Privacy Policy regarding the PROCESSING OF PERSONAL DATA

• This information is addressed to you if you are a natural person who is a client or potential client of LIST APP SRL, but it also applies accordingly if you are a person with whom we interact to mediate a contract with a client of our company, if you are a person who participates in viewings or other interactions we have with our clients and their potential co-contractors for the sales or rentals that we mediate, or if you are the representative or delegate of a legal entity with whom we interact.

• We process your personal data in accordance with the legal provisions on the processing of personal data and the free movement of such data, namely EU Regulation No. 679/2016 (known as GDPR), and we confirm that we, including all our employees and collaborators, take particular care to protect personal data.

• The role of this information is to provide explanations regarding this processing and the measures taken to respect your rights and minimize the risks of unauthorized access or use of this personal data.

We are, according to the law, a personal data controller and we process your personal data for the following purposes: -For the purpose of providing secure interaction services in the Application between demand and supply and/or real estate brokerage, contracted or whose contracting is expected – pursuant to art. 6 para. 1 letter b) of the GDPR “conclusion and performance of the contract” physically or in digital format; List

-For the purpose of complying with our legal obligations, for example those established by consumer protection, financial-accounting, tax and anti-money laundering legislation – pursuant to art. 6 para. 1 letter c) of the GDPR “fulfillment of legal obligations”;

-For the purpose of protecting our legitimate interests, in the sense of avoiding, respectively, combating possible unfounded accusations of violations of legal and contractual norms, or to send you offers of services similar to those already contracted or discussed with us – based on art. 6 para. 1 letter f) of the GDPR "legitimate interest" of the operator or a third party;

-In order to improve your browsing experience on our website and to better adapt it to the specifics and requirements of visitors – based on art. 6 par. 1 lit. a) of the GDPR – consent. In this regard, when accessing our website listapp.eu you have the opportunity to express your consent to the processing of personal data collected through categories of cookie files which, although not absolutely necessary to access the site, have the purposes mentioned above. Details in this regard can be found in the "Cookies and Privacy Policy of the listapp.eu site at listapp.eu/gdpr

– In order to provide the convenient possibility of verbal contact with us at any time and to ensure the quality of the services that our staff and collaborators offer you – pursuant to art. 6 para. 1 lit.

a) din GDPR – consimțământ. În acest sens, cu acceptul Dumneavoastră putem înregistra apelurile telefonice cu noi. Precizăm că NU efectuăm alte prelucrări de date cu caracter personal care, prin natura lor, să necesite consimțământul clientului, motiv pentru care nu veți regăsi pe site-ul nostru sau în interacțiunea cu reprezentanții noștri formulare sau rubrici de acordare a consimțământului pentru prelucrarea datelor cu caracter personal în afara celor sus-menționate.

We process personal data in compliance with the principles set out in Article 5 of the GDPR, namely: processing characterised by lawfulness, fairness and transparency; with collection only for specified, explicit and legitimate purposes, and only of adequate, relevant and limited to what is necessary, accurate and up-to-date data; promptly assignable to the data subject; processing with appropriate technical and organisational measures to guarantee the rights and freedoms of the data subject, ensuring integrity and confidentiality and all on a responsible basis.

• If you contact us through the forms on the listapp.eu website or through the Application, you provide us with and we process, as shown in their headings, your last name and first name, CNP, domicile, type of identity document, series and number, issuer and date of issue and expiration or bank card data if you choose this identification option and your phone number, contact and calendar synchronization and, possibly, your email address, as well as any information you choose to transmit through the message field (for example, information about your property that you would like to sell or rent through us or the type of property that you would like to buy or rent with our help - number of rooms, neighborhood, amenities, comfort level, price range, etc.).

• If you initially contact us by phone, you will most likely provide us with and we will process the same data as mentioned above regarding contacting us via the website, as well as, implicitly, your voice in the case of recording, with your consent, the telephone conversation.

