Privacy Policy

Starting from May 25, 2018, Regulation no. 679/2016 on the protection of natural persons with regard to the processing of personal data and on the free circulation of such data and on the abrogation of Directive 95/46/EC (hereinafter referred to as “GDPR”), applicable in all member states of the European Union. In this sense, we adopt this privacy policy in order to align with the provisions of the new regulations.

1. Information covered by this privacy policy

This privacy policy applies to the use and processing of personal data collected and used by members of the Millstone Group.

The use of “Millstone Developments”, “Millstone” or “we” shall, herein, mean those members of the Millstone Group on whose behalf and in respect of whom this Privacy Policy is made. This privacy policy applies to your use of the Millstone Developments website and/or mobile applications, where applicable, or when you provide your personal data to Millstone, for example if you wish to purchase real estate within the projects our.

Please read this privacy policy carefully and contact us if you have any questions.

If you have any questions regarding this privacy policy or our use of personal data, or if you wish to exercise any of the rights concerned, please contact us at the e-mail address office@millstone.com.ro

2. Types of personal data processed by Millstone

Personal data is information, or any combination of separate information, that could be used to identify you. We may collect information about you from a variety of sources. This includes information we collect directly from you, information we collect when you visit our website, view our online content, and information we collect about you from other third-party sources.

Information we collect directly from you

We collect information directly from you when you participate in our offers and programs or participate in phone calls and email correspondence with us or otherwise provide information directly to us.

The following information we may collect directly from you is:

• Name and surname;
• Email address and postal address;
• Landline or mobile phone number and/or fax number;
• Date of birth;
• Gender;
• Demographic information;
• Information about dependents or vulnerable people in your household, if you choose to provide us with such information;
• Payment information, such as bank account details;
• Other financial records, such as the account statement;
• Proof of identity documents, such as an identity card or passport;
• Credit reference checks;
• Marketing preferences;
• When you contact or visit us, we may process the details of your enquiry, request, communication, complaint, survey responses and other interaction information;
• CCTV images;
• Information captured to meet occupational health and safety obligations;
• Links to your social media profiles.

Information we collect when you visit the Millstone website, view our online advertisements or promotions or other services

We use cookies and other tracking technologies to collect information when you visit our site, view our online advertisements or promotions, or other services. For more information about these, please see our cookie policy.

The following information we may collect using these technologies is:

• Device, browser and operating system information;
• IP address;
• Web pages you view on our site;
• Location data through your IP address, GPS and other means. We will only collect your location information when you use our website.

Information we collect from third-party sources

We also collect your personal data from the following third-party sources: publicly available sources, third-party referral agencies, social media platforms, legitimate marketing lists or authorized referral agents.

The following information we may collect from third-party sources is:

• Name and surname;
• Postal address;
• Email address and contact phone number;
• Date of birth;
• Income level;
• Reference and background data;
• Employment information, such as the name of your employer and your job title;
• Publicly observed activities or information made publicly available by you, including social media channels and platforms and other Internet services.

The legislation treats some types of personal data about you differently as ‘special’, as this data requires more protection due to its sensitive nature. This includes information about race, religion, health, sex life, public opinion or sexual orientation. This also applies to crimes. We will only collect or use this type of personal data (i) with your explicit consent or (ii) if we are required to do so by law.

3. Millstone’s use of website/application user personal data

We use your personal data to provide you with products, offers and services, to deliver advertisements, offers or other content tailored to your interests, to answer your questions and to carry out other business operations. We will only use your personal data where we have a valid legal basis to do so.

The personal data provided with your consent will be collected and processed by us exclusively for the purpose of sending you information and offers for marketing purposes (e.g. information about Millstone’s activity, projects and products, offers, other information as well as to contact you to request more details necessary to solve your requests. The processing of personal data is carried out based on your consent in this regard (art. 6 para. (1) letter (a) of the General Data Protection Regulation ).

We rely on your consent for this purpose.

Your data collected through this form is not subject to an automated decision-making process including the creation of profiles.

Contract: We may process personal data to fulfill our contractual obligations, as well as in the steps leading to the conclusion of a contract, when you ask us to send you an offer.

Consent: We rely on your consent when we send you marketing messages.

