Data Privacy

Status: 15 December. 2020

1. Introduction

 

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With this Privacy Notice we inform you about how and to what extent we process your personal data and about your rights under the General Data Protection Regulation ("GDPR").

In the course of further development of our services and our website as well as the integration of new technologies in order to improve our services for you, changes to this Privacy Notice may occur. We therefore recommend that you access and read this notice from time to time again.

2. Explanation of terms

 

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The data protection terms used below (e.g. "personal data", "controller", "data protection officer" or "data processing") are defined in Art. 4 GDPR. The full text of the GDPR is available on the Internet under the following link:

https://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32016R0679&from=DE

3. Who is responsible for the data processing and who can I contact?

3.1 Controller according to Art. 4 No. 7 GDPR

 

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In this Privacy Notice, the term “BUWOG” refers to the respective responsible company or companies from the BUWOG Group. We explain who this is in each individual case below:

The controller for data processing activities in connection with the use of the www.buwog.de website is

 

BUWOG Property Developer Ltd.
Rankestraße 21
10789 Berlin
Phone: +49 30 33 85 39 1900
info@buwog.com

 

Joint controllers for data processing activities in connection with the planning, implementation and execution of construction projects and the purchase and sale of real estate are the respective buyer or seller (i.e. the project company acquiring or selling real estate) together with BUWOG Bauträger GmbH. The joint controllers have agreed that BUWOG Bauträger GmbH shall be responsible for fulfilling data subject rights and serve as the point of contact. However, this does not mean that you cannot also contact the respective project company as additional joint controller.

The controller for data processing activities in connection with the use of the website of an individual planning project ("Project Website") is the respective project company as indicated in the imprint of the Project Website.

The controller for data processing activities in connection with your application for employment is the respective BUWOG company to which you apply.

3.2 Contact details of the data protection officer

 

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BUWOG is happy to assist you with any questions you may have on data protection. You can reach our data protection officer as follows:

Dr. Stefan Drewes
c/o Vonovia SE
P.O. Box
44784 Bochum
E-mail: datenschutz@vonovia.de

Our data protection officer is the group data protection officer of the Vonovia Group to which BUWOG belongs. We expressly point out that when using this e-mail address, its contents will not exclusively be reviewed by our data protection officer. If you wish to exchange confidential information, we therefore ask you to first contact us directly via this e-mail address without providing a more detailed description of the circumstances.

 

4. To whom does this Privacy Notice apply?

 

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When we process personal data, this means in short that we collect, store, use, transmit or delete the data, for example.

This Privacy Notice is about personal data of

  • visitors to our website or a Project Website (when using the site and the communication options available on it, such as the contact form);
  • users who make use of other of our services (e.g. our newsletter);
  • prospective sellers and buyers, including their employees, tenants and business partners;
  • employees of business partners and service providers (e.g., in connection with the development or sale of property); and
  • applicants for employment at BUWOG.

5. What data does BUWOG process from you and from which sources does the data orig-inate?

 

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We process your personal data when you contact us, e.g. as a visitor to our website, as a prospective buyer or seller, when you write us a message or as a subscriber to our newsletter. In addition, we process your personal data if we have received it from a third party (e.g. a broker).

We process the following personal data:

 

Visiting the website

When you visit our website or a Project Website, we process the following data: technical access data, the name of your Internet service provider, the site from which you are visiting us or the name of the requested file, the date and time of your visit and the identification data of the browser/operating system used as well as your IP address. We evaluate this data - in anonymized form – exclusively for statistical purposes and without drawing any conclusions about your person, e.g. to evaluate the number of page views and the duration of use.

The details in connection with the use of cookies and tracking tools are described in section 9 (use of cookies) and details in connection with the use of plugins are described in section 10 (plugins and social media).

If special features occur on a Project Website (e.g. because other cookies are used or the Project Website has a privacy-relevant functionality not described in this Privacy Notice), this will be noted accordingly on the Project Website.

 

Communication – contact form and newsletter

When using our contact form or the form for subscribing our newsletters and, thereafter, for sending or providing corresponding information, we process the data provided by you in the respective form as well as your message.