If we conclude or prepare to conclude a contract with you, we will process, in accordance with legal requirements, detailed identification and contact information: surname and first name, CNP, domicile, type of identity document, series and number, issuer and dates of issue and expiration, possibly bank account number and bank (if you make a payment to us by bank transfer), e-mail address, telephone number. We will also process detailed information regarding the existence, identification and characteristics of your real estate properties, respectively the one you are looking for, the transfer price of the property or use as well as various information about people in your entourage (family members, including minors, people who are considered "real beneficiaries" by the legislation on the prevention and combating of money laundering - Law 129/2019), about your financial situation, about tastes and concerns, possibly about profession, occupation, place of work, working hours, various habits, about your health, etc. We specify that, in accordance with legal definitions, processing of personal data can also mean simply taking note of or storing such data and that processing must be limited to the minimum objective necessary, which is why, of course, some of the above data that you bring to the attention of our agents will not be recorded in writing nor transmitted to other persons within the agency, let alone to third parties.

If you participate in property viewings with us, we will also process information related to your presence in a certain place at a certain date and time and with certain people or about your schedule or time availability, as well as about the existence and nature of your relationships with certain people who accompany you or are present at the viewings.

• If you are a person offering for sale or rent a property that one of our clients is interested in, or if you wish to buy or rent a property that one of our clients offers for sale or rent through us, we will, of course, come into possession of some of your personal data such as identification and contact data, some regarding the real estate property in question and various information that results directly or indirectly from what you choose to disclose to us, similar to the case of clients or potential clients as shown in the previous paragraphs.

• If you are the representative (legal or conventional) or delegate of a legal entity that is our client, potential client, supplier or with whom we interact for another purpose, we will come into possession of and process a minimal set of personal data such as your last name and first name, possibly CNP, the series and number of your identity document and other information contained therein, your position, place of work, telephone number and professional email address, details regarding your work duties and some information regarding your professional schedule and hours, the place and time where you were at a certain time and everything else that implicitly results from the interactions we will have with you.

• If you are a visitor to our website listapp.eu or other websites, including social media platforms, even if you do not fill out any form on the website or do not perform other proactive actions (such as like or share on the Facebook page), implicitly and automatically, due to the technical specifics, your technical personal data will be collected and processed by us or by specific IT service providers. Some data will always be collected as they are indispensable for the safe operation of the website, others depend on your acceptance of certain categories of cookies according to the specifications in the cookie policy that you can find at listapp.eu. For example, the Internet Protocol (IP) address used to connect your computer to the internet, login information, browser type and version, time zone setting, types and versions of browser extensions (plug-ins), operating system and platform, device type and mobile device brand may be collected. Also, in addition to technical information, data about your visit may be collected and processed, as appropriate, for example this may include complete Uniform Resource Locators (URLs), sequence of clicks to, through and from our Website (including date and time), information or products you viewed or searched for (including top articles read, top categories accessed, page response times, download errors, duration of visits to certain pages (including average time spent on certain pages, viewing certain content or videos), average number of articles viewed on our Websites, information regarding interaction with pages (such as scrolling, clicks and mouseovers), methods used to navigate the page, data about User behavior. Only some of this information collected as a result of your browsing on the pages of our website listapp.eu or on other pages, including on social media platforms, actually reaches us, and other personal information is accessible only to the respective service providers. IT.

• In addition to our own personnel and the personnel of public authorities entitled to access documents containing personal data during control activities, this data may also be disclosed to third parties such as our real estate agents who have collaborator status.

• Also, some data will be disclosed to and processed by our specific service providers such as IT services, accounting, tax and legal consultancy, audit and the like. Given the computerization of some of our procedures and services, technically, some information could also be accessed by suppliers of our direct suppliers, such as software, online service and telecommunications providers.

• We want to assure you that the personal data collected and processed by us is NOT transmitted to third parties for marketing purposes or other purposes other than the one for which it was collected.

• Personal data will be stored for as long as it is objectively necessary for the purposes mentioned in point 1, including in light of the applicable legal provisions, the clauses agreed in the contracts that are or will be concluded with you, respectively the legitimate interest of the company in light of the GDPR and the e-privacy legislation (protection of personal data in the telecommunications and electronic services sector).

