Domus Realty Privacy Policy
The purpose of this Data Protection policy is to explain how Domus Realty Sagl, as the data controller (hereinafter “Domus Realty” or “Owner“) and in accordance with EU Regulation 2016/679 (hereinafter “Regulation” or “GDPR”) and the Swiss Federal Data Protection Act (hereinafter “LPD”) and related ordinance intends to collect and process personal data (hereinafter “Data“) relating to new and existing users (hereinafter “User(s)”), websites, social media, mailings, apps and offline activities, including those relating to the assignment of the mediation assignment or other services, as well as interviews for personnel selection, of the Owner.
The following information is provided so that the User can give a specific, unequivocal, informed, free and informed consent to the processing of Data that may also be done by computer and / or telematics.
This policy was published on 24 May 2018, updated on 28 August 2023, and is effective for new and existing Users of Domus Realty Sagl’s websites, social networks, mailings, apps and offline activities, including those related to the assignment of the mediation assignment as well as interviews for personnel selection, on 25 May 2018 updated on 28 August 2023.
Data Controller
Domus Realty Sagl, data controller, is a real estate trustee that provides real estate brokerage, sales, rental and administration services (hereinafter “Services”). The company is registered in Switzerland, with registration number CHE-337.664.673 and registered office in Paradiso (TI), via San Salvatore 7. To promote our Services, we use offline and online tools such as websites, for example, www.domusrealty.com (“Web Sites”), social media, for example facebook, linkedin, instagram, youtube (“Social”), mailings and apps.
Types of data processed
In order to provide you with our Services, we need to collect and process your Personal Data used for the purposes set out below. This may include, but is not limited to: your first and last name, email address, telephone number, date of birth, gender, marital status, images and location, device ID, certain cookies and network identifiers.
The Data Controller processes (collects, records, stores, processes, consults, modifies, uses, transmits, archives, deletes and destroys) Personal Data as indicated in this Privacy Policy, in accordance with the principles of good faith and proportionality, to manage, provide and improve the Services, for advertising and marketing purposes, to analyze applications, as further described below.
We encourage you to read this Privacy Policy, our Terms and Conditions of Use (referred to as the “Terms” herein).
BY USING OUR SERVICES, YOU EXPRESS YOUR CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL DATA FOR PROCESSING, IN THE MANNER DESCRIBED IN THIS PRIVACY POLICY.
1) Data sources
We collect your Personal Data in different ways and for different purposes, including:
1. When you register for our Services.
We collect Personal Data when you use or interact with our Services, online and offline, including when you enter your data on our Sites, view our items online, use our Services.
2. When you communicate with us or request information.
We collect Personal Data when you communicate with us or re-submit information via Sites, Social and email and offline activities.
By giving your consent, you authorise us to use your Personal Data to send you information and promotional material about the Service you have requested, to provide you with information about Services that we think may be of interest to you and for further marketing purposes. You can manage your communication preferences by interacting with us via the email address: info@domusrealty.com.
Regardless of your preferences, we may send you formal notices about the products or Services you have purchased or used and essential information such as a review of our Terms or this Privacy Policy.
We may use your Personal Data to respond to your requests for online and offline services, product information or any other communication from you. We may also use your Personal Data to respond to your enquiries, questions or complaints.
3. When you interact with our advertisements or online and offline communities.
We may collect your Personal Data when you interact with our online (Social) and offline communities. This is the case, for example, when you click on advertisements, interact on our social media pages, post content, write reviews, calls to the company or otherwise post information in the comments field, on blogs, message boards, events and other forums of communities sponsored by or linked to the Owner.
4. When we use and/or collect Cookies, device ID, location, data from the environment or use other tracking technologies.
We may collect certain Personal Data using cookies and other technologies. Our Use of Cookies section, under point 6), contains more information and options for controlling or withdrawing consent to the collection or use of certain data.
5. When we aggregate or centralize data.
We aggregate and centralize Personal Data and Sites Data for purposes of analysis, improvement and to provide advanced services to our Users.
6. When we provide you with geographically relevant Services, offers or advertisements.
Where you have given your consent to process your precise Location Data, we may use that data to provide you with Services, offers or advertisements relevant to your location.
7. For compliance with legal requirements or obligations, law enforcement and public safety purposes.
We may use Personal Data to comply with laws, regulations, court orders or other legal obligations, to facilitate an investigation, to protect or defend our rights and property, for the safety of third parties, to enforce our Terms of Use, for this Privacy Policy, for agreements with third parties or for crime prevention purposes.