Only information about title, first name and surname, e-mail address and subject/area, the subject and the message are mandatory. All other information are provided voluntarily. In addition, your IP address and the date and time of the message or subscription will also be stored when your message is sent.

If you wish to subscribe to our newsletter or obtain information about a current project, we use the so-called double opt-in procedure. This means that we will first send you an e-mail to the specified e-mail address. In this e-mail, we ask you to confirm that you wish to receive the newsletter or the requested information. If you do not confirm this within 24 hours, your data related to the newsletter subscription or request will be blocked by us and automatically deleted after one month. The purpose of this procedure is to prove your registration or request and, if necessary, to be able to prevent and clarify a possible misuse of your personal data.

 

Project Management

In connection with the development, planning, organization, coordination and distribution of real estate projects, we process the contact data (e.g., first name, last name, e-mail address, telephone number) and, if necessary, other personal data of the parties involved as required for the project management, including the contact data of employees of our business partners and service providers as well as other persons involved in our business activities.

 

Prospective buyers or sellers

If you contact us as a prospective buyer or seller - directly or via a broker - we will process your contact data (e.g. first name, last name, address) and, if necessary, other data required for the conclusion of a purchase agreement.

 

Applicant data

If you apply to work for us as an employee, we will process the personal data you send to us as part of your application (e.g. name, address, contact details, certificates, references).

 

6. What does BUWOG use your data for (purpose of processing) - and on what legal ba-sis?

We process the aforementioned personal data in accordance with the provisions of the GDPR and the Federal Data Protection Act (BDSG). In detail:

6.1 Visit our website

 

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The legal basis for the processing of the data mentioned in section 5 (visiting the website) through the use of cookies that are not necessary (see section 9) and through the use of plugins (see section 10) is your consent (Art. 6 para. 1 lit. a) GDPR), which can be revoked at any time with effect for the future and which you can declare via the cookie banner when you open the website for the first time or when you activate the plugins individually in each case. You can find more details on revocation of consent in section 12.

We use your data as well as the data of the cookies and web tracking tools so that you can fully use all functions of our website, for the needs-based design and optimization of our website and for marketing purposes (see in particular sections 9 and 10).

6.2 Contact form

 

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Your consent, which can be revoked at any time with effect for the future (Art. 6 para. 1 lit. a) GDPR), is the legal basis for the processing of the data you have voluntarily entered and your message to us. We use your data to process and respond to your (contact) request. You can find more details on revocation of consent in section 12.

6.3 Newsletter

 

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Your consent, which can be revoked at any time with effect for the future (Art. 6 para. 1 lit. a) GDPR), is the legal basis for sending the newsletter by which we provide you with current interesting information about the BUWOG Group. We use your data for sending the newsletter. You can find more details on revocation of consent in section 12.

6.4 Sale or purchase of property or real estate

 

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If you and BUWOG are about to enter into a contract as a result of your application or your inquiry about the sale or purchase of property or real estate, we process your data to fulfill the contractual or pre-contractual obligations on the basis of Art. 6 (1) lit. b) GDPR. The purpose of the processing is the negotiation and preparation of a real estate purchase contract as well as its conclusion and implementation.

6.5 Provision of services

 

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The legal basis for the processing of your data in connection with the provision of services is Art. 6 para. 1 lit. b) GDPR, insofar as this is necessary for the fulfillment of (pre)contractual obligations arising from the service contract between you and BUWOG.

6.6 Your contact and website use

 

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BUWOG processes personal data transmitted when you use our website (or a Project Website) and when you send us messages (e.g. via our contact form, newsletter) (e.g. the IP address, date and time of the message) on basis of our legitimate interests pursuant to Art. 6 (1) lit. f) GDPR. The processing is carried out to prevent misuse and to ensure the security of our information technology systems. These interests outweigh in the specific cases the rights and freedoms of the website users concerned. In section 12, we describe your rights to object to such processing.

6.7 Assistance in the sale or purchase of property or real estate

 

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If we are not acting as sellers or buyers, we process your personal data in connection with your application or inquiry for the sale or purchase of a property or real estate on the basis of our legitimate interest in responding to your inquiries pursuant to Art. 6 (1) lit. f) GDPR. In section 12, we describe your rights to object to such processing.

