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    Privacy Policy

    Privacy Notice

    Welcome and thank you for visiting our website at https://scannellproperties.eu; we appreciate your interest in our company. We take the protection of personal data very seriously. We process your data in accordance with the applicable laws and principles regarding personal data, including the EU General Data Protection Regulation (GDPR – Regulation 2016/679 of the European Parliament and of the Council).

    This privacy notice (the “Privacy Notice”) describes how Scannell Properties (“Scannell Properties”, “we”, “our”, “us”) collects, uses, and shares your personal data (i.e., information that personally identifies you, such as your name, e-mail address or billing information, or other data that can be reasonably used to infer this information).

    This Privacy Notice applies to your use of Scannell Properties aforementioned website, and all other digital and online services provided by Scannell Properties (collectively, the “Services”) and describes Scannell Properties’ privacy practices and procedures relating to the Services.

    This Privacy Notice does not apply to information collected by Scannell Properties offline, or to third party websites, applications, or services.

    Note. While browsing, specific privacy notices may be made available whenever you will be asked to provide personal information.

    1. CONTACT INFORMATION OF DATA CONTROLLER, CONTROLLER’S REPRESENTATIVE AND DATA PROTECTION OFFICER

    The Data Controller is Scannell Properties and can be contacted at the following address:
    8801 River Crossing Blvd. Suite 300
    Indianapolis, Indiana 46240
    United States

    In addition, the Data Controller has appointed a Representative in the European Union, who can be contacted at the following address:

    Scannell Management Italia S.r.l.
    Street Ceresio 7, 20154 – Milan (MI – Italy)

    Scannell Properties has appointed a Data Protection Officer (DPO), who can be contacted at privacy@scannellproperties.com.

    2. APPLICABILITY & ELIGIBILITY

    We need to process your personal data to operate our organization and provide you with certain Services. Before accessing, using, or interacting with the Services you should carefully review the terms and conditions of this Privacy Notice. Your use of the Services is further governed by our Terms of Service located at https://scannellproperties.eu/terms-of-service/, which is also incorporated into your agreement with Scannell Properties by this reference.

    By accepting our Terms of Service, you are confirming that you have read and understood such document as well as the Privacy Notice, including how and why we use your information. If you don’t want us to collect or process your personal data in the ways described in this Privacy Notice, you should not use the Services. Please note we are not responsible for the content or the privacy notices or practices of any third-party organization or service.

    The Services are not directed to children under the age of 18. You may not use the Services or provide any information on our Services if you are under the age of 18.

    3. CATEGORIES OF PERSONAL DATA WE COLLECT

    Scannell Properties collects information about you and your use of the Services through various means:

    • Directlyfrom you; for example, from forms you complete on our website;

    When you send a contact request, for example, we collect and process the following data:

    • Salutation, last name, first name
    • Contact data (e-mail address and telephone number)
    • Details on your preferences and interests

    Please do not submit any information to us, including confidential or sensitive information that you do not wish for Scannell Properties or other third parties to have access to or use in the future.

    • Indirectlyfrom you; for example, from observing your actions on our website;

    When you visit our website, we collect and process the following data:

    • Browsing data
    • Name of the Internet service provider
    • Information on the website you have visited us from
    • Web browser and operating system used
    • The IP address assigned by your Internet service provider
    • Requested files, amount of data transferred, downloads/file export
    • Information on the pages of our website(s) that you visit, including date and time

    With newsletters, we collect and process the following data:

    • Salutation (optional)
    • Last name, first name (optional)
    • Company (optional)
    • E-mail address (mandatory)
    • Analysis data from newsletter evaluation (anonymized data)

     

    We also keep track of how you use and interact with our website through the use of cookies and other tracking technologies as listed below (in this regard, please see our Cookie Policy).

