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.
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.
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: email@example.com.
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.
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.
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;
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.
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.
– What are cookies?
– Types of cookies
– Other technologies
– Privacy and cookie security
– Other cookie-based threats
– Cookies on http://domusrealty.com
What are Cookies?
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.
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:
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:
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.
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
Cookies on www.domusrealty.com
In line with the standard practices of many websites, the websites http://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 http://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: firstname.lastname@example.org
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
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: email@example.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.