2) Availability of the privacy policy
The Owner provides the possibility to consult this information notice:
– every time it collects the Data;
– each time an express request is made to the Data Controller;
– through the web consultation accessing from the home page of the site www.domusrealty.com, through the tag “Privacy Policy”.
3) Purpose of data processing
The Data Controller, for his own institutional purposes, connected or instrumental to the activity, processes the Data for the following purposes:
a) purposes connected with obligations under laws, regulations and Community legislation as well as provisions issued by authorities empowered to do so by law or by supervisory and / or control bodies;
b) contractual purposes, connected and instrumental to the establishment and management of relations with customers, such as, for example, the acquisition of information prior to the possible conclusion of a contract, including the sending of information material relating to the request;
c) detection of the degree of satisfaction with the quality of the services offered, carried out directly by the Owner or through the work of specialized companies, through personal or telephone interviews, interactive questionnaires, market surveys;
d) promotion of products and services of the Owner, carried out by sending advertising material, telephone contacts and any other form of electronic communication (sending e-mails, text messages, mms, publications on social networks, etc..) outside the services required under point b);
e) communication and/or transfer of data to third parties for the promotion and/or sale of products and services, using traditional and/or automated methods.
With reference to the purposes referred to in points c), d), e), we inform you that, at any time, the User will be free to revoke the consent expressed in the manner specified in this statement.
4) Nature of data provision
The provision of data may be compulsory or optional in nature, as well as entail consequences in case of refusal. In this regard, we would like to inform the Users that:
a) the granting of their consent for the purposes referred to in letters a) and b) of point 3) is mandatory as required by law or to comply with contractual obligations (as indicated in art. 6, paragraph 1, letter b and c of the Regulation). The refusal of your consent for the purposes indicated in letter b) of point 3) will not, therefore, allow the Owner to provide the services requested by you and to perform the task conferred by you.
b) The refusal to process the Data for the purposes referred to in letters c), d), e) of point 3) is optional, will not have any detrimental consequences and may be revoked by you at any time, limited to the purposes related to the sending of advertising material, detection of the degree of satisfaction with the quality of services, carrying out market research or commercial communications, through telephone contacts or any other form of electronic communication (sending e-mails, sms, mms, whatsapp, publication on websites, social networks, etc.), carried out directly by the Owner or through the work of specialized companies through personal interviews or telephone, interactive questionnaires.
5) Special data, worthy of special protection
Art. 9 of the Regulationand art. 6 LPD defines as particular those data that can reveal racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as genetic and biometric data, data relating to health or sex life or sexual orientation of the person. It is possible that the Owner comes into possession of particular data in relation to the specific operations requested by the person concerned. In this case, the interested party has the right to express a specific consent to the processing of their sensitive data and the Owner may use them only to the extent necessary to perform the services and operations requested.
6) Use of Cookies
This document (Use of Cookies) is an integral part of Domus Realty’s Privacy Policy.
The Owner uses so-called Cookies, and similar technologies, to better understand how people use its Sites in order to improve the platform in the future. This document is intended to provide a clear and explicit overview of how Domus Realty uses all of these technologies.
If you choose to use the website without blocking or disabling cookies and all other technologies used (i.e. using cookies), you must give your consent to their use, all personal information collected through these technologies will be treated in accordance with Legislative Decree 196/2003 in accordance with the Privacy Policy. If the consent is not given, please be sure to have blocked or disabled the use of tracking technologies using the settings of your browser, or the settings on your mobile device. If the website provides for this, a modal pop-up will be displayed that allows the user to express consent to the storage of cookies.
Document structure
This document, known as the Cookie Privacy Policy, has the following structure:
– What are cookies?
– Types of cookies
– Other technologies
– Privacy and cookie security
– Other cookie-based threats
– Cookies on https://domusrealty.com
What are Cookies?
Cookies are small text files placed in a local folder on your computer by websites. These text files can be read by the site that generated them so that they can identify you when you return to the site. They are used to optimise a website, track and analyse the data needed to interpret how and which actions (e.g. how many clicks the user makes on a given link leading to a page) are carried out by the user of the website. Cookies can be classified as “session” or “persistent”. Session cookies are deleted as soon as you close your web browser, while persistent cookies remain stored on your device for a time determined by an expiration date set in the cookie. There are also other similar technologies (which use cookies), which basically allow you to perform similar actions; they are tracking pixels, Web GIFs, Flash Plugins, etc..
