Protection of personal data

The company IREAG UK LTD, Registration Number: 13691033, with its registered office at 71-75 Shelton Street Covent Garden, London, WC2H 9JQ, operating under the trademark IREAG (hereinafter referred to as the "Company"), in this document provides its clients and potential clients with information on how it processes their personal data (as a controller of this personal data).

The company takes it for granted that personal data will be handled sensitively and always in accordance with Regulation (EC) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (hereinafter "the Regulation"), and subsequent legislation.

In order to ensure the processing of accurate and up-to-date personal data in accordance with the Regulation, the Company requests its clients to inform it if there is a change in the personal data processed by their Company.

1. PERSONAL INFORMATION OF POTENTIAL CLIENTS

A potential client is a person who is interested in providing services to the Company, respectively, which the Company intends to offer the provision of its services, but the services are not yet provided to it.

The company processes personal data of potential clients as follows.

1.1 PERSONAL DATA PROCESSED

The company processes, basic contact information of potential clients, especially name and surname, residence, telephone number, e-mail address, as well as data related to the services requested by potential clients and data necessary to create services for potential clients, especially basic information about real estate in his own.

The Company obtains personal data directly from potential clients and / or from publicly available sources. Potential clients do not have a legal obligation to provide the required personal data to the Company. However, their provision is necessary for the provision of services to the Company and for its negotiation. However, for the avoidance of doubt, the Company states that consent to the processing of personal data for marketing purposes within the meaning of paragraph 1.2.1 is not necessary for the provision of the Company's services and for the negotiation of it.

1.2 PURPOSES OF THE PROCESSING OF PERSONAL DATA BY THE COMPANY

1.2.1 Offer of services (marketing)

The company uses personal data to address potential clients with the offer of its services, or for other marketing activities. The processing of personal data for this purpose is carried out on the basis of the consent to the processing of personal data granted by a potential client of the Company within the meaning of Article 6, paragraph 1, letter a) Regulation. Consent to the processing of personal data for this purpose may also be granted to the Company by telephone.

For this purpose, personal data may be processed for the period for which the consent was granted. If the period for which the consent is granted has not been explicitly stated, it is valid that the consent was granted for an indefinite period, respectively until further notice.

Consent to the processing of personal data for this purpose may be revoked by a potential client at any time (so-called opt-out) and the Company will immediately stop using his personal data for marketing activities. In such a case, the Company will also delete all personal data of the potential client from its databases, except in cases where it would be authorised to process the personal data of the potential client for any of the other purposes listed below.

1.2.2 Negotiation of conditions for the provision of services

The Company also uses personal data to negotiate the terms of service to a potential client (if the potential client expresses an interest) and to enter into a contractual relationship between the Company and a potential client, on the basis of which the Company will provide its services to the potential client. The processing of personal data for this purpose is necessary for the conclusion of a contractual relationship between the Company and a potential client within the meaning of Article 6 (1) (a). b) Regulation. For this purpose, personal data will be processed until the conclusion of the contractual relationship and, if it is not concluded, until there is no doubt that it will not be concluded.

1.2.3 Protection of the rights and legitimate interests of the Company

The Company may also use personal data to protect its rights and legitimate interests, in particular in the event of litigation and their prevention, related to negotiations between the Company and a potential client. This processing of personal data is necessary for the purposes of the legitimate interests of the Company within the meaning of Article 6 (1) (a). f) Regulation.

For this purpose, personal data may be processed for a reasonable period of time (usually in the order of several months) after there is no doubt that the contractual relationship between the The company and the potential client will not be concluded. However, if the negotiations have reached a more advanced stage of contracting, where the conclusion of a contract relationship already appears highly probable, personal data may be processed for that purpose for a period corresponding to the relevant limitation periods, usually within 15 years of the last limitation period. This period is suspended if any right related to negotiations between the Company and a potential client is exercised against the Company, until the material decision of the competent public authority on the applied law takes legal effect. An objection to the processing of personal data for this purpose may be raised in accordance with Article 21 of the Regulation.

2. PERSONAL INFORMATION OF CLIENTS

The Client is a person with whom the Company has entered into a contractual relationship, on the basis of which the Company will provide services to the client.

The company processes clients' personal data as follows.

2.1 PERSONAL DATA PROCESSED

The company processes the following personal data of clients:

- Basic contact details, in particular name and surname, date of birth, ID number, residence, registered office, telephone number and e-mail address;

- data necessary for the provision of services by the Company, in particular data on real estate owned by the client and on his requirements and preferences;

- Billing information, in particular the account number;

- Data necessary for the fulfilment of legal obligations pursuant to relevant legal regulations, in particular pursuant to Act No. 253/2008 Coll., on Certain Measures against the Legalization of Proceeds from Crime and Terrorist Financing, as amended (hereinafter the "AML Act"), for example of the client's identity document.

The Company obtains personal data directly from clients and / or from publicly available sources. Clients are not legally obliged to provide the required personal data to the Company. However, their provision is necessary for the provision of services by the Company. However, for the avoidance of doubt, the Company states that consent to the processing of personal data for marketing purposes within the meaning of paragraph 2.2.2 is not necessary for the provision of services by the Company and for the negotiation of it.

