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Privacy Policy

The security and privacy of your information is of paramount importance to us at EMPIRICA Business Solutions, a global consulting company specializing in providing advisory services in the areas of business sale-purchase, mergers and acquisitions, exit strategies for family businesses and global consulting. Through this Privacy Policy, we are committed to protecting your privacy and ensuring that your personal information is handled with the utmost care and responsibility.

The following notice is designed to make you aware of the aspects of the processing of your personal data and your rights regarding such processing under:

Act No. 133 of 08.07.2011 on the protection of personal data, published on 14.10.2011 in the Official Gazette No. 170-175 art. 492, amended by Parliament Act No. 155 of 15.07.2022, published on 05.08.2022 in the Official Gazette No. 246-250, in force from 05.09.2022.

1. GENERAL INFORMATION

We, EMPIRICA Business Solutions (hereinafter the ”Company”) represent the controller in accordance with the General Data Protection Regulation (hereinafter – ”GDPR”).

2. PURPOSE OF PROCESSING AND CATEGORIES OF DATA PROCESSED

In this regard, the purposes for which personal data are processed by the Company are as follows:

  • providing business sale-purchase intermediation services;
  • mergers and acquisitions;
  • exit strategies for family businesses;
  • global consultancy.

In order to fulfil the purposes of the consultancy field, the Company processes personal data in the following operations:

  • the drafting of documents required for consultancy contracts with our clients, at all stages;
  • the drafting of the documents necessary for the preparation of the materials required for the promotion of our clients and the provision of consultancy services, at all stages;
  • regular transmission of information and commercial offers via newsletter/e-mail/promotional material;
  • maintaining internal databases;
  • accurately identifying clients when they want a service to be provided;
  • providing information on Company events;
  • participating in surveys on the Company’s offerings and services in relation to customer satisfaction;
  • soliciting and using information on business presented to customers from various public sources.

The following categories of data are processed within the Company:

  • Surname, first name, domicile/residence, series and number of identity document, IDNP, nationality, date of birth, e-mail address, phone and/or mobile phone numbers, fax number (where applicable), data resulting from business ownership documents (including history and extracts from relevant state authorities);
  • Customer contact with the Company, such as registration on the website, a forwarded email or letter, or other records of contact with the Company;
  • Customer account information, such as account numbers or other information related to the customer’s account or that is included in the business relationship management contract with each customer;
  • Legitimate Access Information – The Company will collect passwords, indices and similar security information used for authentication and access to accounts and services (for online accounts opened by each customer on the Company’s website);
  • Customer preferences for particular products and services when customers let the Company know what they are, or when the Company assumes what they are, based on how customers use the Company’s products and services; in this way the Company will be able to prioritise what the customer is interested in;
  • Marketing preferences;
  • See the Cookies section for details on what the Company collects using cookies;
  • Browsing history. If permission is given, the Company collects categories of websites that website guests have browsed from their mobile phone, device or PC, e.g. news. However, the Company will not hold a history of the websites that Company web page guests browse, this is limited to a short period of time to enable the connection to be made. The Company uses this interest information to send personalized marketing offers or display advertisements. Visitors can opt-out of advertisements under the Cookies section on the Company’s website or, in the case of marketing, through unsubscribing by accessing the first newsletter received.
  • Information that the Company obtains from other sources, such as public or private authorities, fraud prevention agencies, and other data providers. This includes demographic data, interest data, and browsing behavior.
  • For the loyalty program consisting of offering benefits, discounts, rebates to reward loyalty;
  • Answers to invitations and confirmations of participation in events.

The personal data we process is primarily identification, transactional, financial, demographic, location or other personal data that we collect directly from you or from other sources when you become our customer or use our products or services.

Sensitive personal data reveals your racial and ethnic origin, political opinions, religious and philosophical beliefs, genetic data, biometric data, health data, or data about your life or sexual orientation.

THE COMPANY DOES NOT INTENTIONALLY COLLECT SENSITIVE PERSONAL DATA FROM YOU FOR STORAGE.

The legal basis for collecting and processing your data for each of the purposes mentioned above is:

  • Contracts for the provision of consultancy services as well as contracts with third parties to which you are a party or your request prior to entering into a contract.
  • Legitimate business interests of the Company, e.g. preventing fraud, maintaining the security of our services, direct marketing and improving services. Whenever we rely on this legal basis to process your data, we assess our business interests to ensure that they do not override your rights. In addition, in some cases you have the right to object to such processing. The legitimate interest of the Company to enable us to exercise our statutory rights in our favour, to take legal action against any unlawful or damaging activity against the Company.
  • Compliance with a mandatory legal requirement, for example, accounting and tax requirements, which are subject to strict internal policies (such as storage periods), procedures, and the right to restrict the use of our own data, which controls the scope of our services to be provided.
  • In addition, to the extent you have agreed, this constitutes your consent. The processing of personal data on the basis of consent is an additional purpose to the processing of personal data for the performance of the contract to which you are a party and does not determine the provision of services.
  • The processing is necessary for the performance of a task which is of public interest.

We will collect your personal data when, for example:

  • You use any of our services;
  • You register for a particular service;
  • You subscribe to our newsletter or other services;
  • You contact us through various channels, or request information about a service;
  • You visit or browse our website;
  • You have given permission to other companies, such as our business partners or associates, as well as third party suppliers or contractors of ours, to exchange information with us for the purpose of providing services to you;
  • When personal data is public; or

You are the customer/beneficiary of a business activity we provide.

