1.1. The Operator sets compliance with the rights and freedoms of individuals as the primary goal and condition for carrying out its activities in the processing of their personal data, including the protection of the rights to privacy, personal and family secrecy.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website, taking into account all levels of domain names and the domain name welton-realty.com. Key concepts used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking of personal data - the temporary suspension of the processing of personal data.
2.3. Website - a collection of graphic and informational materials, as well as computer programs and databases that provide their availability on the internet at the network address welton-realty.com, taking into account all levels of domain names and the domain name welton-realty.com.
2.4. Personal data information system - a set of personal data contained in databases, along with the information technology and technical means that ensure their processing.
2.5. Depersonalization of personal data - actions that result in the inability to determine the belonging of personal data to a specific User or other subject of personal data without using additional information.
2.6. Processing of personal data - any action (operation) or combination of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website welton-realty.com, taking into account all levels of domain names and the domain name welton-realty.com.
2.9. Personal data allowed by the subject of personal data for distribution - personal data to which an unlimited circle of individuals has access, granted by the subject of personal data through the consent for the processing of personal data, allowed by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as "personal data allowed for distribution").
2.10. User - any visitor of the website welton-realty.com, taking into account all levels of domain names and the domain name welton-realty.com.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific group of individuals.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite group of individuals (transmission of personal data) or making personal data available to an unlimited circle of individuals, including the publication of personal data in mass media, posting in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data - any actions that result in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the information system of personal data and/or the destruction of material carriers of personal data. Principles, objectives, content, and conditions of personal data processing This Policy establishes the procedure for processing personal data of users of the website welton-realty.com, taking into account all levels of domain names and the domain name welton-realty.com (hereinafter referred to as the "Website"), the conditions and principles of personal data processing, the rights of Users, and the obligations of the Operator, as well as information about the implemented measures to protect processed personal data.
3.1. This Policy applies to all personal data that the Operator obtains from Users. The User agrees to this Policy by entering their name, email address (e-mail), and, if necessary, phone number, into the special field on the Website, with an offer to submit a consultation request, register, submit an application, message, or perform other actions provided by the functionality of the Website, and subsequently clicking the "Register," "Submit Application," or other buttons. In case of disagreement with the terms of the Policy, the User must immediately cease any use of the Website. When using the functionality of the Website, the User may provide the Operator with the following personal data (the list and types of personal data depend on the specific functional features of the Internet resource used by the User): last name, first name, email address, contact phone number, photographs, user identification data (user ID). By providing their personal data, the User agrees to their processing (until the User withdraws their consent to the processing of personal data), including collection, storage, depersonalization, and transfer to third parties in cases provided by the Policy, by the Operator for the purpose of providing the User with payment options, advertising, reference information, services in accordance with the functional features. The User's consent to the processing of personal data provided by the User is valid from the date of granting such consent until the achievement of the processing purposes or until the User withdraws their consent, unless otherwise provided by applicable law. The User may revoke the consent provided to the Operator at any time in the manner specified in this Policy. If the User wishes to clarify their personal data in cases where the personal data is incomplete, inaccurate, or outdated, or wishes to withdraw their consent to the processing of personal data, the User should send an official request to the Operator with the subject line "Clarify personal data" or "Cease processing personal data" to the email address info@welton-realty.com. The email should include the User's email address and the corresponding request. The email itself must be sent from the registered email address on the Website. The Operator uses the personal data provided by the User for the following purposes:
8.1. User registration and identification on the Website, providing the User with the opportunity for full use of the Website;
8.2. further communication regarding the User's request, including with third parties - partners of the Operator to fulfill obligations related to the User's request, consulting on services provided by the Operator;
8.4. sending informational messages;
8.5. advertising and promotion of goods, work (services), including based on the received information about the User's personal preferences and settings;
8.6. evaluation and analysis of the Operator's Website performance;
8.7. analysis of the effectiveness of advertising placement, statistical research based on deidentified information provided by the User;
8.8. informing the User about promotions, discounts, and special offers through email newsletters, telephone communication;
8.9. conducting marketing research, including involving third parties as contractors (executors, consultants). The Operator does not verify the data provided or indicated by the User. Therefore, the Operator assumes that when providing personal data, the User:
9.1. Is a capable person. In the case of incapacity of the person using the Website, the consent to the processing of personal data is provided by their legal representative.
