This privacy policy (“Privacy Policy”) describes the purposes and methods of processing personal data (“Personal Data” or “Data”) by MAV S.r.l., through the “Valdoma” brand (“MAV,” “We,” or “Company”), for users who access and visit the Valdoma website at https://www.valdoma.it/ (“Site”).
This policy applies solely to the Valdoma webpage and not to other sites visited by the user through external links, in accordance with the provisions of Regulation (EU) 2016/679 (“Regulation” or “GDPR”), Directive 2002/58/EC (“e-privacy Directive”), and Legislative Decree 196/03 (“Privacy Code”).
1. Who is the Data Controller?
The Data Controller is MAV S.r.l., located at Via Lequile nr. 168, 73100 Lecce (LE), Italy.
2. What Personal Data do we collect?
Through our website, we collect and process Personal Data in several ways:
- Personal Data voluntarily provided by the user: We collect personal information about the user when actively provided, such as when the user contacts us for information about our services or submits a resume to participate in our hiring process.
- Personal Data related to creating a personal profile: For users who wish to create a personal profile, the Company may process the following types of data: personal details (name, surname, date of birth), contact details (email address, phone number, residential or mailing address).
- Personal Data collected through use of the Site: We automatically collect some personal information during the user's navigation and use of the Site. In the case of cookies, where tracking is not necessary for the functioning of the Site, Valdoma will request prior consent for user tracking[1].
2.1. What types of Personal Data do we process?
- Information about the user: If the user requests information about services offered, we may use Personal Data to contact them and answer some questions. In such cases, we may process personal and contact data (e.g., Name, Surname, email address, and phone number provided voluntarily by the user).
- Location data: We may approximate the user’s location based on their IP address.
- Data for managing the Site: We may receive information related to user tracking via cookies installed on our website. If the information is not instrumental to the website’s functioning, we will request prior consent from the user to allow data collection.
2.2. Automatically collected information
When the user interacts with our website through a smartphone, computer, or mobile device, we may automatically collect information about access and usage patterns, as well as details about the device used. We use this information to improve the user experience and monitor and update our website. Typically, we collect this information through various tracking technologies, including cookies, pixels, web beacons, embedded scripts, location identification technologies, and similar technologies (collectively, “tracking technologies”).
The user can accept or refuse these technologies by modifying the privacy settings in their browser profile settings. The information we collect automatically may be combined with other personal information we collect directly from users.
The information we may automatically collect through our Site includes:
- Personal data related to interactions with the Site (e.g., whether the user clicks on an image or a link);
- Information about the devices used to access and interact with us (e.g., this allows us to know if a computer, tablet, or smartphone is used, screen resolution, operating system, Wi-Fi connection, browser type, and IP address, server log files);
- Behavioral data: information derived from the combination of the device ID and system events that can be used to identify trends and behavior patterns to improve our service.
3. What Personal Data do we not collect?
We do not collect or process the following special categories of Personal Data related to the user:
- racial or ethnic origin;
- political opinions;
- religious or philosophical beliefs;
- health or medical conditions;
- criminal background;
- union membership;
- genetic or biometric data;
- sexual life or orientation.
We ask our users not to send or upload, nor disclose any Personal Data from the above-mentioned categories through the Site or directly to our contacts.
If the user wishes to send us their resume for an application to a specific open position or via spontaneous submission, we kindly ask to provide only essential information and, if part of a protected category, to only indicate membership without any additional sensitive data. Any excess information will be promptly deleted by the Company.
4. Why do we process the user’s Personal Data?
The Personal Data of users are processed through our website for:
a. To allow the user to assess their property
To allow the user to assess their property, by entering necessary information required for the service provided by the Company.
For the assessment, we may request personal information related to the user’s residence or mailing address.
Legal basis for processing: to allow the user to benefit from the services offered by the Company.
b. To provide the user with more information about our services
To allow users of the Site to obtain more information about our services and activities, we may collect some personal information such as name, surname, and contact details of the individual.
Legal basis for processing: to allow the user to benefit from services requested by the Company for the fulfillment of preliminary contractual obligations.
c. Property Evaluation Service
We may process the user’s data for the Property Evaluation service, to assist the user in buying or selling properties.
Legal basis: Compliance with contractual obligations or pre-contractual measures.
d. Appointment Booking or ValdomaGest service
We may process the user’s data for the ValdomaGest service, a system developed by the Company to offer post-sale services and manage appointments.
Legal basis: Compliance with contractual obligations or pre-contractual measures.
e. Real Estate Brokerage Service
We may process the user’s data for the real estate brokerage service.
Legal basis: Compliance with contractual obligations or pre-contractual measures.
f. Work with us
To allow the user to submit a spontaneous application or in relation to open positions. In such cases, we may also use Companies or HR professionals, who will act as independent data controllers.
Legal basis for processing: execution of pre-contractual negotiations.
g. Ensure the technical operation of the Site
We collect and use the user’s Personal Data to administrate the operation of our website and ensure it functions properly. We may use the personal information provided by the user to respond to complaints or issues regarding the website’s functionality.
Legal basis for processing: our legitimate interests to ensure the proper technical functioning of the Site.
h. Inform the user about changes to the terms and conditions of use of the Site and provide this Privacy Policy
To send information regarding changes to the terms and conditions of use of the Site and provide this Privacy Policy.
