Data Privacy Policy for Clients

CBS International GmbH, Schreyvogelgasse 2/1. OG, 1010 Vienna, FN 611115z, HG Vienna, Austria (“CBS” or “We”) collects and processes your personal data in order to manage the client’s relationship.This Data Privacy Policy describes the types of personal data we process, the purposes for which we collect the personal data, and the third parties with whom we exchange these personal data. Additionally, we will inform you about your rights in relation to your personal data and how you can contact us.

1. WHO IS RESPONSIBLE FOR DATA PROCESSING AND WHO CAN I CONTACT?

The data controller is:
CBS International GmbH, Schreyvogelgasse 2/1. OG, 1010 Wien, FN 611115z, HG Wien
You can contact us under:
Tel: +43 1 786 04 610
Email: office@cw-cbs.at

2. WHAT PERSONAL DATA DO WE USE?

2.1 General information on personal data

Personal data means any information relating to an identified or identifiable natural person. This can also include information on personal or material circumstances, such as name (including contact persons of legal entities), postal address, email address and correspondence, contact details (telephone number, etc.), account details, invoice data. We also obtain data from other sources, these sources are publicly available information which we obtain from internet, public register or even from credit agencies in individual cases (e.g company register, trade register, money laundering database, contact information, your position in the company, etc.).

Personal data will only be collected when it is required for us in order to provide our services, on the basis of our legitimate interests or when you have willingly provided the personal data to us or consented. If you should fail to provide the necessary personal data, we will not be able to provide you with our services or, at least not in a sufficient manner.

2.2 Personal data that we always process

We process the following personal data:

• Name and surname (including contact persons of legal entities);
• Adress;
• E-mail address and correspondence, IP addresses;
• Contact details;
• Account details, invoice data.

Personal data that we gather from internet, credit agencies, public registers (e.g. company register, trade register, money laundering database, contact information, your position in the company, etc.)

2.3 Further personal data that we collect, as the case may be:

As a company in the sector of brokerage real estate services, we may collect further personal data, if necessary. This varies from case to case. Upon request, we will be happy to provide you with further information on the respective data categories.

3. FOR WHAT PURPOSE AND ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

We can collect, process and use the data as defined under point no. 2.2 and 2.3 for the following purposes:

3.1 the processing is necessary for the performance of a pre contractual measures (such as launching, maintaining and developing our services), for the performance of a contract to which you are a party (Art 6(1)(b) GDPR)

The processing of personal data is necessary in order to provide our services to the client. The purposes highly depend on the specific mandate (e.g. brokerage agreement, consultancy services, etc.)

3.2 the processing is necessary for the purposes of the legitimate interests pursued by us as the data controller (Art 6(1)(f) GDPR)

To the extent necessary, we will process your personal data in order to protect legitimate interests of our own, in particular, in the following cases:

• consultation and transfer of personal data with our CBS group in order to provide our services;
• client management;

3.3 on the basis of statutory regulations-legal obligations (Art 6(1)(c)GDPR)

Moreover, we are subject to various legal obligations (e.g. AML regulation, GewO, European Directive, etc.). For example, for the purposes of preventing money laundering, we may carry out identity checks to determine who the “ultimate beneficial owner” is or whether the client is a politically exposed person (PEP).

3.4 because you have given your consent (Art 9(2)(a) GDPR)

If special categories of personal data are processed, or if you have given your consent for the processing for specific purposes, the legality of the processing is based on your consent. You may withdraw your consent from the partner in charge of the mandate at any time.

3.5 We may use the customer data which we received from our customers in terms of § 107 telecommunications Act (“TKG”) in connection to a sale or service, for the purpose of direct advertising for similar products and services that we offer based on our legitimate interest in accordance with Section 107 TKG and Article 6 paragraph 1 lit. f GDPR. When data is collected and each time it is transmitted, we will clearly give you the option of objecting to such use of your electronic contact details, easily and free of charge. The data will not be sent if the recipient rejected this right from the start, especially by means of an entry in the list named in Section 7 paragraph 2 E-Commerce Act (Robinson list).

4. WHO WILL RECEIVE MY PERSONAL DATA?

For the purpose of providing our services and fulfilling the contract concluded with you, it may be necessary to transfer your personal data to other recipients. However, we will only transfer your personal data for the purpose of providing our services to you. Our recipients could be:

• Affiliated companies within the CBS Group or other Cushman & Wakefield partner companies;
• IT services providers employed by us;
• Auditors and legal advisors bound by statutory confidentiality obligations for the purpose of performing their professional services Jointly appointed brokers;
• Suppliers or sub-contractors appointed by the Company to support the Companies business administration and infrastructure;
• Government authorities and public bodies, to the degree as corresponding authorization exists for this;
• Data processor who performs certain services on our behalf;

Some of the above-mentioned recipients of your personal data are located outside the European Union. The data protection level in other countries may not have the same standards as in Austria. However, we either transfer your personal data to countries having an adequate level of data protection due to the EU Commission’s decision or who are Privacy Shield certified recipients, or we guarantee that the recipients maintain a sufficient level of data protection by having them agree to the Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC).

5. FROM WHICH SOURCES WILL MY PERSONAL DATA BE COLLECTED?

Please note that information about you will be obtained from third party or publicly available sources (e.g. AML registers, land registries, company registers, the press, the internet, etc.). Upon request, we will be happy to inform you about the specific third parties from whom we have received personal data.

6. FOR HOW LONG WILL MY PERSONAL DATA BE STORED?

We process and store your personal data under points 2.2 and 2.3 as long as it is required to meet the purposes as set out under point 3. If the personal data is no longer necessary due to our legitimate interest, the personal data shall be deleted. The same applies if data is prepared on the basis of consent and such consent is withdrawn.

We will store your data we received from you in terms of Section 107 TKG in connection with the sale or a service for this purpose for a maximum of three years, provided there is no subsequent agreement in connection with the sale or service. In the event of objection, the data will no longer be recorded for setting out newsletters.

7. WHAT DATA PROTECTION RIGHTS DO I HAVE?

You have the right of access of your personal data, including information on the source, recipients and purpose of the data processing; as well as the right to rectification, the right to data portability, the right to objection, the right to restriction of processing and erasure of personal data that has been processed unlawfully or that is incorrect.

If your personal data changes, we would kindly request that you inform us.

Your consent to the processing of personal data for marketing purposes may be withdrawn at any time by contacting us office@cw-cbs.at

If you believe that our processing of your personal data violates the data protection laws currently in force or your data protection rights in any other way, you have the right to appeal to a competent data protection supervisory authority. For Austria, the Austrian Data Protection Authority is the competent supervisory authority (www.dsb.gv.at, Wickenburggasse 8,1080 Vienna).