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    Privacy Policy

    Dear customers,

    This Privacy Policy applies to your use of any products, services, content, features, technologies or functions and all websites, mobile applications, mobile sites or other online products or applications offered to you by us (collectively, the "Services").

    We are committed to protecting your personal data. This Privacy Policy informs you about how we handle your personal data, your rights in relation to data privacy and how you are protected by law. Please read this Privacy Policy carefully before using our Services.

    CONTENTS

    Who are we?What data do we collect about you yours?Do we collect data relating to minors?What are the reasons for which we process your personal data?The purposes for which we use your dataHow to be informed about changes to our Privacy PolicyYour rightsCommunicationWith whom do we share your dataInternational transfersWhere do we store your data and for how long?Technical and organizational measures and security of processingLinks to third-party websitesContact detailsData Protection Authority

    1. Who are we?

    S.C. First Digital Imobiliare S.R.L. is the main controller of your data for the purposes of the services provided, a Romanian legal entity with its main office in Bucharest, with its registered office in Bucharest, Lt. Radu Beller Street, no. 3-5, registered with the Trade Register Office attached to the Bucharest Court under no. J2024051390000, CUI 51078640, which provides you with the respective services in accordance with our Terms and Conditions of Use, hereinafter referred to as "FIRST" or, collectively, "we" or "our" in this Privacy Policy. The relevant contact details can be found in section 14.

    2. What data do we collect about you?

    2.1.1 Data obtained from direct interactions

    Registration and other account information. When you register to use our Services, we may collect the following information about you:

    • if you register directly on our platform, you will be asked to provide your email address;

    • if you register using your Google account: your first and last name, email address, and the URL to your Google profile photo;

    • if you register using your Facebook account: your first and last name as it appears on your Facebook account, the email address associated with your Facebook account, your Facebook ID, and the URL to your Facebook profile photo;

    • if you register using your Apple ID: your first and last name and email address.

    In depending on the choices you make during the authentication for our Services or during the contracting process for our Services, you may choose to provide us with the following additional personal data:

    • your name;

    • home address;

    • mobile phone number;

    • your payment details;

    • your country and region (County);

    • your city (and sector - for Bucharest Municipality);

    Validity of your account:

    To create your account, you will be asked for your phone number or email address. To complete, you will be asked to enter a code received either by SMS or by email (depending on the method chosen to create your account).

    For publishing/posting ads, we validate our users' accounts only if both the phone number and the email address provided have been verified via SMS and/or code received to the email address, to ensure that each account is associated with a real and unique user.

    This validation process is free and is initiated before the ad listing is published on our Services.

    2.1.2 Data we automatically collect when you use our Services

    When you use our Services, we automatically collect the following information about you:

    Information about the devices used

    We collect specific information about the devices used, such as the operating system version or unique identifiers. For example, the name of the mobile network you are using, your IP address, your device language settings, device make and type, device operating system and version, browser type and version, and specific software information.

    Location Information

    Depending on the permissions granted by your device, if you post any ads through our Services, we automatically collect and process information about your actual location.

    Clickstream Data

    We collect information about your activity on our Services, including the websites from which you accessed our Services, the date and time stamp of each visit, the searches you performed, the ad listings or banner ads you clicked on.

    2.1.3 Data from third parties or publicly available sources

    We receive your data in the form of personal information from various third parties and publicly available sources, which we may combine with or connect to the personal information we collect from you through our Services.

    3. Do we collect data from minors?

    Our Services are not directed to children under the age of 16 and we do not knowingly collect data from anyone under the age of 16. If we become aware that a person under the age of 16 has provided us with personal information, we will delete that information without delay.

    4. What are the reasons for which we process your personal information?

    We will only use your personal information where the law permits us to do so. Most commonly, we will use your personal information in the following circumstances:

    • where we need to perform the contract that we are about to enter into or have entered into with you;

    • where this is necessary in accordance with our legitimate interests and where we consider that our legitimate interests are not overridden by your interests or those of other data subjects or your fundamental rights and freedoms, for example, to improve our Services and to enhance the safety and security of our Services;

    • where we need to comply with a legal or regulatory obligation.

    In certain circumstances, we may also process your personal data based on your consent. In this case, we will inform you of the purpose and category of personal data that will be processed at the time we ask for your consent.

    We provide you with a description of the reasons why we use your personal data and the legal grounds we rely on we invoke when we do so. We have also identified our legitimate interests, where applicable.

    To provide you with and provide you with the Services

    If you log in using your mobile number or email ID, we use your first and last name, mobile number and/or email address to identify you as a user and to grant you access to our Services.

    If you log in using your Facebook or Google account, we use the first and last name and email address associated with that account, as well as the URL to your profile photo, to identify you as a user of our Services and to grant you access to our Services. The above authentication data is also used by us to provide our Services to you in accordance with the Terms and Conditions.

