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Privacy Policy

Last Actualization, June 2018.

The security of your data is important to us, as it has always been.

Please note that we also observe the EU Data Protection Regulations and we confirm that your data is safe with BCR.

This website www.silvermountain-resort.ro (”the website”) is operated by BANCA COMERCIALĂ ROMÂNĂ S.A. (”BCR”). BCR may be mentioned in this Policy as “we”, “us” or “our”.

The security of your data is important to us, as it has always been.

The BCR website may include links to other websites which are managed by entities/legal persons not related to BCR’s activity and for which BCR is not responsible. We may also provide links to other websites operated by BCR affiliates that apply separate privacy policies. If you access these websites via our website, you should review the privacy policies of these websites in order to understand how they collect, use and communicate your information

BCR and the confidentiality of data

BCR processes personal data as a Personal Data Controller in accordance with the provisions of the General Data Protection Regulation no. 679/2016. According to the activity carried out, BCR processes your personal data in your capacity as a data subject under the following conditions:

  • - for the processing arising out of your capacity as a website visitor, please see the section on using the cookies, available here
  • - if you are a third party, without any direct relationship with BCR (no contracts concluded and undertaken by BCR) and depending on the activity carried out, BCR processes your personal data:
    • (i) to conclude a real estate transaction (including, but not limited to, sale, rental) in connection with one of the buildings owned by BCR or in connection with the conclusion of a real estate transaction covering a building for which BCR has an interest in acquiring the right of ownership or of any of its attributes (e.g. obtaining the right to use). In such a situation, the exchange of information and documents, including the promotion of the real estate offer, can also be achieved via telephone and smart phone and tablet applications;
    • (ii) to manage the relationship with public authorities or other public service providers (bailiffs, notary publics, etc.);
    • (iii) to ensure the security within the premises of BCR and of its subsidiaries - if you visit any of the headquarters/offices and/or buildings owned by BCR, your image being processed for such purpose;

In this context, the data subjects are as follows:

  • - individuals interested in concluding a real estate transaction in connection with one of the buildings owned by BCR or in connection with the conclusion of a real estate transaction covering a building for which BCR has an interest in acquiring the right of ownership or of any of its attributes (e.g. obtaining the right to use);
  • - visitors of the websites managed by Banca Comercială Română;
  • - family members of interested persons and/or clients;
  • - legal representatives or natural persons involved in the activity of corporate clients;
  • - beneficial owners of corporate clients;
  • - associates or direct or indirect shareholders of corporate clients;
  • - legal representatives of corporate counterparties;
  • - natural persons involved in the activity of corporate counterparties;
  • - authorized persons;
  • - third party guarantors;
  • - external evaluators;
  • - brokers, natural persons;
  • - journalists taking part in the events organized by BCR;
  • - visitors of headquarters/offices and/or buildings owned by BCR.

The information we process

BCR processes the personal data directly provided by you, as well as data generated on the basis thereof, such as the identification data contained by the copy of the identity card for the purpose of concluding the real estate transaction or the checks necessary to meet the legal requirements or legitimate interests of BCR and other personal information derived from documents underlying real estate transactions, trading data, profiling data, information resulting from non-conformities reported by any person. We may collect personal data relating to you when you use our website as well as in the conduct of the existing contractual relationships and the provision of services you are involved in by BCR.

The refusal to provide personal data may lead to the impossibility to provide the services and/or to achieve the other processing purposes by BCR.

How we use and communicate your information:

BCR processes your personal data as follows:

A: In order to meet legal obligations, for the following purposes:

  • a) to prevent fraud and to guarantee the banking secrecy by analysing/verifying the authenticity of the identity document provided by you, for the performance and improvement of the banking services provided to you, by entering in the BCR IT record-keeping system the data in the identity card, according to the relevant legal requirements;
  • b) to comply with the applicable legal rules in order to meet the know your client requirements, to prevent money laundering activities and combat the financing of terrorism, to manage conflicts of interest;
  • c) for administrative-financial management;
  • d) to keep/store (prior to archiving) and to archive according to the legal provisions the contractual documentation (including the provision of operations related to these activities) and/or other documents containing personal data;
  • e) for internal audit;
  • f) to ensure the security within the premises of BCR and of its branches;
  • g) to manage the relationship with public authorities or other public service providers (bailiffs, notary publics, etc.);
  • h) to implement technical measures which ensure the security of personal data (including by making backup copies).

In the achievement of these goals, BCR will also rely, to the extent necessary, on its legitimate interest in carrying out activities specific to its objects.