6.8 Settlement of legal disputes, assertion, exercise and defense of legal claims

 

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We process your data for and in connection with law enforcement activities (for example, in connection with rights and obligations under the GDPR), based on our legitimate interests in such processing (Art. 6(1)(f) GDPR), which outweigh the rights and freedoms of the data subjects. In section 12, we describe your rights to object to such processing.

 

6.9 BUWOG Group

 

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In order to provide you with the best possible service and remain competitive and to manage and improve our services, we share data within companies from the BUWOG Group (within the EU) on basis of our legitimate interests (pursuant to Art. 6 (1) f) GDPR), e.g. by forwarding customer inquiries concerning another company from the BUWOG Group to that company. These interests outweigh the rights and freedoms of the data subjects. In section 12, we describe your right to object to such processing.

6.10. Marketing and direct marketing

 

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Your data will be used by us on basis of our legitimate interests for the purpose of direct marketing (e.g. to conduct customer surveys, opinion polls, marketing campaigns, market analyses, sweepstakes, contests or similar actions and events) according to Art. 6 (1) f) GDPR, unless your rights and freedoms outweigh our legitimate interests. In this context, we also analyze the results of (direct) marketing activities in order to measure the efficiency and relevance of our measures. In section 12, we describe your right to object to such processing.

6.11. Project Management

 

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Where we process personal data in connection with the development, planning, organization or coordination of real estate projects or any warranty management resulting hereunder, we base the data processing on our legitimate business interests in providing the project management services (Art. 6 (1) f) GDPR). These interests outweigh the rights and freedoms of the data subjects. In section 12, we describe your right to object to such processing.

6.12. Corporate transaction

 

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In connection with a corporate transaction, a risk assessment (due diligence) will be carried out in relation to the company from the BUWOG Group to be sold or the company to be purchased. This includes the processing of personal data. The data processing will be carried out in accordance with Art. 6 (1) f) GDPR on the basis of our legitimate interest in having the company (to be sold or bought) checked for this purpose by way of a risk assessment, insofar as the rights and freedoms of the data subjects do not prevail. In section 12, we describe your right to object to such processing.

6.13. Compliance with legal requirements

 

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BUWOG processes personal data in order to comply with legal and tax law obligations as well as well as reporting and information obligations towards authorities (Art. 6 para. 1 lit. c) GDPR). Legal requirements include retention obligations under tax and commercial law as well as existing obligations to carry out monitoring measures to prevent financial crime and/or money laundering.

6.14. your application

 

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If you apply to work for BUWOG and provide us with your data in this context, the data protection notice for applicants of Vonovia SE (available at www.vonovia.de/de-de/datenschutz-bewerber) applies to us accordingly, whereby, in deviation from such notice, the respective BUWOG company to which you apply, not Vonovia SE, will be the responsible controller for the processing of your data. When reading the data protection information for applicants, please replace the references to Vonovia SE contained therein with references to the company from the BUWOG Group to which you are applying (e.g. BUWGO Bauträger GmbH).

7. Who receives your data?

 

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In order to offer you the best possible service and to remain competitive, we share data within companies from the BUWOG Group, as described in section 6.9, if this is necessary to safeguard our legitimate interests and unless your interests or fundamental rights and freedoms do not outweigh our interests.

We also share your personal data with the following recipients for the following purposes:

 

Public bodies

BUWOG transfers personal data to courts, supervisory authorities, financial authorities and other public bodies on an exceptional basis in accordance with legal regulations (e.g. in cases of danger prevention, criminal prosecution or money laundering prevention).

 

External service providers

BUWOG uses the following categories of external service providers and contractual partners in order to take advantage of their special expertise: (i) brokers, (ii) property management companies, (iii) consultants, (iv) service providers, (v) marketing agencies, (vi) IT service providers (vii) construction companies and craftsman firms, (viii) banks, (ix) insurance companies and (x) Vonovia SE (HRB 16879, Universitätsstraße 133, D-44803 Bochum).

If the aforementioned third parties are not acting as data controllers pursuant to Art. 4 No. 7 GDPR when processing the transferred data, they will be processing your data as so-called “processors on our behalf” pursuant to Art. 28 GDPR. The processors will only act on the instructions of BUWOG and will be contractually obligated vis-à-vis BUWOG to comply with the applicable data protection requirements.