Legitimate interest: We may process personal data on the basis of legitimate interest, when, according to our assessment, we believe that the processing is fair, reasonable and proportionate to the purpose of the processing.

Legal obligation and public interest: We may process personal data in order to fulfill legal obligations owed to Millstone.

We process personal data transparently for the following purposes:

For the purpose of browsing the website and for purposes related to the use of cookies, we may transmit personal data to analytics and search engine service providers in order for them to provide maintenance services for our website;

Sending the requested offers through the contact form both by e-mail and/or phone;

Processing any other requests received online or by email, including formulating responses to your requests;

Promotion of products offered by Millstone through marketing messages communicated by e-mail and/or telephone;

For the organization and management of promotional campaigns, as well as for analyzing their effectiveness, we may share your personal data with advertising and marketing agencies or digital media agencies;

For direct marketing communications, we may pass on personal data to advertising and marketing agencies that carry out the communication on our behalf;

Administration and maintenance of the website;

Fulfilling the obligations that Millstone has assumed by entering into contracts;

Fulfilling legal and/or contractual obligations.

We will only use your personal data for the reasons we have outlined above. If we need to use your personal data for any other reason, we will let you know and tell you the reason together with the relevant legal basis, unless the law prevents us from doing so.

4. Sharing of website/application user’s personal information

We share your personal data within the Millstone Group and with other organizations so that we can provide you with our services and comply with our legal obligations. We have set out below who these organizations are and why we share your personal data with such organisations.

We may collect personal and other information for a co-promotion or as part of a joint initiative with a business partner and share your information with that business partner. For these initiatives, we will make it clear at the point of collection that the information will be shared with Millstone Developments and the participating business partner and we will seek your consent in accordance with applicable laws.

Sharing information with third parties and third party service providers

We engage third party service providers to perform a variety of business operations on our behalf. In this regard, we may share your personal data with them. We only provide our service providers with the personal data they need to perform the services we request, and we contractually require that they protect this information appropriately and not use it for any other purpose.

In providing our services and products, we may disclose your personal data to third parties and third party service or solution providers, specifically:

• Third party technology provider;
• Third-party provider of real estate promotion services;
• Third-party provider of customer relationship management services or solutions, including customer relationship management tools;
• Third party insurance provider, insurance brokers, insurers;
• Professional representatives or advisors, such as lawyers, accountants, notaries, inspectors, etc.;
• Third party contractors;
• Government departments;
• Regulatory authorities;
• Third parties at the customer’s request;
• Utility service providers or utility management services.

Other situations of sharing personal data

We may transfer or otherwise process your personal data:

• As part of the sale of a Millstone Developments brand to another company;
• To protect, defend or exercise the intellectual property rights of Millstone Developments;
• When required by law, court order and/or governmental authorities which may include background checks;
• Where you tell us to share your personal data or you have otherwise given us consent to do so, where you ask us to share your data with your solicitor, bank or mortgage adviser;

Millstone Developments does not transfer personal data outside the European Economic Area (EEA).

5. How a website/application user’s personal data is safeguarded

When you provide us with your personal data, we will process it using our systems, which means that your details will be entered into our databases. We have appropriate security measures in place to ensure that your data is not lost, stolen, accessed by unauthorized third parties or altered in any way. Internally, your personal data will only be accessible to those members of our staff who need to see your data (depending on the nature of the services provided). However, we cannot guarantee that your personal data will not benefit from any security risks that may be possible when your information is sent to and from the website.

6. Storage time of a website/application user’s personal information

We will retain personal data for as long as necessary to fulfill the purposes described in this privacy policy, unless a longer retention period is required or permitted by law. We will generally retain your personal data for as long as you are registered for our services. The purpose of this is to enable us to:

• Communicate with you about any questions or complaints you may have after you have ceased to be a user of our services;
• To comply with applicable accounting, reporting or other laws and regulations;
• To provide you with relevant information about products and services that may be of interest to you.

