Privacy policy

  1. Introduction
  2. Legislative Context
  3. Data Protection Officer
  4. How We Collect and Use Your Personal Information
  5. Disclosure and Transfer of Personal Data
  6. Your Rights
  7. Retention of Personal Data
  8. Personal Data Security
  9. Changes to the Privacy Policy
  10. Third-Party Websites
  11. About Cookies
  12. Website Security
  13. Questions, Concerns, Complaints

Introduction

APEX REAL ASSETS S.R.L., Tax ID: RO 46779350, registered at the Trade Registry under number J04/1572/2022, located at România, Județul Bacău, Tg. Ocna, Strada Costache Negri, bloc G7, sc. A, ap. 11, hereinafter referred to as APEX Asset Management | Commercial Real Estate Firm., is the operator of personal data transmitted through this website.

Please note that we do not request or accept any information from children under the age of 16.

On behalf of "APEX Asset Management | Commercial Real Estate Firm.", there are third parties who process personal data, referred to as "data processors" in accordance with the provisions of Regulation (EU) 2016/679. The use of processors is justified by business reasons, often involving specialized, professional services capable of managing the necessary volumes and ensuring the technology through which APEX Asset Management | Commercial Real Estate Firm. fulfills its duties. It is important to mention that data is not simultaneously shared with all processors.

APEX Asset Management | Commercial Real Estate Firm. is committed to respecting the confidentiality of your personal data. We will treat all personal data provided by you as confidential and will process only the information permitted by applicable legislation. This privacy notice describes the policies and practices of APEX Asset Management | Commercial Real Estate Firm. regarding the collection and use of your personal data and outlines your privacy rights.

Confidentiality of information is a continuous responsibility, and therefore, we will periodically update this privacy notice as we adopt new personal data practices or privacy policies. Regarding data processing based on consent (as described below), we will notify you of any changes and seek additional consent when necessary.

Legislative Context

In accordance with the requirements of Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (hereinafter referred to as the "GDPR"), applicable as of May 25, 2018, we are obligated to handle your personal data securely and solely for the specified purposes, as provided by the GDPR.

For more details regarding the content of this legal standard, please refer to the following link:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R0679

Data Protection Officer

We have appointed a Data Protection Officer (DPO) responsible for all aspects related to the protection of personal data. You can contact the DPO regarding all matters related to the processing of your data and the exercise of your rights under applicable legal provisions, particularly if you have any questions or concerns about how we process your personal data. The email address to contact the DPO is: info@apexasset.eu.

How We Collect and Use Your Personal Information

Personal Information You Provide: We may collect, store, and use the following types of personal data:

  • Information about your computer and your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths).
  • Information you provide for the purpose of subscribing to email notifications and/or newsletters (including your name and email address).
  • Information you provide when using the services or information generated while using this website.
  • Information contained in or relating to any communication you send us or send through this website (including correspondence with us, the content of the communication, and metadata associated with the communication).
  • Any other personal data you choose to provide us.

Purposes of Using Your Personal Data: Personal data transmitted through this website, as well as personal data we have collected from you, third parties, or public sources, will be used for the purposes specified in this Privacy Policy. Depending on the relationships we have or wish to establish with you, we may use your personal data for the following purposes, based on the legal grounds outlined below:

Communications, based on the legitimate interest of APEX Asset Management | Commercial Real Estate Firm. under Article 6(1)(f) of the GDPR: If you have contacted us through this website or by other means, we may process your name, contact details, location, and other information you have provided to respond to your inquiries, organize meetings, phone calls, or other communications.

Product Purchases, based on our contract with you under Article 6(1)(b) of the GDPR: By purchasing products through this website, you agree to become a party to a contract, the terms and conditions of which will be stipulated in the contract. In this case, your personal data, such as full name, contact details, address, identity document details, and payment details (if applicable), will be processed by APEX Asset Management | Commercial Real Estate Firm. for the following purposes: to conclude the contract for the product purchased from our website, deliver the product to the address you provide, collect the price of the purchased product, or retain your information when you wish to return the purchased product in accordance with the General Terms and Conditions.