Types of Cookies
Persistent cookies: These cookies remain stored on your device for the time specified in the cookie. They are activated each time the user visits the website that created that particular cookie.
Session cookies: These cookies allow, during a work session established with the website (authentication, maintenance of the user profile while browsing) to remember the user when switching between pages. Session cookies are created temporarily and once you close your browser, they are deleted.
Strictly necessary cookies: These cookies allow you to take advantage of services requested by you. They are essential in order to allow you to move around the site and use its features, such as access to secure areas of the website.
Performance Cookies: These cookies collect anonymous information about the pages you visit. It collects information about how users use the website, which pages visitors visit most often, and whether they get error messages. They do not collect information that identifies a visitor. All information that these cookies collect is aggregated and is only used to improve the operation of the site.
Functional Cookies: These Cookies allow you to remember your choices (such as when authenticating your user name, language, or region), remember changes in text size, fonts, and other parts of web pages that you can customize. The information these Cookies collect may be anonymized.
Third Party Cookies: These Cookies collect information about your browsing habits in order to make advertising related to the interests of visitors. Their use is intended to offer ads that are more relevant to your interests and limit the number of times an advertisement is presented to help measure the effectiveness of your advertising campaign. Very often third party cookies or “Advertising Cookies” are linked to the functionality of the site provided by another organization.
Other Technologies
Google Analytics / Optimizer / AdSense: these are services provided by Google. Google Analytics uses Cookies to help us analyze how users use the website, the mobile site and all content entered from third party sites.
Google AdSense is a program operated by Google that allows network advertisers to place advertisements on their websites by earning based on the number of ad exposures or clicks made on them. You can access the information at the address:
https://www.google.com/adsense/localized-terms.
Google Web Optimzer uses cookies to measure how different users respond to different content. The information generated by the cookie (including your partial IP address) is transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage. Please note that Google receives a partial IP address; this is sufficient to identify (approximately) the country from which you are visiting the website or accessing third-party content, but is not sufficient to identify the user, computer or mobile device that is visiting the website.
You can find more information about Google’s Privacy Policy at
http://www.google.it/analytics/learn/privacy.html.
Google also offers visitors the opportunity to download an add-on for the main browsers to deactivate Google Analytics.
This component is provided free of charge at: https://tools.google.com/dlpage/gaoptout.
Web beacons: also known as “tracking pixels”, “gif 1×1”, “single pixel gifs”, “pixel tags” or “action tags”, are small image files embedded in newsletters sent by e-mail. These transparent GIFs inform you if you have opened the newsletter, clicked on any of its contents or forwarded it. This method provides useful information regarding the effectiveness of the newsletters sent, thereby ensuring that we offer relevant information to users. You can unsubscribe from the newsletter at any time by following the link in the newsletter itself.
Flash cookies or Local sharedobjects (LSOs): Web sites may use Flash content displayed on their pages to store certain information on your device. As with HTTP Cookies, local shared objects may be used by websites to collect information about the paths that internet users take when navigating through websites. Online banks or advertisers may use local shared objects for monitoring purposes. With respect to Flash Cookies, Adobe does not directly provide a tool to customize Flash Player settings related to cookie management. To access the various settings offered, instead, you need to access any web page containing your creativity, right-click on it, choose the global settings option and then click on the General Privacy Settings Panel link. Alternatively, you can visit the page directly:
http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
Sharethis Sharing Cookies: These cookies allow the content sharing service provided by Sharethis to work properly. The Sharethis button is a widget that allows users to share any content with their friends via email, or via a text message. The button can be implemented on any site to target traffic, stimulate viral activity and monitor content sharing.
Scorecard Research Beacons: Scorecard Research is a website used to collect web browsing data on specific sites that are registered for extensive market research. The purpose is to create reports on the behavior of Internete new trends. You can view the Privacy Policy at: http://www.scorecardresearch.com/Priv.html
Cookies Privacy and Security
Cookies are not viruses, they are just text files that are neither interpreted by the browser nor executed in memory. As a result, they cannot duplicate themselves, spread to other networks and be replicated again. Since they cannot perform these functions, they do not fall under the standard definition of viruses. However, cookies can be used for malicious purposes. Because they store information about your preferences, the history of a user’s actions, and specific navigation between multiple sites, cookies can be used to act as a form of spyware. Many anti-spyware products are well aware of this problem and routinely report Cookies as possible threats.