    We use third-party payment service providers to process any payments you make in connection with our Services. Depending on the payment method, you may be asked to provide us with your payment and credit/debit card details, which we will then pass on to the payment service provider to process your payment. We do not store your credit card information unless you choose to save this information to make recurring payments easier without having to re-enter your details each time. In such cases In some cases, we only store the cardholder name, card expiration date, card type, and the first and last four digits of your card number. We do not store any credit card verification code values ​​and only transmit such values ​​and your credit card number in an encrypted manner for the purpose of processing your payments to the payment service provider.

    We process the information mentioned above for the proper performance of our contract with you.

    To improve your experience with our Services

    We use clickstream data to:

    • to provide you with personalized content, such as providing more relevant search results when you use our Services; and

    • to determine how much time you spend on our Services and how you navigate within our Services in order to understand your interests and to improve our Services based on this data. For example, we may make suggestions about content you might visit based on the content you clicked on.

    If you choose to provide us with your location data, we use this data for the following purposes:

    • to compile anonymous and aggregated information about the characteristics and behavior of users of FIRST services, including for the purposes of analyzing, segmenting, and developing anonymous profiles;

    • to improve the performance of our Services and to personalize the content we deliver to you. For example, we use location data to display listings of ads that are in your vicinity to improve your shopping experience. In this regard, Google Maps is integrated into our Services. Google Maps is provided by us and Google, acting as independent data controllers. This means that both Google and we are responsible for the processing of your location data in the context of Google Maps. In any case, we will not process your location data for any purpose other than as explained in this Privacy Policy. However, Google may process such location data for its own purposes, as explained in Google's Privacy Policy, which can be found here. Your use of the Google Maps application through our Services is subject to the Google Maps Terms of Service.

    Using the contact information in your account, which includes your email address and mobile phone number, we map the different devices (such as desktops, mobile phones, tablets) you use to access our Services. This allows us to associate your activity on our Services across these devices and helps us provide you with a seamless experience, regardless of the device you use.

    We use the images you upload, descriptions, and prices you provide in your ad listings to:

    • train machine learning models to personalize search results based on ad rank and user interest, to improve the identification and presentation of items in ads, improve search functionality, and increase the likelihood of facilitating a successful transaction. This helps us improve our Services and provide you with a seamless experience. improved as a user.

    To display and provide you with recommendations on ad listings within our Services that may be of interest to you:

    • we use algorithms that use information about your browsing behavior, property types, clickstream data, your user ID and location data, the type of ad added to "Favorites". We use this form of automated decision-making based on our legitimate interest in improving our Services and providing an improved user experience by providing more relevant ad listings.

    Within our Services, in the "Candidate Profile" section, you have the opportunity to complete a candidate profile, in which you voluntarily provide personal data, such as: your name, date of birth, contact details, education and work experience history, as well as skills and your interests.

    We store this data to provide you with our Services, at your discretion, until you decide to delete it, but at most until you delete your user account.

    We access and analyze your communications with other users via the chat feature of our Services to:

    • improve the products and provide you with an enhanced user experience (e.g., to identify products sold and to provide you with only active listings). Therefore, we develop and train machine learning models and algorithms to automatically analyze the content of your chat communications. In order to build and train our machine learning models, our machine learning specialists may manually analyze samples of the content of chat messages. In these circumstances, highly restrictive access rights are granted to selected machine learning specialists "automatically analyzes the content of chat communications. As part of this analysis process, we anonymize the content of communications as much as possible by applying a scanning filter to detect and hide personal data, such as names, phone numbers, or email addresses. However, there may still be cases beyond our control where the content of communications could display certain personal data that you have chosen to provide.

    Using the identifier (a random identification code assigned to you when you download our mobile application):

    • we will occasionally send you user surveys designed to determine your level of satisfaction with the quality of our Services. When we send you a survey, we may also ask for your email address or mobile phone number to contact you and invite you to participate in user experience tests or an interview with our team.

    In order to measure the level of user satisfaction with their trading experience and to ensure an optimal and efficient level of communication between users, as well as to verify and prevent inappropriate actions and behaviors in the context of the activity carried out in connection with our Services, we collect information regarding:

    • ratings and feedback regarding user interactions in connection with our Services, this information allowing us to take necessary and appropriate measures to maintain high standards in the provision of our Services.

    We process the information mentioned above for the proper performance of our contract with you and based on our legitimate interest in improving your experience of using our Services.

    To ensure the safety and security of the Services

    We use your mobile phone number, login details and unique device identifiers for the purposes of administering and protecting our Services (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support services, reporting and data hosting).