Marketing and Public Relations, based on your consent under Article 6(1)(a) of the GDPR: If you are a visitor to our website, we may process data such as your IP address, geographical location, browser type and version, operating system, referral source, length of visit, log files, interactions with our website and online campaigns, as well as data collected automatically about you or your device (in accordance with this Privacy Policy). This includes information you have provided through website forms or services purchased (value, date, sources of data, notes, and remarks) to conduct marketing research, analyze visitor characteristics, assess the impact of our marketing communication, and adapt it to detected trends. We may also use this data to plan future marketing activities, prepare business analyses, customize services and communications for you, direct advertising, or offer direct marketing of the same or similar products and services. Additionally, if you are subscribed to our newsletter, you may receive marketing materials from us. We may use your personal data to distribute promotional materials, announce additions and changes to our services, customize this website and our marketing communication for you, send you email notifications (e.g., about our offers), send newsletters and email bulletins (you can notify us at any time if you are no longer interested in these materials), or send you marketing communications regarding our activity that we believe may interest you.

Security, based on the legitimate interest of APEX Asset Management | Commercial Real Estate Firm. under Article 6(1)(f) of the GDPR: If you are a visitor to this site, we may process personal data you have uploaded, data collected automatically about you or your device (e.g., through cookies, web beacons) to keep this website secure from fraud, protect the rights and interests of APEX Asset Management | Commercial Real Estate Firm. and third parties, and safeguard intellectual property rights. Please note that this information may be disclosed for the purposes of investigation or prosecution.

Disclosure and Transfer of Personal Data

The information we collect from you will be processed within the European Economic Area and outside the European Economic Area, depending on the purpose of the processing. APEX Asset Management | Commercial Real Estate Firm. strives to apply appropriate safeguards to protect the confidentiality and security of your personal data during transfer and to use it only in accordance with your relationship with APEX Asset Management | Commercial Real Estate Firm. and the practices described in this Privacy Policy. APEX Asset Management | Commercial Real Estate Firm. minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you.

To the extent permitted by applicable data protection laws, we may disclose your personal data to clients (for business engagement or to confirm the high quality of our services), auditors, agencies, supervisory authorities, or other external service providers to fulfill our contractual obligations. We will clearly indicate to you each data recipient if they are well known at the time the processing is initiated.

We may also disclose your personal data:

  • To the extent that we are required to do so by law.
  • In connection with any ongoing or potential legal proceedings.
  • To establish, exercise, or defend legal rights (including providing information to others for the purposes of fraud prevention).

Your Rights

The GDPR grants certain rights to individuals. You have the right to access and rectify (correct) your personal data records processed by us if they are inaccurate. You may request us to delete this data or cease processing it, subject to certain exceptions. You may also request that we stop using your data for direct marketing purposes. You have the right to lodge a complaint with the data protection authority if you have concerns about how we process your personal data. When technically feasible, we will be able—upon your request—to provide your personal data or transmit it directly to another controller. If access cannot be provided within a reasonable time frame, we will provide you with a date when the information will be delivered. You may also request additional information about the purpose of processing, the categories of personal data concerned, the source of the information, and how long it will be stored. If you wish to exercise any of these rights, please contact our Data Protection Officer at info@apexasset.eu, at any time.

NOTICE: Please exercise your rights wisely and remember that the abuse of rights may result in liability.

Contact details of the national data protection authority are as follows:

National Supervisory Authority for Personal Data Processing
Address: Bucharest, Blvd. G-ral Gheorghe Magheru No. 28-30, Sector 1, Postal Code 010336
Website: http://www.dataprotection.ro
Email: anspdcp@dataprotection.ro
Phone: +40.318.059.211; +40.318.059.212
Fax: +40.318.059.602

Retention of Personal Data

Your personal data is stored by APEX Asset Management | Commercial Real Estate Firm. on its servers.

