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**Who We Are**

Blue Sky Resort Eforie SRL, with its registered office in the Municipality of Constanta, Strada Veniamin Costache, No. 33, Judet Constanta, with a working point at Strada Meduzei No. 1, Eforie Nord, Constanta, 905350, registered at the Trade Register Office under number J13/925/2018, CUI: RO39184200, email: bskyeforienord@gmail.com, phone number: +40739914704 (hereinafter referred to as “the company” or “the platform” or “the operator”) is a personal data operator.

This policy serves to inform the data subjects about the conditions under which personal data is processed by the company. This policy is valid for all specific activities of the company carried out through the website www.blueskyhoteleforienord.com.

The use of the services offered by the company can only be done after being informed of these policies.

The platform is not intended for minors under 16 years of age and cannot be used by them.

**Definitions**

Within this agreement (as well as in the annexes and other related documents), the mentioned terms will have the meanings specified below:

- **“contract”** – the contract concluded between the parties and its annexes;

- **“personal data of the beneficiary/legal representative/conventional representative”** – all personal data, regardless of their form or medium, which are: (i) provided either by the beneficiary or by the legal or conventional representative of the beneficiary; (ii) provided, derived, or disclosed in writing or verbally by the vehicle insurer subject to repairs or another directly involved insurer or by public institutions/authorities/entities (police stations, courts, etc.);

- **“services”** – the services provided by the provider in accordance with the subject of the contract;

- **“supervisory authority”** – means an independent public authority established by a member state with the competence to oversee the protection of personal data in the EU, within whose jurisdiction the provider, as the operator, or the person authorized by the provider, processes personal data;

- **“processing”** – means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction;

- **“operator”** – the legal person, such as in this case the provider, or a physical person who, alone or jointly with others, determines the purposes and means of processing personal data;

- **“person authorized by the operator”** – means the natural or legal person, public authority, agency, or other body that processes personal data on behalf of the operator;

- **“consent” of the data subject** – means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes, by which they signify agreement to the processing of personal data relating to them, by a statement or by a clear affirmative action;

- **“personal data breach”** – means a breach of security that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed;

- **“regulation”** means Regulation (EU) 2016/679 on the protection of natural persons concerning the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

**General Provisions**

Since we value the confidentiality of your information, the operator is committed to complying with the provisions of this policy, as well as the provisions mentioned in the regulation and the norms provided in national law regarding the processing, security, and confidentiality of personal data.

If we modify this policy, we will notify you on this page and inform you via email or through our platform. If you do not agree with our data privacy policy or do not agree with its modifications, you can close your account by accessing the account settings and selecting account deletion, or you can request the deletion of personal data from the platform.

**Subject, Duration, Nature, Purpose, Type of Personal Data**

**Subject of Processing**

The processing of data of persons who fill out one of the contact forms on the website www.blueskyhoteleforie.com or contact us by phone, in order to request further details or a concrete offer for a specific property being promoted.

**Duration of Processing**

The processing of personal data will be performed: for the duration in which the sale of the property related to the advertisement posted by you has not yet been completed and/or as long as you have an active account on the platform and/or until the moment you request us to no longer process the data contained in your advertisement, but no longer than 3 years from the date processing began upon receiving the advertisement or retrieving it from third-party public sites.

**Nature of Processing**

The processing of personal data is based on the provision of our specific activities, based on the contractual relationship between us or based on a legitimate interest.

**Purpose of Processing**

Serving the legitimate interest of the user of the website plusimobiliare.Ro who requests in writing or by phone a service offer or to buy/rent a property that is in the portfolio of our real estate agency.

**Legal Grounds for Processing**

- Execution of the contract;
- Legal obligation;
- Legitimate interest;
- Consent.

**Type of Personal Data**

Persons using the platform to post advertisements or persons whose advertisements are retrieved from similar public platforms:

- Name and/or surname;
- Email address;
- Phone number;
- Operating system version, unique identifiers;
- The place from which you post the advertisement by identifying the internet protocol (IP) of the device used;
- User sessions, to store language selection preferences and provide you with relevant ads using cookies;
- (Possible) financial data that may include bank account and payment card details (issuing bank, card validity, cardholder, etc.);
- Legal and/or conventional representatives of clients;
- Identification data (name, surname, position);
- Contact data (residential address, phone number, email address).