Please note that if you delete Flash Cookies or completely disable storage, some websites may no longer operate as expected. Flash cookies can be used, for example, to force a new creation of a traditional HTTP cookie containing the information it previously housed (respawn).
Cookies are used for a variety of purposes, including: navigating through pages efficiently, remembering preferences, and generally improving the user experience. They can also help ensure that online advertising is more relevant to your interests. You can find more information about Cookies at www.allaboutCookie.org and www.youronlinechoices.eu.
Other Cookies Based Threats
Because cookies are transmitted between your browser and the website, an attacker or unauthorized person may intercept the transmission of data and information about cookies. Although relatively rare, this can happen if your browser connects to the site using, for example, an unprotected WI-FI network. Other cookie-based attacks involve server settings. If a website does not require the browser to use only encrypted connections (e.g. https), attackers can use this vulnerability to deceive visitors by sending them personal information through unsecured channels. The attackers then hijack the personal data for unauthorized processing purposes.
Cookies on www.domusrealty.com
Domus Realty’s responsible and ethical privacy policy includes clear descriptions of how Cookies are distributed on https://domusrealty.com and http://domusatelier.com. Most browsers implement a privacy action setting feature that provides different levels of cookie acceptance, expiration and deletion after a user has visited a particular site. Because identity protection is highly valued by Internet users, and is a right, you should be aware of the threats that Cookies may present.
We want to be transparent about the conditions and purpose of Domus Realty’s use of Cookies and other technologies.
In line with the standard practices of many websites, the websites https://domusrealty.com and http://domusatelier.com may store cookies, web beacons, flash cookies and other technologies on your computer.
In order to use all the services available at https://domusrealty.com, you must give your consent to the storage of cookies.
7) Data Retention
The Data will be kept for the time necessary to manage the contractual relationship and comply with legal obligations, with particular reference to the legislation on anti-money laundering. The Data is processed in full compliance with the principles of good faith and proportionality of processing (art. 5, paragraph 1, letter c) of the Regulation) and LPD, according to which all personal data and the various methods of their processing must be relevant and not excessive in relation to the purposes pursued, so as to ensure adequate security and confidentiality, including to prevent unauthorized access to or use of personal data and equipment used for processing, as well as lawful and proper processing.
In accordance with the provisions of art. 13, paragraph 2, letter A) of the Regulation, the following information is provided on the storage times of the Data according to the different purposes of the processing:
– with reference to letters a) and b) of point 3), the Data is retained for the period necessary to manage the contract and fulfill legal obligations;
– with respect to points (c), (d), (e) of point 3), retention periods are set at a maximum of 10 years or as long as they are used to provide you with the requested service. Where it is no longer necessary to process your data or on specific request, it will be deleted from our systems.
To protect User data, we take security measures in line with industry standards. However, we would like to point out that we cannot guarantee the absolute security of the User’s personal data, since the electronic processing and transmission of data still involves some risks.
The User has the possibility to withdraw, at any time, the consent given to the Holder and its subsidiaries in relation to the processing of the Data, requesting the deletion of the same.
If you have any questions about our Data retention procedures or request their deletion, you may contact our email address: info@domusrealty.com
8) Methods of data processing
In relation to the purposes indicated in point 3, the Personal Data may also be processed by a “Manager”, i.e. the natural person or company, even outside the Agency, to whom specific and defined tasks of management and control of data processing may be entrusted, and by one or more “Person in Charge”, who will process or use the Data on the basis of the instructions received from the Owner or Manager (persons who, if not expressly indicated in this statement, are considered not yet designated, and not necessarily to be designated if the treatment is occasional, and whose data will be provided to the User in case of designation).
Again in relation to the purposes indicated above, the Data may be processed through manual, computerized and/or otherwise authorized tools according to logic strictly related to the purposes of the processing and in any case, in order to ensure security even in the case of processing through remote communication tools.
9) Data transfer abroad
The Data may also be transferred to third-party companies or service providers appointed abroad, to European Union countries and to third-party countries (i.e. not belonging to the European Union) provided this is appropriate for the purposes of the data processing described in this document privacy policy. For our part, however, we only work with data controllers who are committed to carrying out their tasks in accordance with the LPD and/or the GDPR.