Personal data we process based on your consent will be retained for an indefinite period (or until the consent is revoked), unless applicable legal requirements provide otherwise and it is necessary for the purpose of the processing.

If you have not provided your consent for data processing or have withdrawn your consent, we will store only minimal data about you (full name, contact details, references, and notes) for statistical and reporting purposes or as justified based on another legal ground, such as our legitimate interest.

Notwithstanding the other provisions of this section, we will retain information and documents (including electronic documents) containing personal data:

  • To the extent that we are required to do so by law.
  • If the information/documents are relevant to any ongoing or potential legal proceedings.
  • To establish, exercise, or defend our legal rights (including providing information to others for the purpose of fraud prevention).

Data Security

To protect your privacy and the personal information you transmit through this website, we will maintain physical, technical, and administrative safeguards.

We continuously update and test our security technology. We restrict access to your personal data to employees who need to know that information to provide benefits or services to you. Additionally, we train our employees on the importance of confidentiality and maintaining the privacy and security of your information.

If a personal data breach occurs, we will take all necessary steps to eliminate it and assess the risk level associated with the breach in accordance with our personal data breach policy. If it is determined that the breach may lead to physical, material, or non-material harm to you (e.g., discrimination, identity theft, fraud, or financial loss), we will contact you without undue delay, unless otherwise required by law. All measures will be taken in full cooperation with the competent supervisory authority.

Changes to the Privacy Policy

We may update this information document from time to time by publishing a new version on this website.

Given that data protection laws, interpretations by state bodies, and recommendations from supervisory authorities change and improve periodically, it is expected that this privacy notice and terms of use will also change. We reserve the right to modify this information document at any time, for any reason, and without notice. Any changes to our privacy policy will be posted on this page, so you are always aware of our policies. The provisions contained in this document replace all previous announcements or statements regarding our privacy practices and the terms and conditions governing the use of this website.

Third-Party Websites

This site may include hyperlinks and details about third-party websites. We have no control over and are not responsible for the privacy policies and practices of third parties.

About Cookies

As is the case for most websites, this site automatically collects certain information and stores it in log files. This includes Internet Protocol (IP) addresses, the geographical location of the computer or device, browser type, operating system, and other information about visiting this site, such as pages viewed. This information is used to improve this website and, due to this constant improvement, to better serve our users. Your IP address may also be used to diagnose issues with our server, administer this site, analyze trends, track user navigation on the site, and gather demographic information to help us understand visitor preferences and needs.

This site also uses cookies. For more details about cookies, please access The User Information Document on the Presence of Cookies on the Site.

Site Security

We cannot guarantee that data transmissions over the Internet can be 100% secure. Consequently, we cannot ensure or guarantee the security of the information you transmit, and you understand that any information you transfer to APEX Asset Management | Commercial Real Estate Firm. is done at your own risk. However, APEX Asset Management | Commercial Real Estate Firm. uses site security measures in accordance with best practices to protect the website, emails, and mailing lists. These measures include technical, procedural, monitoring, and tracking measures designed to protect data from misuse, unauthorized access or disclosure, loss, alteration, or destruction.

We are aware that misuse incidents or unauthorized program intrusions can occur, as this is a reality for almost every website, service, or user. In these situations, our objectives are to act quickly to isolate the issue, secure or restore appropriate functionality, and minimize inconvenience to our users. If necessary, APEX Asset Management | Commercial Real Estate Firm. will notify the competent authorities about such incidents of misuse or unauthorized intrusions on the APEX Asset Management | Commercial Real Estate Firm. site.

Questions, Concerns, Complaints

If you have questions about your personal information or if you wish to exercise your rights or have concerns or complaints, please contact us by sending an email to the data protection officer at info@apexasset.eu.

If you do not want us to use the information you have provided, please send us an email to info@apexasset.eu with the subject "Do not use my data" and include your name.

To update or correct your personal information, please contact the data protection officer at info@apexasset.eu.