B. In order to conclude and sign contracts, for the following purposes:

  • a) the performance of any legal relationships arising out of the contracts concluded between BCR and you or the company you represent;
  • b) the adequate monitoring of all obligations undertaken by the contractual partners/buyers/sellers/lessors/lessees of BCR (natural persons) and/or clients towards any of the entities within the BCR Group.

C. In order to meet the legitimate interests of BCR in the context of its objects, for the following purposes:

  • a) simple marketing, PR and communication purposes;
  • b) the management of the complaints you file in relation to the services, for profiling in order to present the most appropriate offers;
  • c) to establish, exercise or defend certain rights of BCR and/or its subsidiaries in court, as well as to establish evidence in this respect;
  • d) to design, develop, test and use existing or new IT systems and services (including database storage in the country or abroad);
  • e) to conclude a real estate transaction (including, but not limited to, sale, rental) in connection with one of the buildings owned by BCR or in connection with the conclusion of a real estate transaction covering a building for which BCR has an interest in acquiring the right of ownership or of any of its attributes (e.g. obtaining the right to use).

Consent:

There are certain processing purposes for which it is necessary, according to the law, for BCR to obtain your consent.

BCR will obtain such consent by various means, for example when you sign an information note/a brochure made available by BCR through a representative/at the time of a visit to any of the Bank's headquarters/offices and/or buildings owned by BCR, either by email or via the BCR (online) website. The consent thus provided may be withdrawn at any time and BCR will take into account your preferences.

The purpose for which BCR is most likely to obtain your consent is to assess your eligibility for the purpose of concluding a real estate transaction and submitting offers, either standard or customized, according to your options.

Personal data recipients

For the purposes of processing, BCR may disclose certain categories of personal data to the following categories of recipients: the data subject and/or his/her legal representatives, BCR representatives, BCR Group entities, judicial authorities or other public authorities of any kind.

Personal data transfer

At present, in order to achieve the above-mentioned purposes, BCR may transfer certain personal data categories outside Romania, in countries within the EU/EEA: the Czech Republic.

Data processing duration

In order to achieve the above mentioned processing purposes, BCR will process personal data during the performance of the services (at most 2 years) and afterwards in order to comply with the applicable legal obligations, including, but not limited to, the provisions regarding the archiving obligation. Following the meeting of the legal archiving deadlines, BCR may order the anonymization of the data, thus depriving it of its personal character, and continue the processing of anonymous data for statistical purposes.

The use of cookies

This website uses cookies. More details on these modules and on how they are used are available here.

Data security

BCR attaches great importance to your personal data and understands to ensure proper security during processing. In this respect, BCR implements technical and organizational measures for protection against unauthorized or illegal processing and against loss, destruction or accidental damage.

Rights of the data subjects

Under the conditions set out in the legislation on the processing of personal data, in your capacity as data subjects you are entitled to the following rights:

  • - the right to information, i.e. the right to receive details of the processing activities carried out by BCR, as described in this document;
  • - the right of access to data, i.e. the right to obtain confirmation from BCR regarding the processing of personal data, as well as details regarding the processing activities;
  • - the right of rectification, i.e. the right to have inaccurate data rectified by BCR, as well as the completion of incomplete data;
  • - the right to data erasure (“the right to be forgotten”), provided the conditions laid down by law are met - however, following the request for data erasure, BCR may anonymize such data (thus depriving it of its personal character) and continue processing for statistical purposes under these conditions;
  • - the right to restrict processing, provided the conditions laid down by law are met;
  • - the right to data portability, i.e. (i) the right to receive personal data in a structured, commonly used, machine readable format, and (ii) the right to have this data transmitted by BCR to another data controller, provided the conditions laid down by law are met;
  • - the right to object - in respect of the processing activities carried out for direct marketing purposes, including profiling, the right to oppose may be exercised at any time by submitting a request as indicated below;
  • - the right not to be subject to individual automated decision making, i.e. the right not to be the subject of a decision made solely on the basis of automated processing activities;
  • - the right to file a complaint with the National Authority for the Supervision of the Processing of Personal Data and/or the competent courts of law, inasmuch as deemed necessary.

For more details on the processing activities carried out by BCR, as well as on the rights you are entitled to in this context, please send a request (on paper/in electronic form by email) to: DPO@bcr.ro.

You may also contact the BCR Data Protection Officer at the email address: dpo@bcr.ro (after his/her appointment by BCR) at any time. Should you have suggestions regarding this Privacy Policy, we encourage you to submit these suggestions: DPO@bcr.ro.

Please consent to our use of your personal data (name, telephone, email) for the further transmission of the information and offers related to the buildings promoted by BCR.

In the absence of your consent, we will no longer send you information and offers related to the properties promoted by the Bank.

Please find here more information on the Privacy Policy and the processing of personal data.

Thank you for your trust!

BCR Real Estate Asset Management Team