Privacy Policy

Introductory Provisions

These Personal Data Processing Principles (the "Principles") serve to fulfill the information obligation pursuant to Articles 13, 14, and 26 of Regulation (EU) 2016/679 of the European Parliament and of the Council (the "GDPR").

This document describes how EPRE Leopoldova s.r.o., with its registered office at Hanusova 496/6, Michle, 140 00 Prague 4, ID No.: 04651405, registered with the Municipal Court in Prague under file number C 251454 (the "Controller"), processes the personal data of natural persons ("Data Subjects" or "Clients") in connection with its development activities, the sale of residential and non-residential units, the operation of the website www.dum-leopold.cz (the "Website"), the Realpad client portal, and related activities.

Relationship to the ENERGO–PRO Real Estate Group

The Controller is part of a business group headed by the parent company ENERGO–PRO Real Estate s.r.o. ("EP RE"). Within this group, data processing occurs in two distinct modes:

  • Joint Controllership (Administration and Sales): For managing business cases within the Realpad CRM system, the Controller and EP RE act as joint controllers (Article 26 GDPR). EP RE provides the technical platform and administrative support, while the Controller handles the sales. You may exercise your rights with either entity; however, the Controller remains the primary contact.
  • Separate Controllership (Group Marketing): For the purpose of offering other real estate projects within the group, EP RE acts as a separate controller. Your data is transferred to EP RE for this purpose solely on the basis of your explicit consent.

Contact Details

To exercise your rights under the GDPR or should you have any questions, you may contact the Controller:

The Controller has not appointed a Data Protection Officer (DPO), as there is no legal obligation to do so.

Purposes, Legal Bases, and Retention Periods

The Controller processes personal data only to the extent necessary for the following purposes:

1. Contract Negotiation and Sales

  • Purpose: Handling inquiries, organizing viewings, managing business cases in the shared Realpad CRM, preparing and executing contracts (reservation, future purchase, and purchase agreements), client modifications, financing, and unit handovers. These activities are carried out under joint controllership with EP RE.
  • Legal Basis: Article 6(1)(b) GDPR (performance of a contract and pre-contractual measures).
  • Retention Period: For the duration of the contractual relationship and 10 years thereafter (statute of limitations). For inquiries not resulting in a contract, data is kept for 6 months from the last communication.

2. Fulfillment of Legal Obligations

  • Purpose: Accounting, tax compliance, AML (Anti-Money Laundering) obligations, and archiving.
  • Legal Basis: Article 6(1)(c) GDPR (compliance with legal obligations).
  • Retention Period: As stipulated by law (e.g., 10 years for tax documents and AML identification).

3. Legitimate Interests

  • Purpose:
    • Defense of legal claims (debt collection, litigation).
    • Direct marketing to existing customers ("soft opt-in" regarding the same project).
    • Basic web analytics and IT system security.
    • Transfer of data to the property manager/Homeowners Association (SVJ) for property management.
  • Legal Basis: Article 6(1)(f) GDPR (legitimate interests).
  • Retention Period: For the duration of the legitimate interest, but no longer than until a legitimate objection is raised.

4. Consent-based Marketing

  • Purpose:
    • Sending newsletters to non-clients.
    • Transfer of data to EP RE (as a separate controller) for cross-selling other group projects.
    • Marketing cookies.
  • Legal Basis: Article 6(1)(a) GDPR (consent).
  • Retention Period: 36 months from the date of consent/last interaction, or until consent is withdrawn.

Scope of Processed Data

We only process data necessary for the specified purpose:

  • Identification Data: Name, surname, title, date of birth, personal identification number (if required by the Cadastral Act or AML Act), ID/passport number, permanent address.
  • Contact Data: Email, phone number, correspondence address.
  • Transaction Data: Unit number, price, payment schedule, financing details (mortgage), client modifications.
  • Technical Data: IP address, logs, cookies.

Recipients of Personal Data

Data is disclosed only to the following categories of recipients as necessary:

  • Joint Controllers: Parent company EP RE for CRM administration and sales support.
  • Independent Controllers: Parent company EP RE for marketing other group projects (only with explicit consent).
  • Public Authorities: Cadastral office, tax office, courts.
  • Financial Institutions: Banks (financing, escrow).
  • Property Management: Building managers and SVJ.
  • Processors: IT service providers (hosting, Realpad operator), external accountants, and marketing agencies.

International Transfers

We primarily process data within the EU/EEA. Transfers to third countries (e.g., the USA) are based on:

  • Adequacy Decisions (e.g., EU-US Data Privacy Framework) for certified providers.
  • Standard Contractual Clauses (SCCs) with additional security measures.

Cookies and Profiling

  • Necessary Cookies: Required for technical operation (consent not required).
  • Analytical/Marketing Cookies: Used only with your consent.
  • Profiling: We may segment clients by preference (e.g., unit size) for marketing. This is not automated decision-making with legal effects under Article 22 GDPR. You may object to profiling at any time.

Data Subject Rights

You may exercise the following rights via realestate@energo-pro.com:

  • Access: Confirmation of what data we process.
  • Rectification: Correction of inaccurate data.
  • Erasure: "Right to be forgotten" if the purpose has expired or consent is withdrawn.
  • Restriction: During disputes regarding data accuracy.
  • Portability: Obtaining data in a structured format (for automated processing based on contract/consent).
  • Objection: Regarding processing based on legitimate interest. We will cease direct marketing immediately upon objection.
  • Withdrawal of Consent: At any time, without penalty.

You also have the right to lodge a complaint with the Office for Personal Data Protection (www.uoou.cz).

Final Provisions

These Principles are effective as of December 1, 2025. The Controller reserves the right to update these Principles and will inform Clients of significant changes. Providing data for a contract is a requirement; failure to do so may prevent the conclusion of an agreement. Marketing consent is entirely voluntary.

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