of the Data Subject available to third parties due to an official court or police request, copyright, property or other infringement or a reasonable suspicion of such infringement, or in other cases stipulated by law or official obligation. Adriatic Advisors cannot be held responsible for such data transfer and the resulting consequences.

Several of the companies in the Adriatic Advisors group are based outside the European Union. Data are transferred to these companies according to the standard contractual clauses adopted by the Commission.

In addition, Adriatic Advisors does not transfer personal data to third parties. Personal data shall not be transferred to countries that do not have the adequacy decision of the European Commission, or that do not otherwise ensure adequate protection of personal data. Adriatic Advisors does not carry out automated decision-making or profiling in connection with data processing.

The Data Subject has the right to request information free of charge about the processed personal data, the purpose, legal basis, duration of the data processing, the name, address (seat) of the person entitled to data controlling and data processing, and the activities related to the data processing, as well as who and how they can access the data, as well as about the rights of the Data Subject and legal remedies related to data processing.

The Data Subject may request Adriatic Advisors regarding personal data:

The data does not need to be erased if the data processing is necessary for the purposes as follows:

The Data Subject shall have the right to obtain from Adriatic

• access to data: shall have the right to obtain from Adriatic Advisors confirmation as to whether or not personal data concerning him are being processed and access to the personal data and the essential information regarding the processing.
• rectification of data: the Data Subject has the right to have Adriatic Advisors rectify or amend inaccurate personal data concerning him without undue delay upon request,
• erasure of data: the Data Subject has the right to request that Adriatic Advisors erase the personal data concerning the Data Subject without undue delay, and Adriatic Advisors is obliged to erase the personal data concerning the Data Subject without undue delay.

The data does not need to be erased if the data processing is necessary for the purposes as follows:

• exercising the right of freedom of expression and information,
• compliance with a legal obligation under EU or member state law applicable to Adriatic Advisors,
• for the establishment. exercise or defence of legal claims,
• for the archiving purpose in the public interest, scientific or historical research purposes or statistical purposes, if erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing;
• for reasons of public interest in the area of public health;

 

• restriction of data processing: the Data Subject shall have the right to obtain from Adriatic Advisors restriction of processing if – among other things – the accuracy of the personal data is contested by the Data Subject, or Adriatic Advisors no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defence of legal claims;
• can object to the processing of personal data: the Data Subject has the right to object to the processing of his personal data at any time if the data processing is based on public interest or the data processing is necessary for the purposes of the legitimate interests pursued by Adriatic Advisors or a third party, and
• may request the release of his personal data in a machine-readable format: the Data Subject is entitled to receive the personal data provided by him in a structured, commonly used, machine-readable format, and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.

Adriatic Advisors shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed unless this proves impossible or involves disproportionate effort. The data controller shall inform the Data Subject about those recipients if the Data Subject requests it.

If the data processing is based on consent, the Data Subject is entitled to withdraw his consent at any time.

Adriatic Advisors shall provide information on action taken on a request the Data Subject without undue delay and in any event within 1 (one) month of receipt of the request. That period may be extended by 2 (two) further months where necessary, taking into account the complexity and number of the requests. Adriatic Advisors shall inform the Data Subject of any such extension within 1 (one) month of receipt of the request, together with the reasons for the delay. Where the Data Subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the Data Subject. If Adriatic Advisors does not take action on the request of the Data Subject, Adriatic Advisors shall inform the Data Subject without delay and at the latest within 1 (one) month of receipt of the request of the reasons for not taking action.

The Data Subject can file a complaint regarding data processing at National Authority for Data Protection and Freedom of Information (seat: 1055 Budapest, Falk Miksa utca 9-11., Hungary; postal address: 1363 Budapest, Pf.: 9.; phone number: +36 (1) 391-1400; fax: +36 (1) 391-1410; e-mail: ugyfelszolgalat@naih.hu; website: https://www.naih.hu), furthermore, in case of violation of his rights, the Data Subject has the right to an effective judicial remedy.

 

• only persons with express authorization and who are bound by confidentiality can access personal data, the data can be seen by employees in the job positions as follows: project manager, newsletter editor, marketing assistant, system operator, system developer;
• access to personal data on computers/servers only with a username and password, in the case of data processed in electronic form, the use of a central authorization management system;
• computer system containing personal data equipped with virus protection;
• password-protected administrative interface,
• password protection on computing devices,
• password change at specified intervals,
• Adriatic Advisors ensures that the installed systems can be restored in the event of a malfunction, as well as that a report is prepared on such errors.