**Categories of Data Subjects**

**From Whom We Collect Data**

From the data subject when the data is provided directly, for example when filling out a contact form on the website www.blueskyhoteleforie.com.

From third parties such as Google when we receive information regarding the use of our platform.

**Sensitive Personal Data**

Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political opinions, union membership, information about your health, and genetic and biometric data. We do not collect any information about beliefs, sexual life or orientation, political opinions, union membership, health information, genetic or biometric data, or criminal offenses.

In accordance with tax and accounting legislation, we may be required to collect data that may be considered sensitive, such as C.N.P. (Personal Numerical Code), as well as bank account and card details (including issuing bank, card validity, cardholder). The processing of such data may only occur if we are obliged by a legal provision.

**Legal Grounds for Using Personal Data**

The provider will process personal data for:

- Fulfillment of obligations according to the request of the user who contacted us via the contact form or by phone from the website www.blueskyhoteleforie.com.
- When there is a legitimate interest of the company, this legitimate interest cannot prevail over your legitimate interests.
- When we have obtained your consent to send advertising messages via email or SMS, other than messages regarding which you have a direct interest.

Processing of this data, regarding frequency and manner, is:

- At the moment of completing a contact form on our website;
- At the moment we conclude a contract;
- If necessary in our legitimate interests (or those of a third party) and your fundamental rights and interests do not outweigh those interests.
- If we need to comply with a legal or statutory obligation.
- When we send you a notification via SMS or email.
- When we receive information about your visits and interaction with the services provided by other entities when you visit the services of other providers that include ads, cookies, or similar technologies.

**Consent**

Considering the provisions of this policy, it results that we generally do not process sensitive personal data, as defined in the regulation; therefore, your explicit consent is not required.

By completing a contact form on the website or making a phone call through the platform, we consider it to be your legitimate interest to receive periodic notifications from the company via SMS or email regarding advertisements that may be of interest to you. If at any time you believe that your legitimate interest has changed and you no longer wish to receive periodic information, you have the option to express your choice not to receive such messages.

Also, regarding sending communications to you via email or text message, you have the right to express your choice not to receive notifications from us at any time by sending an email to us at bskyeforienord@gmail.com.

We will obtain your explicit consent before sharing your personal data with any third party or sending messages for marketing purposes outside your legitimate interest.

You can request us or you can ask third parties not to send marketing messages at any time by sending us an email at bskyeforienord@gmail.com at any time or by activating the unsubscribe function in the content of the message.

**Modification of Purpose**

The provider will only use personal data for the purpose for which it was obtained, unless it is reasonably necessary to use it for another purpose and the reason is compatible with the original purpose. If you wish to know more about how processing for the new purpose is compatible with the original purpose, please email us at bskyeforienord@gmail.com.

If we need to use your personal data for a purpose that is

 not compatible with the original purpose, we will notify you and explain the legal basis that allows us to do so.

**Rights of Data Subjects**

Regarding your personal data, the following rights are guaranteed to you in accordance with the provisions of the regulation:

- **Right to access**: You have the right to request copies of your personal data. We may charge a small fee for this service.
- **Right to rectification**: You have the right to request that we correct any information you believe is inaccurate or incomplete.
- **Right to erasure**: You have the right to request that we erase your personal data, under certain conditions.
- **Right to restrict processing**: You have the right to request that we restrict the processing of your personal data, under certain conditions.
- **Right to data portability**: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
- **Right to withdraw consent**: If we process your personal data based on your consent, you have the right to withdraw your consent at any time.
- **Right to complain**: If you believe that we have not complied with the regulation, you have the right to make a complaint to the supervisory authority.

To exercise your rights, please contact us at bskyeforienord@gmail.com. We will respond to your request within one month.

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