    3. PURPOSES OF PROCESSING, LEGAL BASES AND RETENTION PERIOD

    The purposes of the processing are as follows:

    • Purposes on the basis of your consent (Art. 6(1)(a) of the GDPR)
      • To derive statistical information on the use of the website;

    Data retention period: data processed for the above purposes will be stored until the purposes pursued are achieved.

    • Carrying out promotional campaigns, including presentation of relevant content through third-party services, also by sending direct marketing and other communications.

    Data retention period: data processed for the above purposes will be stored until the purposes pursued are achieved.

    • Purposes for performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract (Art. 6(1)(b) of the GDPR)
      • To provide our Services that you have requested.

    Data retention period: data processed for the above purposes will be stored until the purposes pursued are achieved.

    • Compliance with a legal obligation to which we are subject (Art. 6(1)(c) of the GDPR)
      • Fulfilment of any legal obligations to which we might be subject: for example, if we’re responding to a legal process or an enforceable governmental request, or if we are required to retain your information to comply with applicable tax/revenue laws).

    Data retention period: data processed for the above purposes will be stored until the purposes pursued are achieved.

    • Purposes for the fulfilment of our legitimate interests (Art. 6(1)(f) of the GDPR)
      • To ensure the proper functioning of the website: we have a legitimate interest to ensure the proper functioning of the website and, therefore, in performing activities such as maintaining the technical integrity and security of the website, preventing and detecting any unauthorized access or malicious activities, troubleshooting technical issues, and ensuring the overall stability and reliability of the website. By safeguarding the website’s functionality, we aim to provide a seamless user experience, protect the privacy and data security of website visitors, and fulfil our obligations to maintain a secure online environment.

    Data retention period: data processed for the above purposes will be stored until the purposes pursued are achieved.

    • To improve our Services: we have a legitimate interest to continuously improve our services and enhance the user experience. By analyzing usage patterns, user feedback, and market trends, we can identify areas for improvement and develop new features or functionalities. This allows us to provide a better and more tailored experience for our users, meet their evolving needs, and remain competitive in the market. This legitimate interest enables us to make data-driven decisions and implement necessary changes to optimize our services, ensuring their relevance and effectiveness while respecting the privacy rights of our users.

    Data retention period: data processed for the above purposes will be stored until the purposes pursued are achieved.

    • To keep our Services safe and secure: we have a legitimate interest in keeping our services safe and secure and, therefore, in performing activities such as implementing strong security measures, monitoring for suspicious activities, detecting, preventing or otherwise addressing fraud, abuse, security or technical issues with our Services, maintaining and improving the integrity of our computing systems, and protecting our users’ data security and ensuring compliance with regulations to protect our systems, data, and users from unauthorized access and potential harm. By prioritizing security, we aim to create a trusted environment for users to interact with our services and safeguard their personal information.

    Data retention period: data processed for the above purposes will be stored until the purposes pursued are achieved.

    • To defend against attempted attacks on our web server: we have a legitimate interest in protecting our web server against attempted attacks by implementing security measures like firewalls and intrusion detection systems to prevent unauthorized access and malicious activities.

    Data retention period: data processed for the above purposes will be stored for 7 days; after 7 days at the latest, anonymization is carried out by shortening the IP address so that no reference is made to the user. To achieve this, the last three digits are removed: in other words, 127.0.0.1 becomes 127.0.0.*. IPv6 addresses are also anonymized. The anonymized IP addresses are kept for 60 days.

    • To develop new products and features: we have a legitimate interest to innovate and continuously improve to meet the evolving needs of our users; in fact, by investing in research and development, we aim to enhance our services, introduce new functionalities, and deliver a better user experience. This legitimate interest allows us to remain competitive, provide value to our users, and drive business growth while respecting privacy rights and ensuring data protection.

    Data retention period: data processed for the above purposes will be stored until the purposes pursued are achieved.

    • To understand how our Services are used: we have a legitimate interest in understanding how our services are used by analyzing user behaviour and collecting usage data to gain insights that help us improve and optimize our offerings, enhance the user experience, and tailor our services to better meet the needs of our users.