    We access and analyse your communications with other users that you have via the chat function within our Services to check customer satisfaction, for security reasons and for fraud prevention purposes (e.g. to block spam or abusive messages that may be sent to you by other users). Therefore, we develop and train machine learning models and algorithms to help us automatically detect and prevent inappropriate or fraudulent user behavior. During the analysis and training process, we anonymize the content of chat communications to the extent possible by anonymizing the unique identifiers assigned to users. However, there may still be cases beyond our control where the content of chat communications may reveal certain personal data that you have chosen to provide. Only in limited cases and circumstances do our customer safety and security specialists manually review the content of chat communications, for example, if we have strong indications that lead to suspicions of fraudulent activity. In these situations, extremely strict access rules apply to selected customer safety and security specialists who review the content of chat communications.

    To prevent and detect fraud in within our Services

    We use algorithms capable of recognizing suspicious or fraudulent user behavior based on certain information such as user activity and published content, which may lead us to ban certain user accounts. Automatic banning occurs when there is an extremely high level of certainty that an account or action is fraudulent. Otherwise, an analysis is performed by the human factor, namely by specialists responsible for customer safety and security, based on extremely restrictive access rights. We use this form of automated decision-making based on our legitimate interest in detecting and preventing fraud and maintaining the safety and security of our Services for users. If you believe that your account has been banned unjustifiably, you can contact us via [email protected] in which case our team will review the decision to ban your account.

    We collect certain information from and about the electronic device you use to access our Services based on our legitimate interest in preventing fraud on our Services. The information we collect includes your user ID (depending on whether you are logged in or not), FIRST country domain, IP address, device settings such as language, device make and type, device operating system and version, browser type and version, and specific information about the device software, such as fonts, system and browser time zone, and available video and audio formats. Device information is used to determine whether the same device is used when users interact with our Services. We associate this information with a fraud score for the user, based on which we may ban certain users. For more information on this topic, please see our Cookie and Similar Technologies Policy. If you believe your account has been banned unjustifiably, you can contact us by email at: [email protected], in which case our team will review the decision to ban your account.

    We process the information mentioned above for the proper execution of our contract with you and based on our legitimate interest in preventing fraud and improving the overall quality and effectiveness of our Services.

    To promote and offer you Services that may be of interest to you.

    We use your email address and mobile phone number (via SMS) to provide you with suggestions and recommendations regarding our Services that may be of interest to you.

    To send you email communications through which we may provide you with suggestions and recommendations regarding ad listings or our Services, we use algorithms capable of using information based on your clickstream data. We will always give you the opportunity to opt out of such communications by including an unsubscribe link. We use this form of automated decision-making based on our legitimate interest in improving our Services, increasing the number of transactions on our Services, and providing an enhanced user experience by providing more relevant ad listings.

    We use clickstream data to monitor and report on the effectiveness of our campaigns for our business partners and for internal business analysis.

    If you choose to provide us with your location data, we may use this data to measure and monitor your interactions with third-party banner ads we place on our Services.

    We process the information mentioned above based on our legitimate interest in conducting marketing activities to provide you with Services that may be of interest to you. Specifically, you may receive certain marketing communications from us:

    • by any preferred means of communication, if you have requested such information from us;

    • by email, regarding similar products and services, if you already use our Services or have purchased some of our products;

    • by telephone or email, where you provided us with your details when you entered the competition; or

    • by telephone or email, where you registered for a particular promotion.

    You can ask us to stop sending you such marketing communications at any time by clicking on the unsubscribe link in the email message sent to you or by changing the notification settings in your account.

    In other situations than those mentioned above, we will use your email address and mobile phone number to send you direct marketing communications (by email, push notifications, SMS or phone calls), where you have given us consent to do so by ticking the relevant box when registering for our Services. You can change your mind at any time and withdraw your consent via your FIRST account settings.

    If you encounter any problems changing your notification settings, please contact us using email: [email protected]

    In order to provide you with quality customer support services:

    • we record your telephone conversations with members of the customer relations team or members of the sales team only subject to your explicit consent;

    • if you agree to participate in our customer interaction studies occasionally organized by FIRST, we will make a video recording of your interaction with our team in order to improve our Services.

    We process the personal data mentioned above for the purpose of an in-depth analysis of your interaction with members of our customer relations team or sales team (as applicable) and to improve the way where our team members serve customers.

    You can withdraw your consent at any time and free of charge using the instructions on www.first.ro or by email: [email protected]

    5. Purposes for which we use your data

    To ensure access to the Services

    • To identify and authenticate you as a user

    • To process payments when you use our paid services

    • To provide services in accordance with the Terms and Conditions

    To improve your experience

    • Personalizing content and search results

    • Analyzing how you use our Services

    • Improving functionalities and performance

    To ensure security

    • Fraud prevention and detection

    • Protecting your account and personal data

    • Ensuring compliance with legal requirements

    For communication and marketing

    • Sending important notifications about the services

    • Providing personalized recommendations

    • Informing about updates and changes to the services

    We process this data only based on our legitimate interests and with respect for your fundamental rights and freedoms. You can always exercise your rights regarding personal data according to the section on your rights.