Legal basis for processing: our legitimate interest to inform the user in advance about such changes.
i. Comply with legal obligations
To comply with our legal obligations, orders from governmental authorities, which may include orders from authorities outside the user's country of residence, when we reasonably believe we are obligated to such communications and when the disclosure of Personal Data is necessary to comply with such legal obligations or governmental orders.
Legal basis for processing: compliance with our legal obligations.
j. Prevent fraud and abuse
We will use information on fraudulent or criminal activity related to the use of our services for fraud detection and prevention.
Legal basis for processing: our legitimate interests to protect our organization from fraudulent activity.
k. Legal protection of our interests
To protect our business operations, safeguard our rights, ensure the protection of Personal Data through the Site, and enable us to pursue legal remedies or limit potential damages.
Legal basis for processing: our legitimate interests to protect our business organization under the law.
l. Marketing activities
Valdoma may collect the user’s Personal Data to offer services related to the Company's services, if the user has provided prior consent.
We may also ask the user if they wish to be contacted by our commercial partners to receive offers related to specific products or services.
Legal basis for processing: the user's prior consent to receive marketing communications.
Users always have the option to refuse to receive marketing communications they have already consented to by unsubscribing from newsletters or contacting us via email. Revocation of consent does not affect the lawfulness of processing based on consent before the revocation.
If the user has already shown interest in some of Valdoma's services, we may contact them by email or WhatsApp to inform them about similar products and keep them updated on the latest news.
Legal basis for processing: our legitimate interest to promote the Company’s activities and services directly to our customers.
The user has the right to object to this specific direct marketing processing at any time by sending an email or unsubscribing through the link at the bottom of our newsletters.
m. Profiling
We may collect the user's Personal Data to better understand their tastes and preferences and tailor our offers accordingly. This is profiling activity that we may perform together with our Partners.
Legal basis for processing: the user’s prior consent to engage in profiling activities.
5. To whom are the user’s Personal Data communicated?
In addition to authorized personnel, Personal Data may be communicated to our commercial partners (e.g., companies involved in renovation activities, real estate, mortgages, and loans), companies that support us in providing our services (e.g., marketing and communication companies), professionals assisting us in technical and legal matters (e.g., law firms, IT companies, administrative, commercial, and accounting consultants), and public authorities and judicial authorities to prevent fraud or illicit acts.
It is possible to request a detailed list of the recipients of the data by sending an email to the address provided in this Privacy Policy.
6. What are the user’s rights regarding the processing of Personal Data and how can they be exercised?
Users have the right to request confirmation of the existence or non-existence of their Personal Data and to know the content, origin, accuracy, or request integration, updating, or rectification (Articles 15 and 16 GDPR) of their Data.
- Right of access: the right to access the personal information concerning the user along with some related information;
- Right to data portability: the right to receive personal information in a commonly used format and to have it transferred to another data controller;
- Right to rectification: the right to obtain rectification of Personal Data without undue delay if they are inaccurate or incomplete;
Under Articles 17, 18, and 21 of the Regulation, users have the right to request the deletion, restriction of processing, anonymization, or blocking of Data processed in violation of the law, and to object for legitimate reasons to their processing, including:
- Right to deletion: the right to obtain the deletion of their Personal Data without undue delay under specific circumstances;
- Right to restriction of processing: the right to obtain a restriction of the processing of their Data for a specific period in certain situations;
- Right to object: the right to object to the processing of Personal Data for legitimate reasons and to object to the processing of Personal Data for direct marketing purposes.
As the data subject, the user also has the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal. Rights can be exercised by contacting the Data Controller at the following addresses:
- Email: privacy@valdoma.it
- By mail, at Valdoma, Via Otranto 42, 73024 Maglie (LE), Italy
7. How long do we retain the user’s Personal Data?
Personal Data will be retained only for the time necessary to achieve the purposes mentioned above and to ensure the proper functioning of the Site. Data collected for commercial communications will be retained until the user requests deletion from the service. In case of legal disputes, where it is necessary to retain Data for a longer period, Valdoma may retain only the necessary information to protect its rights or interests.
What transfers may we make?
We may disclose some of the user's Data to our providers for activities related to the services offered and for the functioning of the Site. For some treatments mentioned earlier, we may use providers outside the European Union. In such cases, we ensure compliance with applicable laws on Data transfer by entering into agreements that ensure an adequate level of protection or adopting standard contractual clauses as provided by the European Commission.
8. How do we protect the user's Personal Data?
Information security is very important to us, and we have implemented safeguards to maintain the integrity and security of the information we collect and process through the Site. However, no security system is impenetrable, and we cannot guarantee 100% security of our systems. In case any information under our control is compromised due to a security breach, we will take reasonable measures to investigate the situation and, if necessary, notify individuals whose information may have been compromised and take other actions in accordance with applicable laws and regulations.
9. Applicable law
This Privacy Policy is governed and interpreted in accordance with applicable provisions and any other mandatory regulations in the European Union.
10. Complaints to the Data Protection Authority
The user has the right to file a complaint with the Data Protection Authority, contactable at the website https://www.garanteprivacy.it/.