Customer Information Notice

BEN PROPERTY MANAGEMENT SRL

Preliminary Aspects The purpose of this Information Notice is to explain to you what data we process, why we process it, and what we do with it in your capacity as a natural person client or as a representative or contact person within a legal entity client of our company, as well as in our capacity as a data controller. Also, by going through this document, you will know your rights and how you can legally exercise them. We take your privacy seriously and never sell lists or email addresses. Fully aware that your personal information belongs to you, we make every effort to store it securely and process it carefully. This information is important. We hope you read it carefully. 

About Us BEN PROPERTY MANAGEMENT SRL, a Romanian legal entity, with headquarters at 35 Eroilor Street, Apt 1, Sibiu, Sibiu County, managed by Andrei Benchea, email: andrei.benchea@benapartments.ro, is responsible for processing your personal data that we collect directly from you or from other sources.

According to the law, our company is a personal data controller. To ensure that your data is processed securely, we have made every effort to implement reasonable measures to protect your personal information. Who Are You? According to the law, you, the natural person client or the representative or contact person within a legal entity client of our company, are a “data subject”, meaning an identified or identifiable natural person. To be completely transparent about data processing and to allow you to easily exercise your rights at any time, we have implemented measures to facilitate communication between us, the data controller, and you, the data subject. Our Commitment to Personal Data Protection Protecting your personal information is very important to us. Therefore, we are committed to complying with European and national legislation regarding the protection of personal data, especially Regulation (EU) 679/2016, also known as GDPR, and the following principles: Legality, fairness, and transparency We process your data legally and fairly. We are always transparent about the information we use, and you are adequately informed.

You are in control Within the limits of the law, we offer you the possibility to examine, modify, delete the personal data you have shared with us, and to exercise your other rights.

Data integrity and purpose limitation We use data only for the purposes described at the time of collection or for new purposes compatible with the original ones. In all cases, our purposes are compatible with the law. We take reasonable measures to ensure that personal data is accurate, complete, and up-to-date.

Security We have implemented reasonable security and encryption measures to protect your information as much as possible. However, please note that no website, application, or internet connection is completely secure.

Changes We may change this Information Notice at any time. All updates and modifications to this Information Notice are valid immediately after notification, which we will provide by posting on the website/at the company’s headquarters/workplace and/or by email notification and/or by other methods accepted by law. Questions and Requests If you have any questions or concerns about the processing of your data or if you want to exercise your legal rights regarding the data we hold, or if you have concerns about how we handle any privacy issues, you can write to us at the email address: andrei.benchea@benapartments.ro Personal Data What kind of personal data do we collect? Name and Surname

Address

Age

Citizenship

CNP (Personal Numerical Code)

Company Name (where applicable)

Authentication data (PIN password)

Authentication data (username)

Credit/debit card details

Date of birth

Picture

Email address

IBAN

Phone number(s) (contact)

Series and number of identity card, passport, and/or driver’s license

Why do we collect this information? We collect your information for specific and legitimate purposes, including but not limited to the following:

To conclude or execute a contract between you and us; To respond to your inquiries and requests; To provide and improve the services and products we offer; To comply with the law; For asserting or defending a right in court; For maintaining the business relationship between us. Legal grounds for processing Processing is necessary for the conclusion and/or execution of a commercial contract; Processing is necessary for our legitimate interests, but only where our interest outweighs your rights and interests. Processing is necessary to fulfill a legal obligation. In certain situations, data processing is necessary to fulfill a legal obligation, such as keeping financial documents for a period of 10 years.

Processing is necessary for our legitimate interests, but only where our interest prevails over your rights and interests, such as video surveillance through CCTV. Where we use legitimate interest, we conduct a legitimate interest assessment (balancing test) through which we can balance our interest and your interests. Where our interests prevail, we will use legitimate interest. Where your interests prevail, we will not use legitimate interest, and to the extent that we fail to identify another correct legal basis, we will not carry out that processing activity.

In some situations, processing may be necessary to protect your vital interests or those of another natural person.

Please note that obtaining consent is not mandatory, and we will only obtain your consent in situations where we cannot use another legal basis.

How long do we keep personal information? We store personal data only for the period necessary to fulfill the purposes, but not more than 5 years from the termination of the contract or the last interaction with us. After the end of the period, personal data will be destroyed or deleted from computer systems or transformed into anonymous data for use in scientific, historical, or statistical research purposes. Please note that in certain expressly regulated situations, we store data for the period imposed by law, such as keeping accounting documents for a period of 10 years. How do we transmit your information? We may disclose your data, respecting the applicable law, to business partners or other third parties, such as companies seeking personnel, accounting firms, human resources firms, public authorities (ITM), etc. We constantly make reasonable efforts to ensure that these third parties have implemented adequate protection and security measures. With these third parties, we have contractual clauses so that your data is protected. We will inform you about the identity of these companies before transmission or within a reasonable time and ensure that any transfer is legitimate, based on your consent or other legal basis. For example, we could provide your data to other companies, such as IT or telecommunications service providers, accounting, legal services, and other third parties with whom we have a contractual relationship. These third parties are carefully selected so that your data is processed only for the purposes we indicate. Also, we could share your data with business partners as a result of a joint effort to provide a product or service. Although unlikely, we could sell the business or part of the business in the future, a situation that will include the transfer of your data. We may transfer data to other parties with your consent or according to your instructions. We may also provide your personal information to the prosecutor’s office, police, courts, and other competent state bodies, based on and within the limits of the law and as a result of express requests. We will ensure, to a reasonable extent, that your data does not leave the European Economic Area; however, to the extent that we transfer data to countries outside the EEA, we will ensure, in all cases, that the transfers are legitimate, based on your explicit consent or other legal basis. What are your rights? Your rights under the GDPR are as follows:

Right to withdraw consent Right to be informed about the processing of your data Right of access to the data You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed and, where that is the case, access to that data and the information provided for in Art. 15 (1) of the GDPR.

Right to rectify inaccurate or incomplete data You have the right to obtain from us, without undue delay, the rectification of inaccurate personal data concerning you.

Right to erasure (“right to be forgotten”) In the situations provided for in Art. 17 of the GDPR, you have the right to request and obtain the erasure of personal data.

Right to restriction of processing In cases provided for in 18 of the GDPR, you have the right to request and obtain the restriction of processing. Right to data portability In cases provided for in Art. 20 of the GDPR, you have the right to request and obtain data portability.

Right to object to data processing In cases provided for in Art. 21 of the GDPR, you have the right to object to the processing of data.

Right not to be subject to a decision based solely on automated processing, including profiling Right to appeal to justice Right to lodge a complaint with a Supervisory Authority Please note that:

If you want to exercise your rights, you can do so by sending a written, signed, and dated request to the email address: info@benapartments.ro The rights listed above are not absolute. There are exceptions, so each request received will be analyzed to decide whether it is justified or not. If the request is justified, we will facilitate the exercise of the rights. If the request is unfounded, we will reject it, but we will inform you of the reasons for the refusal and of the rights to lodge a complaint with the Supervisory Authority and to appeal to justice. We will attempt to respond to the request within 30 days. However, the deadline may be extended depending on various aspects, such as the complexity of the request, the large number of requests received, or the inability to identify you within a reasonable time. If, despite our best efforts, we cannot identify you, and you do not provide us with additional information to identify you, we are not obliged to comply with the request. Questions, requests, and exercising rights If you have any questions or concerns about the processing of your information or if you want to exercise your legal rights or have any other concerns about confidentiality, you can write to us at the email address: andrei.benchea@benapartments.ro