2.2 PURPOSES OF THE PROCESSING OF PERSONAL DATA BY THE COMPANY

2.2.1 Providing services

The Company uses personal data for the purpose of providing services to the client and to exercise its rights and obligations arising from the contractual relationship between the Company and the client, on the basis of which the Company provides services. The processing of personal data for this purpose is necessary for the performance of this contract relationship within the meaning of Article 6 (1) (a). b) Regulation. For this purpose, personal data will be processed for the duration of the contractual obligations.

2.2.2 Offer of services (marketing)

The company uses the contact details of clients to contact them with the offer of its services, or for other marketing activities. The processing of personal data for this purpose is carried out on the basis of the legitimate interest of the Company within the meaning of Article 6, paragraph 1, letter f) Regulation. However, if the client has given explicit consent to the processing of personal data for this purpose (if requested by the Company), the processing of personal data for this purpose is carried out on the basis of the client's consent within the meaning of Article 6 (1) (a). a) Regulation.

For this purpose, personal data may be processed for the duration of the obligations under the contractual relationship between the Company and the client and for another reasonable period after the termination of the obligations under this contractual relationship (usually 1 year). In the event that personal data are processed on the basis of the client's consent, personal data may be processed for this purpose for the period for which the consent was granted. If the period for which the consent is granted has not been explicitly stated, it is valid that the consent was granted for an indefinite period, respectively until further notice.

An objection to the processing of personal data for this purpose may be raised pursuant to Article 21 of the Regulation, respectively revoke the consent (so-called opt-out), and the Company will immediately stop using the client's personal data for marketing activities.

2.2.3 Fulfilment of legal obligations of the Company

The Company also uses personal data in fulfilling its obligations arising from applicable legal regulations, in particular the obligations arising from the AML Act (especially the obligation to identify and control the client) and Act No. 563/1991 Coll., On Accounting, as amended. The processing of personal data for this purpose is necessary to fulfill the legal obligations of the Company within the meaning of Article 6, paragraph 1, letter c) Regulation. For this purpose, personal data will be processed for the time necessary to fulfill legal obligations. In the case of documents subject to a binding minimum retention period, personal data will be processed for at least this minimum retention period.

2.2.4 Protection of the rights and legitimate interests of the Company

The Company may also use personal data to protect its rights and legitimate interests, in particular in the event of litigation and its prevention, related to the contractual relationship between the Company and the client and the services provided. This processing of personal data is necessary for the purposes of the legitimate interests of the Company within the meaning of Article 6 (1) (a). f) Regulation.

For this purpose, personal data may be processed for a period corresponding to the relevant limitation periods, usually up to fifteen years from the beginning of the last limitation period. This period is suspended if any right related to negotiations between the Company and a potential client is exercised against the Company, until the material decision of the competent public authority on the applied law takes legal effect. An objection to the processing of personal data for this purpose may be raised in accordance with Article 21 of the Regulation.

2.3 PERSONAL DATA OF THIRD PARTIES

If necessary for the provision of services by the Company, the Company may also process certain information about third parties (e.g., personal data of the client's contact person), which the client provides to the Company for this purpose. The company will process this personal data for the purpose for which it was provided to it (e.g., for the purpose of communication with the client, in the case of personal data of the contact person), for the time necessary to achieve the purpose of processing. The processing of such personal data is carried out for the purposes of the legitimate interest of the Company within the meaning of Article 6, paragraph 1, letter f) Regulation.

The Administrator requires clients, when transferring personal data of third parties to the Company, to ensure that such personal data is transferred to the Company in accordance with the Regulation. In particular, it is necessary to ensure that the third parties concerned are informed in accordance with the Regulation that their personal data will be passed on to the Company and for what purpose.

2.4 RECIPIENTS OF PERSONAL DATA

The company processes personal data itself without the use of external processors of personal data.

Personal data may be disclosed to the following third parties:

- professional service providers such as lawyers and tax advisers bound by legal or contractual secrecy;

- persons who will be witnessed by a legal reason for access to personal data (e.g., tax office, law enforcement authorities or other supervisory authorities with a legal authority to access information);

- Other persons if this is necessary for the protection of the Company's rights (e.g., a court).

The Company will not transfer personal data to countries outside the European Union or to international organisations.

2.5 THE RIGHTS OF CLIENTS AND POTENTIAL CLIENTS ARISING FROM THE REGULATION

As data subjects, potential clients and clients have all rights under the Regulation, in particular:

- the right to obtain information from the Company as to whether or not their personal data are being processed and, if so, the right to access such personal data and other information pursuant to Article 15 of the Regulation;

- the right to rectify inaccurate personal data concerning them, in accordance with Article 16 of the Regulation;

- the right to have personal data erased under the conditions laid down in Article 17 of the Regulation, e.g., where such personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

- the right to restrict processing under the conditions set out in Article 18 of the Regulation, e.g., if the client denies the accuracy of the personal data processed;

- the right to obtain personal data concerning them in a structured, commonly used and machine-readable format and the right to transfer such data to another controller without the Company's interference, under the conditions laid down in Article 20 of the Regulation;

- the right to object to the processing of personal data pursuant to Article 21 of the Regulation.

You can exercise the above rights, revoke your consent to the processing of personal data or make another request regarding the processing of personal data by the Company through the contact details provided on the Company's website www.ireag.co.uk, or through a representative of the Company. Withdrawal of consent to the processing of personal data for the purposes of the offer of services can also be made via the e-mail address of the Company info@ireag.co.uk.

In addition to the above rights, potential clients and clients have the right to lodge a complaint with the relevant supervisory authority if they believe that the processing of their personal data violates the Regulation.