We also collect information from certain companies where appropriate and to the extent that we have legal grounds to do so. These include fraud prevention agencies, trade directories, verification/control agencies, billing agencies and contracted service providers.

We use cookies (small text files stored in your browser) and other techniques such as web beacons (small, transparent image files used to track your movements around our site). For further details on this and how to opt-out of these, please see the Cookies section of our website.

4. CATEGORIES OF RECIPIENTS TO WHOM PERSONAL DATA COLLECTED MAY BE DISCLOSED

In order to achieve the purposes set out above, we use the following categories of product and service providers/processors:

  • providers (property owners) directly/indirectly involved in the provision of services in the real estate sector;
  • state authorities (including tax authorities);
  • accountants, auditors, legal experts, lawyers or other such external advisors of the Company or to third parties providing products and services to the Company (providers of security services, IT systems, financial consultants);
  • Company suppliers directly/indirectly involved in the marketing and promotion process.

5. STORAGE PERIOD

Your personal data will be kept by the Company for a period not exceeding the period necessary to achieve the purposes described above and/or for any other period required by virtue of the legal obligations applicable to the Company, using the following criteria for determining this period:

  • When you purchase property rights through the Company, we keep your personal data for the duration of our contractual relationship;
  • When you participate in a promotional offer, we keep your personal data for the duration of the promotional offer;
  • If you contact us for the provision of a service, we keep your personal data for the time necessary to process your enquiry, but no longer than 10 (ten) years from the last correspondence sent, for tax purposes;
  • If you have registered on our website, we keep your personal data until you request that we delete it or after a period of inactivity (no active interaction with us). In this regard, we note that the data processed for this purpose will be deleted 5 (five) years after the last interaction;
  • If you have given your consent for marketing, we keep your personal data until you unsubscribe or request that we delete it or after a period of inactivity (without an active interaction with our brands) defined in accordance with the regulations and guidelines. In this regard, we note that data stored in our databases for the purpose of direct marketing communications is deleted from the records of these databases 10 (ten) years after your last interaction with us;
  • If cookies are stored on your computer, we keep them for as long as necessary for them to achieve their purposes (e.g. for the duration of a session for shopping cart cookies or session ID cookies) and for a period defined in accordance with the regulations and guidelines, we mention that the data processed through cookies used to provide online behavioural advertising, to personalise our services for you and to enable the distribution of our content on social media sites (distribution buttons intended to display the site) will be kept for a maximum period of 10 (ten) years from their collection, based on your consent.

6. YOUR RIGHTS

The Regulation confers certain rights to the persons whose personal data are processed. Thus, in addition to the existing rights, there is also the right to data portability and the right to erasure of data. Thus, your rights include:

  • The right to withdraw at any time a consent given in order to stop a data processing based on your consent. Withdrawal will not affect the lawfulness of processing based on consent given prior to withdrawal, for the performance of a contract, to fulfil a legal obligation or to pursue our legitimate interests.
  • The right of access – means that you have the right to obtain confirmation from us whether or not we are processing personal data about you and, if so, you have access to that data and information on how that data is processed.
  • The right to data portability – refers to the right to receive personal data in a structured, commonly used and machine-readable format by us, and the right to have such data transferred directly to another controller if technically feasible.
  • The right to object – refers to your right to object to the processing of personal data when the processing is necessary for the performance of a task carried out in the public interest or in the legitimate interest of the controller. Where the processing of personal data is for the purposes of direct marketing or processing carried out on the basis of express consent, you have the right to object to the processing at any time.
  • The right to rectification – refers to the correction, without undue delay, of inaccurate personal data. The rectification will be communicated to each recipient to whom the data was transmitted, unless this proves impossible or involves disproportionate efforts.
  • The right to data erasure (“right to be forgotten”) – means that you have the right to ha data erased, without undue delay, if one of the following grounds applies: your personal data are no longer necessary in relation to the purpose for which it was collected or processed; you withdraw your consent to the processing and there is no other lawful basis for processing the data; you object to the processing and there is no overriding legitimate grounds for continuing the processing; your personal data have been unlawfully processed; your personal data have to be erased in order to comply with a legal obligation; your personal data have been collected in relation to the provision of information society services.
  • The right of restriction of processing – can be exercised if the individual contests the accuracy of the data for a period necessary to verify the accuracy of the data; the processing is unlawful and you object to the deletion of the personal data and request restriction instead; if the Company no longer needs the personal data for the purpose of the processing, but the individual requests it for the establishment, exercise or defence of legal claims; if the individual has objected to the processing for the period of time during which it is verified whether the legitimate rights of the controller prevail over those of the individual.
  • To exercise these rights, as well as for any further questions regarding this information or in relation to the Company’s use of personal data, please contact our Data Protection Officer by choosing any of the communication methods described below.

You can contact us at: …info@dev.empiricabs.com

By using our services, you agree to the provisions of this Privacy Policy. If you have any questions or concerns about our handling of your personal information, please contact us at …@dev.empiricabs.com.

Thank you for your trust to EMPIRICA Business Consulting in the management of your personal information.