9.2. Provides accurate information about themselves (or about the incapacitated person they represent). The User is responsible for keeping the provided personal data up to date. The Operator processes personal data based on the following principles:
10.1. Legality.
10.2. Limitation of personal data processing to achieve specific predefined lawful purposes.
10.3. Prevention of personal data processing that is incompatible with the purposes of collecting and/or storing the data.
10.4. Compliance of the content and volume of processed personal data with the purposes of their processing.
10.5. Avoidance of processing excessive data compared to the purposes of processing.
10.6. Ensuring the accuracy, sufficiency, and relevance of personal data in relation to the purposes of their processing.
10.7. Destruction or depersonalization of personal data to prevent their disclosure upon achieving the processing goals, loss of the need for such processing, or upon receiving a User's request for the destruction of personal data or withdrawal of consent to the processing of personal data. The Operator takes necessary and sufficient organizational and technical measures to protect personal data from unauthorized access and other unauthorized actions with regard to personal data during their processing. The processing of Users' personal data by the Operator takes into account the following:
11.1. Processing of personal data is carried out both with and without the use of automated means. 11.2. The Operator undertakes not to disclose the information received from the User to third parties, except as expressly provided in this Policy. The transfer of Users' personal data to third parties, who are partners of the Operator, is carried out based on the Users' consent for the purpose of fulfilling obligations to Users.
11.3. If it is necessary to transfer Users' personal data to third parties who are partners of the Operator, these parties undertake to keep such data confidential, not to disclose or distribute personal data without the User's consent, unless otherwise provided by applicable law and/or this Policy.
11.4. The storage of Users' personal data is carried out on electronic media and, for the purpose of fulfilling obligations to Users, may also be carried out on physical media after extracting the personal data.
11.5. The storage of personal data is limited to the period objectively necessary to fulfill obligations to Users and is determined by the following events (whichever occurs earlier): 11.6. Until the personal data is destroyed by the Operator due to a User's request for the destruction of personal data or withdrawal of consent for their processing. 11.6.1. Until the expiration of the User's consent period.
11.7. The Operator has the right to store Users' personal data, except in cases of receiving a request for data destruction or withdrawal of consent for data processing, in de-identified form after fulfilling obligations to the User for the purposes specified in section 8.7 of this Policy. When it is necessary to transfer Users' personal data to third parties who are partners of the Operator in cases explicitly provided by the Policy, such transfer is carried out with compliance to the following conditions:
12.1. The third party, being the Operator's partner, ensures the confidentiality of personal data during their processing and use, undertakes not to disclose the data to other parties, and refrains from disseminating Users' personal data without their consent.
12.2. The third party, being the Operator's partner, guarantees compliance with the following security measures for the processing of personal data: the use of information security means; detection and recording of unauthorized access to personal data and taking measures to restore personal data; restriction of access to personal data; control and assessment of the effectiveness of applied measures for the security of personal data, as well as other measures provided by legislation. The Operator has the right to use the "cookies" technology. Cookies are data automatically transmitted to the Operator during the use of the Website through software installed on the User's device. This includes the IP address, geographic location, information about the browser and operating system of the User's device, technical specifications of the equipment and software used by the User, and the date and time of access to the Website. Cookies do not contain confidential information. Cookies are used to remember User preferences and settings, as well as to collect analytical data about visits to the Website. By using the Website, the User agrees to the use of all cookies and the transfer of analytical data about visits to the Website to third parties. The Operator receives information about the User's IP address and information about the internet site from which they came through a link. This information is not used to determine the visitor's identity