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Privacy Policy


Privacy Policy
 We take your privacy serious and in relation to Art. 13 of the Regulation (EU) 2016/679 (General Data Protection Regulation - GDPR) we highlight how we use any personal data within our website.  This information applies only to our website and not other websites which you might use (via links) from our website (our data Controller's domain name) and so shall not be liable under any circumstance for third parties websites.  The DATA CONTROLLER, pursuant to art. 4 and art. 24 of the Regulation (EU) 2016/679, is Gemma Immobilaire s.a.s., via Rima, 2, Tremezzina-Lenno (Co) ), as represented by Mrs Gemma Fumagalli. You can contact the Manager  at any time at the following contacts:  
telephone number +39 0344-55630, email:
The information below is based on the use of Cookies, what they are and how they are used

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Third-party cookies
For some features of the site we use cookies provided by third-party partners. This site uses Google Analytics, which is one of the most popular software for web analytics. This allows us to understand how the site is used and therefore allows us to improve your experience. These cookies can trace different elements, for example how much time is spent on the site and the pages visited in a completely anonymous way.
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We also use on this portal the buttons of the various Social Media and/or plugins that allow you to connect to social networks in various ways. For these functions of Facebook, Twitter, etc., sites will send cookies through our portal. These will be used to improve the profile on their site or to contribute to the data in their possession for various purposes indicated in the respective privacy policies.

Further information
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"Information on the processing of personal data" Pursuant to EU Regulation 2016/679

The undersigned Gemma Fumagalli, born in Morbegno (So) on 27/02/1975, domiciled, for the purposes of this at the real estate brokerage company Gemma Immobiliare, based in Tremezzina-Lenno, tel. 0039-0344-55630 e-mail address:, pec address: (hereinafter referred to as "Agency"), by the same representative and in the capacity of "Data Controller" (hereinafter "Owner") of your personal data (hereinafter, cumulatively, also "Data"), of which you are the "Concerned", in accordance with EU Regulation 2016/679 (hereinafter "Regulation"), and of which the Agency has come into possession with the assignment of the task of mediation, provides the following information so that you can give a specific, unequivocal, informed, free and informed consent to the processing of data that may also be done by computer and/or telematic tools.

1) Source of Data: The data necessary for completing the contractual requirements between all Parties, as well as data otherwise acquired that forms part of this activity, is collected by the Agency directly from the Interested Party and/or through third parties; and also obtained from other relevant public and private external databases.

2) Availability of the Information: The Agency provides the possibility to consult this information: a) every time it collects the personal data of the Customers; b) every time an explicit request is made to the Owner; c) through the web consultation by accessing the home page of the site:

3) Purposes of data processing: The Agency for its own institutional purposes, connected or instrumental to the activity, processes your data for the following purposes: 
a) purposes related to the obligations established by laws, regulations and Community legislation as well by provisions issued by Authorities legitimated by the law or by supervisory and/or control bodies
b) contractual purposes, connected and instrumental to the establishment and management of relationships with customers, such as for example the acquisition of preliminary information to the possible conclusion of a contract
c) recognition of the degree of satisfaction with the quality of services, performed directly by the Agency or through the work of specialised companies through personal or telephone interviews, interactive questionnaires, market surveys 
d) promotion of products and services of the Agency through the sending of advertising material, telephone contracts and any other form of electronic communication (sending of e-mails, sms, mms, publication on social networks)
e) communication and / or transfer of data to third parties for the promotion and/or sale of products and services, using traditional and/or automated methods. With reference to the purposes referred to in points c), d) and e), we inform you that, at any time, you will be free to revoke the consent expressed in the manner specified in this statement.

4) Nature of the provision of data: You have the right to know that the provision of data may be compulsory or optional, as well as imply consequences in case of refusal. In this regard, I specify that: 
a) the conferment of your consent for the purposes referred to in points a) and b) of point 3 is mandatory in so far as provided by law or to follow up obligations of a contractual nature (as indicated by Article 6, paragraph 1, letter b) of the Rules). The refusal of your consent for the purposes indicated in letter b) of point 3) will not, therefore, allow the Agency to carry out the task conferred by you or to reach the conclusion of the contract of which you are a part 
b) the refusal to process the Data for the purposes referred to in letters c), d) and e) of point 3 is, on the other hand, optional, will not entail any prejudicial consequences and may be revoked by you at any time, limited to the purposes related to the sending of advertising material, detection of the degree of satisfaction on the quality of services, carrying out market research or commercial communication, through telephone contacts or any other form of electronic communication (sending e-mail, sms , mms, whatsapp, publication on websites, social networks, etc.), performed directly by the Agency or through the work of specialised companies through personal or telephone interviews, interactive questionnaires.

5) Specific data: Article. 9 of the Regulations defines particular data suitable to reveal racial and ethnic origin, political opinions, religious or philosophical beliefs or union membership, as well as genetic and biometric data, data related to health or sex life or to the sexual orientation of the person. It is possible that the Agency will be in possession of particular data in relation to the specific operations requested by the interested party. In this case, the interested party has the right to express a specific consent to the processing of their sensitive data and the Agency may use them exclusively to the extent necessary to perform the services and operations required.

6) Data Retention: The Data will be kept for the time necessary to manage the contractual relationship and fulfil legal obligations, with particular reference also to the anti-money laundering legislation. The Data is always treated in full compliance with the principle of proportionality of the processing (Article 5, paragraph 1, letter c) of the Rules), according to which all Personal Data and the various modalities of their processing must be relevant and not exceeding the aims pursued, so as to ensure adequate security and confidentiality, also to prevent unauthorised access or use of personal data and equipment used for processing, as well as lawful and correct processing.