    Data retention period: data processed for the above purposes will be stored until the purposes pursued are achieved.

    • To perform research that improves our Services for our users and benefits the public: we have a legitimate interest in performing research to improve our services for our users and benefit the public; in fact, by analyzing data and studying user behaviour, we aim to gain insights that help us enhance our offerings, develop innovative features, and provide a better overall experience. This legitimate interest allows us to contribute to technological advancement and deliver Services that meet the evolving needs of our users.

    Data retention period: data processed for the above purposes will be stored until the purposes pursued are achieved.

    • To perform business transactions: we have a legitimate interest in processing payments, managing contracts, and conducting necessary financial operations to support our business operations. By engaging in these transactions, we aim to maintain the viability and sustainability of our business, fulfil contractual obligations, and provide our products or services to customers.

    Data retention period: data processed for the above purposes will be stored until the purposes pursued are achieved.

    • If necessary, to protect contractual and pre-contractual rights or, in any case, arising from existing relationships: we have a legitimate interest in taking necessary actions to enforce contractual terms, resolve disputes, and ensure compliance with legal obligations. By safeguarding these rights, we aim to maintain fair and balanced relationships with our partners, customers, or stakeholders, and protect the interests and obligations established within contractual or pre-contractual agreements. This legitimate interest allows us to uphold the integrity and enforceability of contractual relationships while respecting applicable laws and regulations.

    Data retention period: data processed for the above purposes will be stored until the purposes pursued are achieved.

    Note. Should it be necessary to ascertain, exercise or defend the Scannell’s rights in court, the retention period may extend until the termination of the litigation.

    4. NATURE OF PROCESSING

    Related to the above purposes, we point out that:

    • Where the legal basis is your consent, the provision of your personal data is optional; if you do not give your consent, there will be no negative consequences for you, except for the non-performance of the relevant services (we point out that you will also be able to browse the website even if you do not provide us with your consent);
    • In other cases, the provision of your personal data is necessary in order to execute the contract concluded with you or to take steps at your request prior to entering into a contract, or to comply with a legal obligation to which we are subject: in such cases, failure to provide your personal data may result in our inability to perform what you have requested (e.g., provide you with the Services).

    Note. What has just been stated does not apply to the use of technical (necessary) cookies, which, as indicated within the Cookie Policy, allow us to ensure the proper functioning of our website. It should be noted that if the functionality of these cookies had been restricted through the settings of the browser used, depending on different situations it may be difficult or impossible to browse properly.

     

    5. INFORMATION SHARING

    5.1 Communication of personal data to third parties

    When you access or use the Services, we collect, use, share, and otherwise process your personal data as described in this Privacy Notice. Scannell Properties will not share, sell, rent, or otherwise disclose your private personal data to third parties without your consent or another valid legal basis permitted by law.

    Scannell Properties will share your information in the following circumstances:

    • Within Scannell Properties: We may share and process information internally within Scannell Properties and with our subsidiaries and affiliates. Scannell Properties’ personnel may have access to your information as needed to provide and operate the Services in the normal course of business. This includes information regarding your use and interaction with the Services.
    • Affiliated Businesses:Scannell Properties is affiliated with a variety of businesses and works closely with them for a variety of purposes, including assisting us to perform and improve the Services. These businesses may sell items or services to you through the Services or, with your consent, offer promotions (including e-mail promotions) to you. Scannell Properties may also provide services or sell products jointly with affiliated businesses, including providing information to such partners to allow them to more effectively market to you. When an affiliated business assists in facilitating your transaction, we may need to share information related to the transaction with that affiliated business in order to facilitate your transaction, and this forms part of the Services we provide in accordance with our Terms of Service.
    • Service Providers:Scannell Properties work with various organizations and individuals to help provide the Services to you (“Service Providers”), such as website and data hosting companies and companies providing analytics information, like Google Analytics. Scannell Properties needs to engage such third-party Service Providers to help us operate, provide, and market the Services. These third parties may use your information only to perform these tasks on our behalf. Information we share to our Service Providers may include both information you provide to us and information we collect about you, including personal data and information from data collection tools like cookies, web beacons, and log files.