8. Is data transferred to a third country or to an international organization?

 

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Data transfers to countries outside the EU or EEA (so-called third countries) will only take place if this is necessary for the execution of your order, if this is required by law (e.g. due to reporting obligations under tax law) or if you have given us your consent (e.g. cookies, social media and tracking tools).

9. Use of cookies

 

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Cookies are small text files that store and/or read various information on the users computer when our website is accessed. Cookies cannot execute programs or transfer viruses to your computer. They are used to make the website much more user-friendly and effective. The cookies used on our website are classified as necessary, marketing and statistics cookies. The classification of the respective cookies was highlighted to you when you accessed the website and can be accessed again via the "Privacy settings" checkmark on the website.

Cookies of the category “necessary” are mandatory for the operation of the website. Without them, the website cannot be displayed properly. Thus, they serve to ensure user-friendly, effective and secure access to the website.

Cookies of the categories “marketing” and “statistics” (collectively, "non-essential cookies") are used to personalize content and ads, to recognize our website visitors, to offer social media features, to collect statistical information, to follow marketing purposes using web tracking tools and to better target offers. If you have consented to the use of non-essential cookies, these non-essential cookies will be stored on your computer based on your consent. If you have not given your consent to the use of such cookies, no processing by non-essential cookies will take place. You can revoke your consent at any time by changing your settings after clicking the "Privacy settings" checkmark on the website.

Our website and the Project Websites use cookies from providers specified when the sites are accessed, the scope and functionality of which are explained below.

9.1 Google

 

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BUWOG uses cookies from the provider Google Ireland Ltd ("Google") based on your consent. In the following, we explain which tools from Google we use and how Google collects personal data in the process. Unless expressly described otherwise, all information provided about YouTube and Google's data processing activities therewith apply accordingly to the other services:

 

YouTube

According to its own statement, Google collects through YouTube cookies information about the browsers and devices you use when accessing our website. This information includes the unique identifiers, the type and the settings of the browser. Google also collects data about how your browsers and devices interact with our services. This includes, but is not limited to, IP addresses, crash reports, system activity as well as the date, time, and referring URL of your request.

Activity data that may be collected includes: terms you search for; videos you watch; content and ads you view and interact with; voice and audio data within your use of audio features; purchase activities; people you communicate with or share content with; activities on third-party websites that use our services; and the Chrome browsing history you have synced with your Google account.

Furthermore, by using GPS, IP addresses (due to the "_anonymizeIp()" extension used on this website, your IP address collected by Google will be truncated in EU member states or other contracting states of the European Economic Area; only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there), sensor data from your device, information about objects in the vicinity of your device (such as WLAN access points, radio masts and Bluetooth-enabled devices) and information about your location may be collected.

Google uses this information to evaluate your use of the website, to compile reports on website activity and to provide other services to the website operator relating to website activity and Internet usage. Google may also use this data for its own purposes.

Further information on data protection at and data processing by Google can be found here: https://policies.google.com/privacy?hl=en.

 

Google Analytics

We use Google Analytics on our website, a web analytics service provided by Google. Google Analytics uses cookies that enable an analysis of the use of our website. The information generated by the cookie about the use of our website is usually transferred to a Google server in the USA and stored there. However, due to the activation of IP anonymization on our website, the IP address of the website visitor is shortened beforehand by Google within the EU/EEA. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of BUWOG, 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 to BUWOG.

In connection with the use of Google Analytics, your personal data is transferred to the USA. The transfer will only take place with your express consent. Google LLC, headquartered in California, USA, as a provider of electronic communications services, is subject to monitoring by US authorities, which may also have access to the data stored by Google.

 

ReCAPTCHA

The CAPTCHA abbreviation stands for “Completely Automated Public Turing test to tell Computers and Humans Apart”. Captcha protects website services from being used by BOTS (computers).

 

Use of DoubleClick

DoubleClick by Google ("DoubleClick") uses cookies to serve ads that are relevant to users, to improve campaign performance reports or to prevent a user from seeing the same ad more than once. Via a cookie ID, Google records which ads are displayed in which browser and can thus prevent them from being displayed more than once. In addition, DoubleClick can use cookie IDs to record so-called conversions that are related to ad requests. For example, when a user sees a DoubleClick ad and later calls up the advertiser website with the same browser and buys something there.