7) Data retention times: In accordance with the provisions of art. 13, paragraph 2, lett. a) of the Regulations, indications are given below regarding the data retention times according to the different purposes of the processing: 
• with reference to letters a) and b) of point 3, the Data are kept for the period necessary to manage the contract and fulfil the legal obligations
• with reference to letters c), d) and e) of point 3, storage times are set in 10 years.

8) Methods of data processing. In relation to the purposes indicated in point 3, Personal Data may also be processed by a "Manager", i.e. the natural person or company, even outside the Agency, which may be entrusted with specific and defined tasks of management and control of data processing, and by one or more "Distributors", who will provide for the processing or material use of the Data on the basis of instructions received from the Data Controller or the Data Processor (subjects that, if not expressly indicated in this information, they are to be considered not yet designated, and not necessarily to be designated if the treatment is occasional, and the data will be provided in case of their designation). Also in relation to the aforementioned purposes, the Data may be processed through manual, computerised and/or otherwise automated tools according to logics strictly connected to the purposes of the processing and, in any case, in order to guarantee its security and confidentiality even in case of treatment through instruments of distance communication.

9) Transfer of data abroad: The Data could be transferred to countries of the European Union and to third countries (that is not members of the European Union) exclusively for the purposes referred to in points a) and b) of point 3. In this case, the intention to the transfer of personal data must be communicated beforehand and authorised by you only if a level of data protection adequate to the European one is guaranteed.

10) Communication of Data: The Data, by virtue of the relationship established and in order to facilitate and allow the conclusion of the contract, may be communicated to: 
i) external collaborators
ii) other business agents in mediation (including companies) identified by the Owner in order to collaborate for the accomplishment of the assignment entrusted by the interested party
iii) banks and other subjects operating in the banking sector 
iv) counterparties and their potential technicians and consultants
v) notaries for the purpose of preparing notarial deeds and/or related activities pertaining to the assignment conferred to the proprietor
vi) companies and/or professionals who perform services for the completion of technical/land/building/town planning practices
vii) insurance in order to stipulate policies pertaining to the assignment conferred to the proprietor
viii) websites for the purpose of real estate advertising 
ix) boards of arbitrators and, in general, all those public and private subjects to whom communication is necessary for the correct fulfilment of the purposes indicated in point 3)
x) Supervisory/Control bodies and other Authorities, for purposes connected to the obligations established by law (anti-usury law, anti-money laundering legislation) and/or by regulations, as well as by instructions issued by the same Authorities. All subjects, belonging to the categories to which the Data may be communicated, will use the Data as "owners" in accordance with the law or specific consent, independently, being unrelated to the original processing carried out at the Agency, or of "external managers". To know at any time the subjects, to which your data will be communicated, it is sufficient that you request the updated list by writing to the Data Controller at the office of the Agency. Finally, your data will be known by all employees and collaborators of the Agency, designated managers and/or in charge of processing, in relation to the performance of the duties and tasks assigned to each. Data processed by the Agency will not be disseminated.

11) Rights of the interested party: Within the limits and under the conditions set out in articles 15 - 23 of the Regulations, the Agency guarantees and acknowledges the exercise of the following rights: • the right to access personal data in their paper and/or electronic archives
• the right to request correction, updating and cancellation, if incomplete or erroneous, and to oppose their processing for legitimate and specific reasons
• the right to obtain the correction of inaccurate personal data without unjustified delay. Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, also by providing an additional declaration
• the right to obtain the cancellation of personal data concerning him/her without undue delay if one of the reasons set out in art. 17, paragraph 1 of the Rules
• the right to obtain the limitation of processing when one of the hypotheses referred to in art. 18, paragraph 1 of the Rules
• the right to portability of data within the limits and in the ways provided for by art. 20 of the Rules. You also have at any time the right to withdraw your consent to the processing of your data without prejudice in any way to the lawfulness of the processing based on consent given prior to the revocation, as well as to object to processing for marketing purposes at any time (right of opposition). You have the right to receive information relating to the action taken concerning one of the aforementioned requests or the effects arising from the exercise of one of the aforementioned rights, without unjustified delay and, in any case, no later than one month after receipt of the request; extendable if necessary for two months; you also have the right to lodge a complaint with a supervisory authority and to bring a judicial appeal. Without prejudice to the case in which the processing of the Data violates the general principles laid down by the Regulations, the exercise of these rights must be relevant and justified and may not imply the revocation of the consent given or the request for cancellation of the Data provided by conclusion and execution of the contract referred to in point 3) letters a) and b), in so far as and as long as the data are necessary for this purpose. The rights in question may be exercised, also through a designated person, by submitting a request to the Data Controller or Data Processor at the following addresses: Via Rima 2, Cap 22016 Città Tremezzina-Lenno, tel. 0344-55630, cell. 0039-3387112973 e-mail address:, pec address: In exercising your rights, you may grant, in writing, a proxy or power of attorney to individuals, associations or organisations; may also be assisted by a trusted person. In order to guarantee the effective exercise of your rights, the Agency will adopt appropriate measures aimed at facilitating access to the Data, simplifying the procedures and reducing the time required to respond to your request. Finally, it should be noted that you can lodge a complaint with the supervisory authority or with the Personal Data Protection Authority through the following means:
a) A / R registered letter to the Data Protection Authority, Piazza di Monte Citorio n. 121 00186 Rome
b) e-mail to the address:, or
c) fax to the number: 06 / 69677.3785. All related information on complaints proposed by the Interested party is available on the website of the Guarantor at

12) Responsible and in charge of data processing. Responsible for processing, pursuant to art. 24 of the Rules is Gemma Fumagalli in charge.

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