Privacy Policy

I. Introduction

RIVERGATE RATING GROUP S.R.L. (“RRG”), with its registered office in Bucharest, Romania, Str. Industriilor nr. 56, 3rd floor, sector 3, ap. 4, bloc 1, J2006014791408, unique registration code RO 19023870, is the data controller for the personal data submitted via the website www.rrg.ro

RRG 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 outlines RRG’s policies and practices regarding the collection and use of your personal data and establishes your privacy rights.

The confidentiality of information is an ongoing responsibility, and therefore, we will update this privacy notice from time to time as we implement new personal data practices or adopt new privacy policies.

II. Legislative Context

In accordance with the requirements of Regulation (EU) 2016/679 on the protection of natural persons 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 Regulation”), applicable as of May 25, 2018, we are obligated to manage, in safe conditions and only for the specified purposes, the personal data you provide through the use of our website, in compliance with the provisions of the GDPR Regulation.

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

III. Data Protection Officer

We have appointed a Data Protection Officer for all matters related to the protection of personal data. You may contact the Data Protection Officer regarding any issues related to the processing of your data and the exercise of your rights under applicable legal provisions, especially if you have questions or concerns about how we process your personal data.

The email address to contact the Data Protection Officer is: dpo@rrg.ro.

IV. Personal Data Processing Policy

4.1. Protecting your privacy during the use of our website is of utmost importance to us. Therefore, we provide detailed information below regarding the processing of personal data. Personal data is processed on this website by RIVERGATE RATING GROUP S.R.L., the owner of the domain.

When using and processing personal data, the companies strictly comply with the legal provisions in force concerning data protection. The right to use personal data and anonymous data belongs to RIVERGATE RATING GROUP S.R.L.

4.2. This data protection statement applies solely to (www.lakeside11.ro) and its associated subdomains, as well as pages presenting promotional campaigns, but not to pages controlled or operated by third parties. Please review the data protection statements of third-party-controlled or operated websites, as these sites are not under the control of the residential project and are not responsible for their content or data protection measures.

4.3. We do not use automated decision-making, including profiling, in a way that produces legal effects or similarly significantly affects you. All decisions concerning your personal data are made with human intervention to ensure fairness and accuracy. Should this policy change in the future, we will update this provision and provide you with clear information on the logic involved, the significance, and the envisaged consequences of such processing for you.

4.4. Data Security:
To protect your data, technical and organizational measures have been implemented to safeguard it specifically against loss, manipulation, or unauthorized access. The adopted measures are regularly reviewed and constantly updated to align with technological advancements.

4.5. Notifications.

In the event of a personal data breach that poses a risk to the rights and freedoms of individuals, we are obligated to notify the relevant supervisory authority. This notification will be made without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach.

If the data breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly and without undue delay, where feasible. The notification will include a description of the nature of the breach, the name and contact details of our Data Protection Officer (DPO), a description of the likely consequences, and a description of the measures taken or proposed to be taken to address the breach.

4.6. Please note that you are personally responsible for maintaining the confidentiality and security of your user data or passwords, which have been provided or communicated to you.

4.7. Processing Data of Minors:
We expressly emphasize that all personal data processing refers exclusively to individuals who are 16 years of age or older. The use of systems and tools, as well as the results of data processing for users below this minimum age, is prohibited without the consent of parents/guardians. If personal data processing of minors does occur, we will cease such processing upon becoming aware of this fact.

V. WHAT KIND OF PERSONAL DATA DO WE PROCESS?

5.1. If you are a client or potential client of the residential project:
We collect personal data from most of our interactions with you, as well as during other aspects of our activity.

5.2. The categories of data we process are as follows:
a) Data necessary to send you an offer based on your request and to maintain contact with you (e.g., name, surname, email, phone number, address);
b) Information about your request, including special requirements and apartment preferences;
c) Additional data required to conclude contracts between you and us (e.g., for a rental agreement, we will need the series and number of your identification document as well as your address, and for a sales-purchase agreement, we will need your personal identification number (CNP) to authenticate the document with a public notary);
d) Information about the vehicles you may bring onto our property, such as license plate numbers;
e) Information you provide regarding your marketing preferences;
f) Personal data you provide for registration and subscription to newsletters;
g) Reviews and opinions regarding our services;
h) Any other types of information you choose to provide to us.