10) Communication of Data
The Data, due to the relationship established and in order to facilitate and allow the conclusion of the business, may be communicated to:
– external collaborators and service providers;
– other business agents in mediation (including companies) identified by the Owner in order to cooperate in the performance of the task entrusted by the interested party;
– banks and other subjects operating in the banking sector;
– counterparties and their possible technicians and consultants;
– notaries for the purpose of preparing notarial deeds and/or related activities relating to the mandate conferred on the Holder;
– companies and/or professionals that provide services for the performance of technical practices/catastrophes/construction/urban planning;
– insurance for the purpose of stipulating policies relating to the mandate conferred on the Holder;
– websites, social networks, apps, mailings and offline activities for real estate advertising purposes;
– boards of arbitrators and, in general, all those public and private subjects whose communication is necessary for the correct fulfilment of the purposes indicated in point 3);
– Supervisory/Control Bodies and other Authorities, for purposes connected with the obligations provided for by law (anti-usury law, anti-money laundering legislation) and/or by regulations, as well as by provisions issued by the same Authorities.
All subjects belonging to the categories to which the Data may be communicated, will use the Data as “owners” under the law or specific consent, in full autonomy, being unrelated to the original processing carried out by the Owner, or as “external managers”. To know at any time the subjects to whom your data will be communicated, it is sufficient that you request the updated list by writing to the Data Controller at the headquarters of the Agency.
Finally, your data will be known to all employees and collaborators of the Agency, including affiliates and partners, designated managers and / or processors, in relation to the performance of their duties and tasks assigned to each.
The Data processed by the Agency will not be disclosed.
11) Rights of the interested party
Within the limits and under the conditions provided for in Articles. 15 – 23 of the Regulations and pursuant to articles. 25 and 28 LPD, the Owner guarantees and recognizes the exercise of the following rights:
– the right to access personal data in its paper and/or electronic archives;
– the right to request their rectification, updating and cancellation, if incomplete or incorrect, and to oppose their processing for legitimate and specific reasons;
– the right to have inaccurate personal data corrected without undue delay.
Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, including by providing a supplementary statement;
– the right to obtain the cancellation of personal data concerning him without undue delay if there is one of the reasons referred to in art. 17, paragraph 1 of the Regulation;
– the right to obtain the limitation of the treatment when one of the hypotheses referred to in art. 18, paragraph 1 of the Regulation occurs;
– the right to data portability within the limits and in the manner provided for by art. 20 of the Regulation.
You also have, at any time, the right to revoke your consent to the processing of your data without prejudice in any way to the lawfulness of the processing based on the consent given before revocation, and to oppose at any time to the processing for marketing purposes (right of opposition).
You have the right to receive information relating to the action taken in relation to one of the aforementioned requests or to the effects arising from the exercise of one of the aforementioned rights, without undue delay and, in any case, at the latest within one month of receipt of the request itself, which may be extended, if necessary, by two months; you also have the right to lodge a complaint with a supervisory authority and to lodge a judicial appeal.
Unless the processing of the Data violates the general principles laid down in the Regulation, the exercise of such rights must be relevant and justified and may not imply the revocation of the consent given or the request for cancellation of the Data provided by you for the conclusion and execution of the contract referred to in paragraph 3) letters a) and b), to the extent and for as long as the Data are necessary for that purpose.
The rights in question may be exercised, also through a person in charge, by sending a request to the Data Controller or Data Processor at the following addresses:
Domus Realty Sagl, Via San Salvatore 7, 6900 Paradiso (TI), Switzerland, tel. +41.91.966.33.55, email: info@domusrealty.com. To the attention of the Privacy Manager.
In exercising your rights, you may grant, in writing, delegation or power of attorney to natural persons, entities, associations or bodies; you may also be assisted by a trusted person. In order to guarantee the effective exercise of your rights, the Agency will adopt appropriate measures to facilitate access to the Data, to simplify the procedures and to reduce the time required to respond to your request.
Finally, please note that you may lodge a complaint with the supervisory authority or the Guarantor for the Protection of Personal Data.
12) Responsible and in charge of data processing
In accordance with art. 24 of the Regulation and of the LPD, the Data Processor is Domus Realty Sagl, a real estate trustee that provides real estate brokerage, sales, rental and administration services. The company is registered in Switzerland, with registration number CHE-337.664.673 and registered office in Paradiso (TI), via San Salvatore 7.