    FIRST DIGITAL IMOBILIARE is not responsible for the lawfulness of the processing of users' personal data when our users agree to provide certain such data, requested by the respective professional user, when using the way to interact with it - made available by the professional user (link, email address, phone number, etc.)

    The obligation to provide reliable information regarding the rules for using the links made available, the security policy, as well as other information provided by applicable legislation, in particular the provisions relating to the protection of personal data, lies with each professional user.

    6. How we will notify you of changes to our Privacy Policy

    We may change and update this Privacy Policy from time to time. We will notify you of material changes to this Privacy Policy as appropriate in the circumstances and as required by applicable law, e.g. by posting a prominent notice on our Services or by sending you a message.

    7. Your rights

    In certain circumstances, you have rights under data protection law.

    Right of access

    The right to request access to your personal data (commonly referred to as a "data subject access request"). This gives you the opportunity to receive a copy of personal data held by us concerning you and to verify whether the processing is carried out by us lawfully.

    Right to rectification

    The right to request rectification of the data we hold concerning you. This gives you the opportunity to obtain the rectification of any incomplete or inaccurate data held by us concerning you, although a verification of the accuracy of new data you provide to us may be necessary.

    Right to restriction

    The right to request restriction of the processing of your personal data. This gives you the opportunity to request that we suspend the processing of your personal data in the following situations: (a) where you wish to establish the accuracy of the data; (b) where you consider that our use of the data is unlawful; (c) where you request that we we keep the data even if we no longer need it.

    Right to erasure

    The right to request the erasure of your personal data. This gives you the opportunity to request that we delete or remove your personal data if there are no legitimate grounds for us to continue processing it.

    8. Communication

    We will communicate with you via email, SMS or notification app in connection with our Services, with the validation of your account with us, to inform you if your ad listings have become active/expired and in connection with other transaction-related messages in connection with our Services. Given that it is imperative for us to send you such transaction-related messages, you may not be able to opt out of such messages.

    9. Who we share your data with your

    We may need to share your personal data with the parties listed below for the purposes specified in section 4 above.

    Third party service providers:

    We use third party service providers to help us provide certain aspects of our Services and to maintain and monitor our Services. In this context, your personal data may be shared with the following recipients or categories of recipients:

    • payment service providers;

    • cloud service providers;

    • third party providers of integrated tools;

    • customer support tool providers;

    • marketing communications service providers;

    • user survey service providers.

    10. International Transfers

    Whenever we need to transfer your personal data outside the EEA, we ensure that it is provided with a similar level of protection by implementing at least one of the following safeguards:

    • we will only transfer personal data to those countries that have been considered to provide an adequate level of protection for personal data by the European Commission;

    • in situations where we use certain service providers, we may use specific contracts approved by the European Commission.

    11. Where do we store your data and for how long?

    The data we collect about you will be stored and processed within and outside the EEA, on secure servers, in order to provide you with the best possible user experience. The data of FIRST users in the EEA is stored on "cloud" servers provided by companies such as Google.

    We will retain your personal data only for as long as is necessary to fulfill the purposes for which we collected it, including for the purpose of fulfilling any legal, tax, accounting or reporting requirements.

    12. Technical and organizational measures and security of processing

    All information received by us regarding your person is stored on secure servers and we have implemented technical and organizational measures that are appropriate and necessary to protect your personal data.

    !!! Please note that, despite the measures implemented by us to protect your data, data transfers over the Internet or other open networks are never completely secure and that there is a risk that your personal data may be accessed by unauthorized third parties.

    13. Links to websites of third parties

    Our services may contain links to websites or applications of users of the FIRST website/application, professionals in the field or third parties. If you click on one of these links, please note that each one will have its own privacy policy.

    14. Contact details

    For any additional information or to exercise your rights, please check your account/privacy settings or contact our Data Protection structure using the email address: [email protected]

    If you wish to contact us to request information regarding the processing of your personal data, you can send a letter to the following address: S.C. First Digital Imobiliare S.R.L., Bucharest, Lt. Radu Beller Street, no. 3-5

    15. Data Protection Authority

    With regard to complaints regarding data protection, you may contact the Data Protection Authority. You may exercise this right by contacting the authority at your place of residence or workplace or at the address of the data controller.

    With regard to Romania, the competent Data Protection Authority is: National Data Protection Authority, with headquarters at: b-dul. Magheru, no. 28-30, sector 1, Bucharest, website: http://www.dataprotection.ro/