Additionally, surveillance cameras and other security measures on our properties may capture or record images of you, residents, and visitors in public areas (such as entrances to the premises or lobby areas), as well as your location data (via images captured by surveillance cameras).

You may always choose which personal data you wish to provide to us. However, if you choose not to provide certain personal data, in cases where our request is based on compliance with a legal obligation, contractual obligations, or obligations necessary for the conclusion of a contract, we may be unable to provide certain services, for example:

• If you do not wish to provide your name, surname, email address, or phone number when requesting an offer, we will be unable to create and send the requested offer; or
• Given the legal obligations in force, if you do not wish to provide the public notary with your personal identification number (CNP) for the completion and authentication of the sales-purchase contract, we will be unable to conclude the contract with you.

5.3. If you are a potential employee:
We collect the information from the CV you submit, as well as any other information provided along with the CV and/or during interviews you attend.

5.4. If you are a visitor to our locations:
Surveillance cameras may capture or record images of visitors in public areas (such as entrances to our locations).

5.5. SPECIAL CATEGORIES OF PERSONAL DATA

The term “special categories of personal data” refers to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as the processing of genetic data, biometric data, health data, or data concerning sexual life or sexual orientation. In general, we do not process such special information unless you choose to provide it to us.

5.6. Third-Party Recipients of Personal Data

To achieve the purposes mentioned above, we may transfer your personal data to the following categories of recipients:

• IT and cloud service providers (hosting, email, data storage), as well as web developers;
• Payment processors and banking services, for purchases and payments;
• Marketing and communication providers – for sending newsletters, email campaigns, or messaging communication;
• Legal and notary service providers, for the conclusion of sales-purchase or rental agreements;
• Courier service providers, if document transmission is required;
• Social media platforms and messaging applications, including WhatsApp, if you choose to communicate with us via these channels;
• Public authorities or other institutions, if required by law;
• Contractual partners involved in the implementation of the residential project, based on legal or contractual grounds.

All these recipients will have access to the data only to the extent strictly necessary for providing the services, and based on firm commitments to confidentiality and data protection.

5.7. Use of WhatsApp for Communication

To enhance communication with clients and potential clients, we may use the WhatsApp application, in which case we process the following categories of personal data:

• Name and surname;
• Phone number;
• Conversation content (questions, requests, information provided);
• Date and time of the interaction.

WhatsApp is operated by Meta Platforms Ireland Ltd., and its use involves data transfer in accordance with its privacy policy. We recommend using official channels (email, phone) for transmitting sensitive or contractual information.

5.8. Data Processing in Specific Processes

In addition to the previously presented information, we would like to clarify the processing of personal data based on specific processes as follows:

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

6.1. If you are a client or potential client and have provided your data as follows:

A) General contact form or phone call to the number displayed on the website
The contact form (information about availability, purchasing housing units, information about the residential project, evaluations, complaints, etc.): When submitting the respective contact form or initiating the phone conversation, your personal data from the categories (name, surname, phone, email address, specific message) will be processed in accordance with the provisions of this section.
Purpose: Providing a response to your request.
Basis: Legitimate interest to individually process your questions and provide adequate answers.
Consequences of refusal: If you do not provide this data, we will not be able to be contacted, and we will not be able to provide the requested information. For this purpose, the data will be transmitted to sales representatives, and they will contact you to address your requests.

B) When submitting the contact form or making a phone call to request a viewing of a housing unit from the stock, your personal data from the categories (name, surname, phone, email address, specific message) are processed in accordance with the provisions of this section.
Purpose: Preparation, execution, and management of the purchase of a housing unit from the stock or to respond to the offers requested by you. The data is processed through the sales representatives of the residential project.
Basis: Execution of a contract or taking pre-contractual measures at your request.
Consequences of refusal: If you do not provide this data, you will not be able to receive proposals from the sales representative.

C) Contacting you
The data will be transmitted to authorized sales representatives, and you will be contacted by them for the preparation, execution, and management of a purchase of a housing unit from the stock.
Purpose: We process your personal data to maintain contact with you to provide necessary and relevant information of interest to you.
Basis: Conclusion and execution of a contract; we may also send you information regarding the rented or purchased location based on our legitimate interest.

D) Concluding the contract with you
Purpose: We process your personal data for the valid conclusion of the contract requested by you.
Basis: Conclusion and execution of a contract and fulfillment of legal obligations.