7. Website/application user rights

As a data subject you have the following rights:

• the right to access data – you have the right to obtain from Millstone a confirmation that personal data concerning you is being processed or not, as well as access to said data; at the same time, you can obtain a copy of the personal data provided to Millstone and which are the subject of processing; for any other copies requested by you Millstone may charge a reasonable fee based on administrative costs; if you submit your application electronically and unless you request a different format, the information will be provided to you in a commonly used electronic format;
• the right to rectification – you have the right to obtain the rectification by Millstone of inaccurate personal data, as well as the right to obtain completion of personal data that is incomplete; Millstone will communicate to each recipient to whom the personal data has been disclosed any rectification thereof, unless this proves impossible or involves disproportionate efforts and will inform you of such recipients if you request it;
• the right to data deletion – you have the right to obtain from Millstone the deletion of personal data concerning you, without undue delay, and Millstone has the obligation to delete said data, when: (i) the personal data is no longer necessary to fulfill the purposes for which they were collected or processed; (ii) you withdraw your consent on the basis of which the processing takes place and there is no other legal basis for the processing; (iii) you object to the processing and there are no overriding legitimate grounds for the processing; (iv) personal data have been processed illegally; (v) personal data must be deleted to comply with a legal obligation owed to Millstone under Union law or Romanian legislation; Millstone will notify each recipient to whom personal data has been disclosed of any deletion thereof, unless this proves impossible or involves disproportionate effort and will inform you of such recipients if you request it;
• the right to restriction of processing – you have the right to obtain from Millstone the restriction of processing if you are in one of the following cases: (i) you dispute the accuracy of the data, for the period that allows Millstone to verify the accuracy of the data; (ii) the processing is unlawful and you object to the deletion of the personal data, requesting instead the restriction of its use; (iii) Millstone no longer needs the personal data for the purpose of processing, but you request it for establishing, exercising or defending a right in court; or (iv) you have objected to the processing for the time period in which it is checked whether Millstone’s legitimate rights prevail over your rights; Millstone will communicate any restriction of processing to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort and will inform you of these recipients if you request it;
• the right to data portability – you have the right to receive your personal data, as provided to Millstone, in a structured, commonly used and machine-readable format and to transmit this data to another controller , under certain conditions; in exercising this right, you have the right to have your personal data transmitted directly from Millstone to another operator when this is technically feasible;
• the right to oppose – you have the right to oppose, for reasons related to your particular situation, at any time, the processing of your personal data, including the creation of profiles based on those provisions;
• the right not to be subject to a decision based exclusively on automatic processing, including the creation of profiles;
• the right to file a complaint with the National Authority for the Supervision of Personal Data Processing;
• the right to withdraw your consent at any time, without affecting the lawfulness of the processing of personal data carried out by Millstone on the basis of the consent before its withdrawal.

8. Children’s privacy

All personal data processing activities presented in this policy refer exclusively to persons who are at least 16 years old. The use of the systems, as well as the results of the processing, is prohibited with regard to children who have not reached this age without the consent of their parents/legal representatives. If, despite our reasonable efforts to prevent, such processing still takes place, we will stop it once we notice that the users have not reached the age mentioned above.

9. Refusal to process personal data of the website/application user

If you do not provide us with the personal data provided in the contact form, you will not be able to send us your request.

If you do not opt-in to receive direct marketing communications, we will not be able to inform you about Millstone offers.

10. Website/application user’s access to their personal data

You can modify the data provided by accessing the ‘update your preferences’ section available in the footer of each newsletter sent.

You can unsubscribe from the newsletter by selecting the ‘unsubscribe from this list’ option or by accessing the ‘update your preferences’ section, followed by the unsubscribe option, in the footer of any newsletter sent.

For any questions or requests regarding the personal data that you have transmitted to us, including in order to exercise the rights you have, as they are mentioned in the previous section (e.g. request for a copy of personal data, modification, deletion), you can contact us at the e-mail address specified previously in this Privacy Policy.

Millstone will provide the information in electronic format when possible, unless you request a different format.

The information provided and any communications and actions taken by you in exercising the above rights are provided by Millstone free of charge. However, if the requests made by you are unfounded or excessive, in particular due to their repetitive nature, Millstone may: (i) either charge a fee taking into account the administrative costs of providing the information or communication or taking the requested measures; (ii) either refuse to comply with the request.

Also, regarding the processing of your personal data, you have the right to file a complaint with the National Supervisory Authority for Personal Data Processing (www.dataprotection.ro).