Information Notice on the Processing of Personal Data – Clients and Potential Clients

  1. Identity and Contact Details of the Data Controller

The Website is entirely managed by:

AXA REIM SGP – Italian Branch on behalf of the Columbus fund

Corso di Porta Romana, 68 – 20122 MILAN, Italy

  1.  VAT no. 10074270967 mail to: axareimsgp@legalmail.it

Hereinafter also referred to as “the Data Controller”.

Since the Data Controller is established in Italy, no representative has been appointed.

  1. Contact Details of the Data Protection Officer

The Data Controller has not appointed a Data Protection Officer.

  1. Purposes of Processing and Legal Bases

Personal data will be processed for the following purposes:

Contractual and pre-contractual purposes To manage contractual activities and/or pre-contractual steps taken at your request, and to fulfil any related legal obligations; specifically, to enable us to contact you to assess the possibility of purchasing a property, to conclude contracts granting a time-limited right of first refusal on a property purchase, or to submit a purchase offer. Legal basis: processing necessary for the performance of a contract or to manage pre-contractual relations.

Marketing purposes To send direct marketing communications, newsletters, advertising material using traditional and automated contact systems, including commercial or promotional messages via email or SMS, and to carry out market research and analysis. Legal basis: your consent, expressed in accordance with this notice.

Legal obligations To fulfil legal obligations if processing under point (a) has been carried out. Legal basis: the Data Controller’s legal obligation to process personal data in compliance with applicable national law.

  1. How Consent Is Provided

Where required, consent may be given by signing a digital document, including via specific checkboxes.

  1. Methods of Processing

For purposes under point 3(a) (contractual and pre-contractual) and point 3(c) (legal obligations), data will be processed using paper tools, automated systems, and cloud-based CRM management software to properly manage contractual obligations.

For purposes under point 3(b) (marketing), data will be processed using software designed for sending commercial information.

  1. Source of Personal Data

Only data provided in accordance with this notice will be processed. No personal data from publicly accessible sources will be used.

  1. Recipients or Categories of Recipients of Personal Data

Personal data may be disclosed to:

Communication companies carrying out commercial communication activities on behalf of the Data Controller, if you have given your consent (acting as processors);

Information service providers, including hosting providers;

Companies providing cloud-based software;

Accounting/auditing firms;

The Data Controller’s partner companies.

  1. Categories of Data

Personal data will be processed.

  1. Data Transfers

The Data Controller intends to transfer personal data to a third country or an international organisation. These may include, for example:

Communication companies acting on behalf of the Data Controller;

Providers of information society services;

Group-affiliated or controlling/controlled organisations.

Data transfers will take place only where the European Commission has issued an adequacy decision confirming adequate protection of rights. If deemed appropriate, the Data Controller may also conclude specific agreements requiring such parties to adopt adequate security measures. Data may therefore be transferred to the United States of America. You may request a copy of such data or information on where they are made available by contacting the Data Controller at the above addresses.

  1. Data Retention Period

For contractual and pre-contractual purposes (3a): retained for no longer than 10 years after the end of the contract, or for no longer than 10 years after the end of pre-contractual negotiations.

For marketing purposes (3b): retained until deletion and/or revocation is requested by the data subject.

For legal obligations (3c): retained for no longer than 10 years after the end of the contract or pre-contractual negotiations, unless otherwise required by law.

  1. Optional Nature of Consent and Consequences of Refusal

For purposes under 3(a): providing personal data is contractually required. Without such data, no contract or pre-contractual negotiation can be carried out.

For purposes under 3(a): providing personal data is contractually required. Without such data, no contract or pre-contractual negotiation can be carried out.

For purposes under 3(c): providing data is a legal obligation. Without such data, the contract cannot be concluded.

  1. Right to Object

You have the right to:

Object at any time, for reasons related to your particular situation, to processing under Article 6(1)(e) or (f) GDPR, including profiling. The Data Controller will stop processing unless compelling legitimate grounds override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims.

Object at any time to processing for direct marketing purposes, including related profiling.

In case of objection to direct marketing, data will no longer be processed for such purposes. You may also object only partially (e.g., only to automated promotional emails).

Object, for reasons related to your particular situation, to processing for scientific or historical research or statistical purposes, unless the processing is necessary for a public interest task.

  1. Other Rights

You also have the following rights:

Right of access (Art. 15 GDPR): to obtain confirmation of whether your data is being processed and access to the data and related information.

Right to rectification (Art. 16 GDPR): to obtain correction of inaccurate data and completion of incomplete data.

Right to erasure (Art. 17 GDPR), including withdrawal of consent: to request deletion of your data without undue delay or revoke consent at any time, without affecting prior lawful processing.

Right to restriction of processing (Art. 18 GDPR).

Right to data portability (Art. 20 GDPR): to receive your data in a structured, commonly used, machine-readable format and transmit it to another data controller.

Right to object to commercial communications: to object at any time, free of charge, to receiving marketing communications.

  1. Exercising Your Rights

Requests to exercise the rights listed in this notice, including the right to withdraw consent or request erasure, must be addressed directly to the Data Controller via the provided email address. Alternatively, you may send a registered letter with return receipt to the Data Controller’s postal address.