E) Provision of additional information regarding possible financing options for real estate properties or guarantees with a residential property (through partners, for example, but not limited to them).
Purpose: We process your personal data to facilitate information about financing options.
Basis: Providing information about financial products and/or concluding and executing a service agreement.

F) Marketing:
Purpose: We process your personal data for marketing purposes, such as commercial newsletters and marketing communications regarding new products and services or other offers that we believe may be of interest to you.
Subscription to Newsletter
The data provided during the respective registration from the categories (contact and identification data) will only be used for sending newsletters. When sending the newsletter, we will use the email address you have provided, and finally, we need your confirmation that, as the email address owner, you agree to receive them. We will include an unsubscribe link that you can use if you no longer wish to receive messages.
Purpose: Sending information about products, services, and events.
Basis: Consent.
Consequences of refusal: If you do not agree to this processing, you will not receive the newsletter.
• Exact data fields: Title, first name, last name, email address.
If necessary, in accordance with applicable legislation, we will obtain your consent before processing your personal data for direct marketing purposes. In this case, we inform you that you may withdraw your consent for marketing processing at any time, in which case you will no longer receive any marketing communications from us.
Additionally, during participation in certain events (e.g., Real Estate Fairs), we may take some photographs, and some of these may be shared online to show others how these events are conducted. In any case, considering your right to privacy, we will do our best to inform you about the fact that photographs will be taken (for objections regarding our photographs, please see the “Right to Object” in the “Your Rights” section).

G) Other communications: by email, phone, or SMS
The purpose of these communications will be for a specific reason, such as: (i) to respond to your requests, (ii) if you have not completed a request for an offer or a payment, we may send you an email to remind you to complete the process, (iii) to inform you about how complaints and/or incidents resulting from our collaboration have been resolved, (iv) to ensure that you had a pleasant experience when using the services offered by our company.
Legal basis: Our legitimate interest in providing services at desired standards by resolving any requests/complaints and ensuring our full availability to you; if we respond to a request during the execution of the contract concluded with you, the basis for processing is the execution of a contract.

H) If you are a visitor to our location:
Purpose: We process your personal data to ensure the protection of goods and people within the location.
Basis: Our legitimate interest in ensuring the protection of clients’ and staff’s goods as well as the protection of people within our location.

I) If you are a user of our website:
Purpose: Monitoring traffic to identify errors and/or any other website malfunctions.
Basis: We base this data processing activity on our legitimate interest, namely providing you with a fully functional website by fixing any errors and continuously improving it.

J) If you are a representative or contact person of our suppliers or business partners:
Purpose: Managing contractual relationships with our suppliers or business partners.
Basis: Execution of a contract.

K) If you are a potential employee:
Purpose: Evaluating your job application.
Basis: Conclusion of a contract.

For all the above categories of individuals, we may process your data in the context of the following activities:

a) Restructurings, internal reorganizations, or sales of assets or shares:
Purpose: We process your data to carry out the aforementioned operations.
Basis: Legitimate interest in carrying out the operations, especially since these would be impossible to achieve without processing your data. However, we assure you that any such processing will be conducted in accordance with this policy and by implementing measures to ensure the confidentiality of your data.

b) Security:
Purpose: We process personal data to ensure the security of goods and the physical integrity of individuals.
Basis: We rely on our legitimate interest in protecting your goods as well as the people within the perimeter of our location.

c) Legal reasons:
Purpose: In certain cases, we need to process the information provided, which may include personal data, to resolve legal disputes or complaints, for investigations, and compliance with applicable legal regulations, to enforce an agreement, or to comply with requests from public authorities to the extent that these requests meet the conditions imposed by law.
Basis: The reasons for processing may be represented by the legal obligation (if we are legally required to disclose certain personal data to public authorities) or our legitimate interest in resolving potential disputes and/or complaints.

6.2. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Your personal data is retained for the entire duration necessary to achieve the purposes detailed in this policy and the processes mentioned in Section 5.8, unless a longer retention period is required or permitted by applicable law.

We regularly review the necessity of retaining your personal data. If processing is no longer required and there is no legal obligation to retain your personal data, we will delete or destroy your information as soon as possible, ensuring it can no longer be recovered or reconstructed. For example:

• We will delete/destroy all data of individuals who were not hired following interviews unless there is a serious prospect of future employment.

If personal information is printed on paper, it will be destroyed in a manner that ensures its complete elimination. If it is stored electronically, it will be deleted using technical measures to ensure that the information cannot be recovered or reconstructed later.