 

Google Adwords Conversion Tracking

We use the offerings of Google Adwords to draw attention to our attractive offers with the help of advertising media (so-called Google Adwords) on external websites. We can determine how successful the individual advertising measures are in relation to the data of the advertising campaigns. In this way, we pursue the interest of displaying advertising that is of interest to you, making our website more interesting for you and achieving a fair calculation of advertising costs.

These advertisements are delivered by Google via so-called "ad servers". For this purpose, we use ad server cookies, which can be used to measure certain parameters for measuring success, such as the display of ads or clicks by users. If you access our website via a Google ad, Google Adwords will store a cookie on your PC.

9.2 Microsoft - Bing Ads completion tracking

 

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We also use completion tracking by Bing Ads, a web analytics service provided by Microsoft Cooperation ("Microsoft"), located in Redmond, WA 98052-6399, USA. Bing Ads also enables visitor action tracking. Microsoft uses this website analytics to measure the effectiveness by which an addressed group of people is persuaded to perform desired actions (e.g., how many users sign up for a newsletter or apply for a property as a result of an advertisement on the Bing search engine website). In doing so, Microsoft Bing Ads will store a cookie on your computer if you accesses our website through a Microsoft Bing ad. In this way, Microsoft Bing and we can recognize that someone has clicked on an ad, been redirected to our website and reached a previously determined target page (conversion page). We only learn the total number of users who clicked on a Bing ad and then were redirected to the conversion page. The data processing is based on your consent, which you can revoke at any time, as explained above in section 6.1.  

For more information about privacy and cookies used by Microsoft and Bing Ads, please visit Microsoft's website at https://privacy.microsoft.com/en-US/privacystatement.

10. Plugins and social media

 

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Google Maps

We use the map service Google Maps, which is operated by Google. You can find more information about embedding maps from Google Maps here: https://support.google.com/maps/answer/144361?co=GENIE.Platform%3DDesktop&hl=en.

When you access a page of our website that contains a Google Maps plugin, your browser establishes a direct connection to the servers of the respective provider based on your consent. The content of the plugin is transmitted directly to your browser by the respective provider and integrated into the page. By integrating the plugins, the provider receives the information that your browser has called up the corresponding page of our website, even if you do not have a profile or are not currently logged in. This information (including your IP address) is transmitted from your browser directly to a server of the respective provider in the USA or Germany and stored there. If you are logged in to Google, Google can immediately assign the visit of our website to your profile. If you interact with the plugins and click the corresponding buttons, the corresponding information is also transmitted directly to Google and stored there.

For the purpose and scope of the data collection and the further processing and use of the data by the providers, as well as your rights in this regard and setting options for protecting your privacy, please refer to the data protection information of Google Maps: https://policies.google.com/privacy?hl=en&gl=en.

 

Social media

We are present on various social media channels (currently Facebook, Instagram, LinkedIn, YouTube and Twitter), where we regularly publish reports and photos to inform you about us and our products and services. On the social media channels, you have the opportunity to respond to our "posts" and communicate with us. In doing so, we may process your personal data on the basis of our legitimate interest in responding to your comments / questions / suggestions and promoting our products and services, based on Art. 6 para. 1 lit. f) GDPR. For the use of Facebook, Instagram, LinkedIn, YouTube and Twitter, the privacy information of the social media channel you use applies.

11. How long will my data be stored?

 

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BUWOG processes and stores your personal data as long as it is necessary to achieve the purpose for which it was collected. If the data is no longer required to achieve the purpose for which it was collected, it will be deleted, unless its - temporary - (further) processing is required for the following purposes:

 

Legal retention periods

To comply with the (commercial and tax) legal deadlines for storage or documentation from the German Commercial Code and the German Tax Code: These deadlines are up to ten years.

 

Evidence

To preserve evidence within the statutory limitation periods: According to Sections 195 et seq. of the German Civil Code, these limitation periods can be up to thirty years, with the regular limitation period being three years.