    Scannell Properties takes reasonable steps to ensure that our Service Providers are obligated to reasonably protect your information on Scannell Properties’ behalf. If Scannell Properties becomes aware that a Service Provider is using or disclosing information improperly, we will take commercially reasonable steps to end or correct such improper use or disclosure.

    Our engagement of Service Providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like helping us keep our Services operating and secure. In some other cases, these Service Providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users.

    • Third Party Technologies: Third-party plug-ins also may collect information about your use of the Services. These interactions are subject to the privacy notice of the third-party site. In addition, certain cookies and other similar technologies on the Services are used by third parties for targeted online marketing and other purposes. These technologies allow a partner to recognize your computer or mobile device each time you use the Services. Please be aware that when you use third-party sites or services, their own terms and privacy notices will govern your use of those sites or services. Scannell Properties chooses and manages these third-party technologies placed on its Services. However, these are third-party technologies, and they are subject to that third party’s privacy notice. Scannell Properties is not responsible for the privacy or security practices of third parties.
    • Business Transactions: Scannell Properties may purchase other businesses or their assets, sell our business assets, or be involved in a bankruptcy, merger, acquisition, reorganization or sale of assets (a “Business Transaction”). Your information, including personal data, may be among assets sold or transferred as part of a Business Transaction. In some cases, Scannell Properties may choose to buy or sell assets.
    • Safety and Lawful Requests: We may be required to disclose Services user information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose user information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. We may share your information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Services or using Scannell Properties name, or to protect the safety of any person. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this Privacy Notice is intended to limit any legal defences or objections that you may have to a third party’s, including a government’s, request to disclose your information.
    • Aggregated Non-Personal Data: We may disclose aggregated, non-personal data received from providing the Services, including information that does not identify any individual, without restriction. Scannell Properties may share demographic information with business partners, but it will be aggregated and de-personalized so that personal data is not revealed.

     

    5.2 Transfer of personal data

    Scannell Properties may transfer personal data to third parties as autonomous data controllers or to data processors to enable the performance of the activities listed in this Privacy Notice. In the event that such transfer takes place to countries that do not provide the same level of protection as provided by the GDPR or applicable law or, in any case, an adequate level of protection of personal data, Scannell Properties will ensure that each of such recipients undertakes specific contractual obligations in accordance with applicable data protection regulations (including signing the Standard Contractual Clauses approved by the European Commission), unless it can refer to any other legal basis for the transfer of such information. In any case, you can always request more information, including the countries to which your personal data will be transferred, by writing to privacy@scannellproperties.com.

     

    Personal data will not be disseminated, so it will not be made available to unspecified parties.

    6. YOUR RIGHTS & CHOICES REGARDING YOUR INFORMATION

    6.1 Your rights

    Firstly we would like to inform you of your rights as an data subject. These rights are standardized in Articles 7 and 15 – 22 of the GDPR. The data subject has the following rights:

    • Right to withdraw consent (Art. 7(3) of the GDPR – right to withdraw the consent given. Note: withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal);
    • Right of access (Art. 15 of the GDPR): right to obtain from us confirmation as to whether or not personal data is being processed and, if so, also to obtain access to such data and further information, such as purposes of processing, categories of data processed, recipients of communications and/or transfers of data (including their copy in intelligible form);
    • Right to rectification (Art. 16 of the GDPR): right to obtain from us the rectification of inaccurate personal data without undue delay, as well as the integration of incomplete personal data, including by providing a supplementary declaration;
    • Right to erasure (‘right to be forgotten’) (Art. 17 of the GDPR): right to erasure your data, if permitted by applicable legislation (please note that requests to delete or remove your information do not necessarily ensure complete or comprehensive removal of the content or information posted and removed information may persist in backup copies for some time. Please note that if you choose to delete your information, you understand that certain features, including but not limited to access to the Services, may no longer be available to you);
    • Right to restriction of processing (Art. 18 of the GDPR): right to obtain the restriction of processing, for example, in case the accuracy of the data is contested or in case of unlawful processing;
    • Right to data portability (Art. 20 of the GDPR): the right to receive in a structured, commonly used and machine-readable format personal data concerning you and provided to us and the right to transmit such data to another data controller without hindrance by us if the processing is carried out on the basis of consent or a contract and is carried out by automated means;
    • Right not to be subjected to automated decision-making (Art. 22 of the GDPR): right not to be subjected to a decision based solely on automated processing that produces legal effects or similarly significantly affects you.

    The above rights may be exercised in writing by sending an e-mail to privacy@scannellproperties.com; the same contact may be asked for more information about the processing of personal data at any time. It should also be noted that the exercise of your rights must not prejudice and/or infringe on the rights and freedoms of others.

    Scannell Properties undertakes to respond to requests within a period of one month, except in the case of particularly complex requests, for which it may take up to 3 months. In any case, Scannell Properties will explain the reason for the wait within one month of the request.

    The outcome of the request will be provided in writing (at your request) or in electronic format (and, in this case, free of charge). Scannell Properties specifies that you may be asked to contribute if your requests are manifestly unfounded, excessive or repetitive: in this regard, we will keep track of the requests.

    Scannell Properties, in compliance with Article 19 of the GDPR, undertakes to report to the recipients to whom your personal data have been disclosed any rectification, deletion or restriction of processing requested by you, where possible.

     

    6.2 Right to object (Art. 21 of the GDPR)

    You also have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you if it is based on our legitimate interest (Art. 6(1)(f) of the GDPR); with specific regard to cookies, the exercise of this right can be made by preventing the functioning of strictly necessary cookies via your browser settings.

    In addition, where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, your related personal data will no longer be processed for such purposes.

    You may exercise this right by writing to the e-mail address indicated in the previous paragraph.

    Please note you may not opt-out of certain Services-related communications, such as account verification, changes or updates to features of the Services, or technical and security notices.

     

    6.3 Right to lodge a complaint (Art. 77 of the GDPR)

    If you believe that your rights have been compromised or infringed upon, or that the processing of your data is contrary to applicable law, you have the right to lodge a complaint with the territorially competent Supervisory.

    6.4 Do Not Track

    Scannell Properties does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including personal data, about your online activities over time and across different websites or online services when you use Services. You may opt out of online behavioural ads at https://optout.aboutads.info/?c=2&lang=EN. You also may limit certain tracking by disabling cookies in your web browser.

    7. INFORMATION SECURITY

    The security of your personal data is important to us. Scannell Properties takes reasonable efforts to secure and protect the privacy, accuracy, and reliability of your information and to protect it from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Scannell Properties implements security measures as we deem appropriate and consistent with industry standards. As no data security protocol is impenetrable, Scannell Properties cannot guarantee the security of our systems or databases, nor can we guarantee that personal data we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information you transfer to or from Services is provided at your own risk.

    8. SAFELY USING SCANNELL PROPERTIES’ SERVICES

    Despite Scannell Properties’ safety and privacy controls, we cannot guarantee the Services are entirely free of illegal, offensive, or otherwise inappropriate material, or that you will not encounter inappropriate or illegal conduct from other users when using the Services. You can help Scannell Properties by notifying us of any unwelcome contact by contacting us at privacy@scannellproperties.com.

    9. CHANGES TO OUR PRIVACY NOTICE

    Scannell Properties may modify this Privacy Notice from time to time. The most current version of this Privacy Notice will govern our use of your information and will be located at https://scannellproperties.eu/privacy. You may contact us to obtain prior versions. We will notify you of material changes to this policy by posting a notice at the Services.