VII. WHAT ARE YOUR RIGHTS?
7.1. As a data subject, you have the following rights under the GDPR:
a) Right of access: You can request from us (i) a confirmation of whether or not personal data is being processed and, if so, access to such data and information regarding it, as well as (ii) a copy of your personal data that we hold (Art. 15 of the GDPR).
b) Right to rectification: You can inform us of any changes to your personal data or request that we correct the personal data we hold about you (Art. 16 of the GDPR).
c) Right to erasure (“right to be forgotten”): In certain circumstances (e.g., (i) if the data was collected unlawfully, (ii) the data storage period has expired, (iii) you have exercised your right to object, or (iv) data processing is based on consent and you have withdrawn that consent), you can request that we delete the personal data we hold about you (Art. 17 of the GDPR).
d) Right to restrict processing: In certain situations (e.g., if the accuracy of the data is contested or the legality of processing is disputed), you can request that we restrict the processing of your data for a certain period (Art. 18 of the GDPR).
e) Right to data portability: You can request that we send your personal data to a third party or directly to you (Art. 20 of the GDPR).
f) Right to object: In certain situations (e.g., processing based on legitimate interest), you can request that we stop processing your data (Art. 21 of the GDPR).
g) If we use your personal data based on your consent, you have the right to withdraw this consent. In this case, your data will no longer be processed by us, unless a legal provision obliges us to retain and archive it. In any case, we will inform you if such a legal provision exists and will explicitly indicate it.

VIII. HOW DO WE PROTECT PERSONAL DATA?
The website uses information security techniques such as firewalls, access control procedures, and cryptographic mechanisms, all with the aim of preventing unauthorized access to data and ensuring their confidentiality. For more information, please refer to the Terms and Conditions and the Cookie Policy.

IX. TECHNICAL AND ORGANIZATIONAL SECURITY MEASURES
We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk and to protect personal data against accidental or unlawful destruction, loss, alteration, disclosure, or unauthorized access to personal data transmitted, stored, or otherwise processed.
• Pseudonymization/encryption of the Client’s personal data where possible without affecting the execution of the contract.
• The ability to ensure the confidentiality, integrity, availability, and ongoing resilience of processing activities and services. Personal data must be protected against accidental destruction or deletion.
• A process for testing, evaluating, and periodically assessing the effectiveness of technical and organizational measures to ensure the security of processing.
• Access control measures (physical and IT) to prevent unauthorized physical access to data processing facilities.
• Usage control measures to prevent the use of data processing facilities and systems by unauthorized individuals, including means of assigning privileges, usernames, and passwords.
• Data transmission control measures to prevent the reading, copying, modification, or deletion of personal data during transmission, transport, or storage on data media and to allow checks identifying authorized recipients of the personal data, including through encryption methods.
• Data entry control measures to allow subsequent checks to determine whether and who entered, modified, or deleted personal data in automated processing systems or data entry systems, including through audit logs.
• A risk assessment process allowing the Provider to evaluate and select the appropriate level of security, taking into account the risks associated with processing. Such information will be requested from the Provider if necessary.
• A policy and procedure for responding to incidents and breaches of personal data security, which regulates how the Provider acts in the event of such a breach.
• Data protection and security training for staff.

X. CONTACT INFORMATION
RIVERGATE RATING GROUP SRL
Email: dpo@rrg.ro
To process your request, we may ask for identification by presenting an identity document.

XI. LEGAL ASPECTS
In certain cases, prices may no longer be up to date. For exact price information, please contact your sales representative. Please ensure that you are informed upon concluding the sale-purchase contract about the exact specifications and price of the housing unit. All images are for informational purposes only. Please note that we cannot guarantee the exact correspondence of the characteristics shown in the presentation images due to the different display modes of various monitors. All commercial presentation materials related to this residential project (images, technical characteristics, finishes, prices, etc.) do not create contractual obligations, do not constitute contract offers, and may be unilaterally modified by the Developer.
Detailed information, viewings, and contracting are only available through the Developer’s authorized representatives.
For additional information regarding how we collect, use, store, and protect your personal data, we encourage you to also consult the Terms and Conditions applicable to the website’s use, as well as the Cookie Policy. These documents contain important details about your rights and options regarding data processing, as well as information about the technologies used to provide you with an optimal browsing experience.

Last updated: 12.08.2025