In addition, the following applies to data storage with respect to individual operations:

 

Visit the website

Your data is generally deleted as soon as the respective session has ended. Log files are deleted after seven days. Storage beyond this period is possible in exceptional cases. In this case, however, the IP addresses of the users are deleted or alienated so that a linking to the calling client is no longer possible.

 

Contact form

Your data from the input mask on the contact form will be deleted when the respective conversation with you has ended. The conversation has ended when it is clear from the circumstances that the matter in question has been conclusively clarified.

Additional personal data collected during the sending process (e.g. IP address) will be deleted after a period not later than seven days.

 

Application for a property

Your data from the data mask application for a property will be deleted six months after the property concerned has been sold. In addition, your data from the data mask application will be deleted if you have not agreed to a confirmation request from us that we may contact you within 14 days after receipt of the request.

Additional personal data collected during the sending process (e.g. IP address) will be deleted after a period not later than seven days.

 

Newsletter

If you subscribe as a visitor to our website to our newsletters, BUWOG will use the so-called double opt-in procedure described above in section 5. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month.

We rely on your consent to send a newsletter until you revoke your consent. After revocation of consent, your personal data will be deleted after a period of fourteen days at the latest. The revocation does not affect the lawfulness of the processing carried out on the basis of the consent before the revocation.

Additional personal data collected during the sending process (e.g. IP address) will be deleted after a period of seven days at the latest.

12. What data protection rights do I have?

 

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As a data subject you have in particular the following rights under the GDPR ("data subject rights")

 

Right of providing information:

Pursuant to Art. 15 GDPR, you can request information from us as on whether BUWOG processes personal data of you and which data this is.

 

Right to rectify data:

If your data is incorrect, you can request a correction in accordance with Art. 16 GDPR. If your data is incomplete, you can request that it be completed. If BUWOG has disclosed your data to a third party, this third party will be informed about your correction - if this is required by law.

 

Right to erasure personal data:

You have the right to have your data deleted by BUWOG, provided that the requirements of Art. 17 GDPR are met (especially if the purposes for which your data was collected or processed have ceased to apply).

 

Right to restriction of processing:

You have the right to restrict the processing of your data, provided that the requirements of Art. 18 GDPR are met.

 

Right to data portability:

Furthermore, upon your request, we will make your data available to you for further use in accordance with Art. 20 GDPR or transfer it to a recipient to be designated by you.

 

Right to withdraw consent (more details on how to exercise this right for cookies in section 9):

If you consented to the processing of your personal data, you have the right to revoke the given consent at any time with effect for the future, i.e. the revocation does not affect the lawfulness of the processing carried out on the basis of the consent prior to the revocation. The revocation can be made form-free, e.g. by e-mail to datenschutz@buwog.com (in the case of newsletters to newsletter@buwog.com), by sending a message to the contact details provided above in section 3.1 or in the respective imprint of the project website or by pressing the unsubscribe link provided in each newsletter e-mail.

After revocation, BUWOG may only continue to process the personal data to the extent that the processing is still necessary for BUWOG due to legal requirements.

 

Right to object to processing

According to Art. 21 (1) GDPR, you have the right to object at any time to the processing of your personal data that is carried out on the basis of Art. 6 (1) (f) GDPR (data processing for the protection of legitimate interests).

If you object, we will no longer process your personal data for the purposes covered by the objection unless

  • we can demonstrate compelling legitimate grounds that override the interests, rights and freedoms of the data subject, or
  • the processing serves the assertion, exercise or defense of legal claims.

 

If the objection is also or only directed against the processing of your data for direct advertising purposes, we will no longer process your personal data for this purpose.

The objection can be made form-free, e.g. by e-mail to datenschutz@buwog.com or by sending a message to the contact details given above under section 3.1 or given in the respective imprint on the Project Website.

 

Right to lodge a complaint:

In addition, you have the right to lodge a complaint to a data protection supervisory authority (Art. 77 GDPR).

 

However, we recommend that you always first address your complaint to our data protection officer. You can find the contact details of our data protection officer under section 3.2.  

13. Effect of non-communication

 

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If the aforementioned personal data are not provided, BUWOG will not be able to collect such data. In this case, individual purposes described above may not be achieved. For example, your application for a specific property may not be considered.

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