• Thus, for example, in light of accounting legislation, documents attesting to payments will be kept for 5 years, and those included in cumulative documents such as accounting registers or annual financial statements, if applicable, for 10 years. The contract for the provision of real estate brokerage services and its annexes, as well as related or derivative contracts and essential correspondence, records and reports related to them will be kept for the entire duration of their validity and, in addition, for a period equal to the limitation period, according to the provisions of the Code of Civil Procedure, usually three years. We specify that the information included in these documents is considered processed for the duration of the retention of these documents, even if the only type of processing is their retention.

• We comply with all legal provisions regarding the protection of personal data as personal data controllers and implement appropriate technical (such as IT security, physical security of the premises and communications), legal (specific clauses in contracts with suppliers and other entities) and organizational (training and verification of individuals, limitation of access rights to what is objectively necessary, regulation of the way of working with personal data, etc.) measures to protect all operations directly or indirectly related to personal data, which prevent unauthorized or unlawful processing, as well as accidental or unlawful loss or destruction of data, regardless of their form and storage medium.

• We process personal data recorded on paper but also in electronic format.

• We note that personal data collected and processed by us may be considered to be subject to a transfer to a third country as we use the Gsuite professional services package offered by Google, but any data that would reach outside the EU would be in the USA and Google offers security and privacy guarantees recognized by the European Union as adequate under the system known as the "US-EU Privacy Shield". We also use Immoflux services that store data in the European Union.

• We inform you that we process your personal data through an automated decision-making process and create profiles only for the purpose of sending you the most relevant offers for your needs. For example, if you tell us that you want to purchase a 2-room apartment in a certain neighborhood, our IT system will automatically decide based on these criteria which offers from our database will be sent to you for analysis. However, we assure you that no automated decisions will be made regarding the termination of the contract with you, the modification of the commission, the method of communication with you or other elements that could disadvantage or discriminate against you.

• Right to information and access to personal data – you can request information regarding the existence of your personal data processing activities and access to that information, if any.

• Right to rectification – you can rectify inaccurate personal data or complete it.

• Right to erasure of data – you can request the deletion of personal data concerning you, if their processing was not or is no longer legitimate or was based on consent or in other cases provided for by law.

• The right to withdraw your consent – ​​where the processing is based on your consent, you may withdraw it at any time. The withdrawal of consent will only have effect for the future, with processing carried out prior to the withdrawal remaining lawful.

• Right to restriction of processing – you can request and obtain restriction of processing of personal data concerning you if you contest the accuracy of the data, the legitimacy of its holding or in other cases provided by law.

• Right to data portability – you can receive, under legal conditions, the personal data you have provided to us, in a machine-readable format and you can request that the data be transmitted to another operator.

• Right to object – you can object, in particular, to data processing based on our legitimate interest;

• The right to address justice directly or through ANSPDCP

• The right to lodge a complaint with the controller and the competent data protection authority

• To exercise the rights mentioned above, as well as for any additional questions regarding this information or in connection with the use of your personal data by our company, please contact us personally at the headquarters at Cluj-Napoca, Nicolae Cristea no. 25, 1st floor, Cluj County or write us an e-mail at listapp.eu. We provide clarifications by phone at 0372.903.904.

• If you wish to exercise your right to file a complaint with the competent state authority, we inform you that this is the National Authority for the Supervision of Personal Data Processing (ANSPDCP – www.dataprotection.ro) which has the right to investigate the notified situation administratively and to order measures to adequately resolve your grievances, including being able to file a court action on your behalf if a judicial referral is required and you do not do so directly (in accordance with the provisions of Law 129/2018).

• Personal data protection legislation may continue to undergo changes and, through decisions of the ANSPDCP, regulations may be adopted regarding the application of EU provisions (GDPR) in Romania.

• Also, the European Data Protection Board is currently developing or revising various guidelines for the application of the GDPR and, over time, codes of conduct, certification schemes and other such instruments will also appear.

• Therefore, although we have adequately implemented the GDPR, it is very likely that periodic adjustments to the privacy and personal data protection policy will be required to keep up with evolving legislation and good practices, as well as with the development of our society and technologies and practices in reality, so this information will also undergo changes that we will display.