MyCosmopolis Privacy Policy

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PERSONAL DATA PROCESSING POLICY

INTRODUCTION

MyCosmopolis is the official application of the Cosmopolis community, developed on the Realtynno platform, with the purpose of facilitating efficient management of interactions and improving communication regarding the residential complex.

Through the application, you benefit from quick access to a range of essential features, including:

• Managing access for visitors and      vehicles;
• Real-time monitoring of buses      serving the community;
• Simplified payments to the      administration;
• Efficient handling of maintenance      and support requests, with real-time updates;
• Booking and managing access to      the swimming pool during the summer season;
• Exploring Cosmopolis Mall, with      details about shops and available offers;
• Centralized notifications, to      always stay updated with community news.

Through MyCosmopolis, the experience of living in Cosmopolis becomes simpler, more organized, and more connected than ever.

To provide you access to the functionalities of the MyCosmopolis application, it is necessary to collect and process certain personal data, such as identification details, contact data, and other relevant information (as detailed below), for managing your relationship within the Cosmopolis community. These data are used for administering the services offered through the application, improving user experience, and communicating relevant information about the residential complex.

By continuing to use the application, you confirm that you have read and understood this notice and that you give your consent for the processing of your personal data in accordance with Regulation (EU) 2016/679 (“GDPR”) and the MyCosmopolis privacy policy. If you do not agree, please do not continue using the application.

PERSONAL DATA CONTROLLERS

The developer of the “COSMOPOLIS” residential complex acts as a “Personal Data Controller” under the General Data Protection Regulation (GDPR), through the “OPUS” group companies, namely SOLAR S.R.L., OPUS LAND DEVELOPMENT S.A., and OPUS LAND RESIDENTIAL DEVELOPMENT S.R.L. (hereinafter referred to as “COSMOPOLIS”), together with the partner company SVN COMMERCIAL REAL ESTATE ADVISORS S.R.L.

CATEGORIES OF DATA PROCESSED

To ensure the functioning of the MyCosmopolis application and facilitate access to available services, we process the following categories of personal data:

• Full name;
• Email address;
• Phone number;
• Home or residence address;
• Identity document data (national      ID, residence permit, or passport), including series and number and      Personal Numeric Code (CNP) or PIN;
• SSN (Social Security Number for      U.S. citizens);
• Proof of ownership of properties      or other assets or collateral (including money) used as a guarantee for      acquiring a property, if applicable;
• Proof of vehicle ownership, if      applicable;
• Utility bills for the property      owned or used, and other accounting/financial documents related to      administration and maintenance of the property and common areas;
• Visitor data.

PURPOSES OF PERSONAL DATA PROCESSING AND LEGAL BASIS

Your personal data are processed for legitimate purposes, necessary for efficiently managing the Cosmopolis community, complying with legal obligations, and ensuring the proper functioning of the services available through the MyCosmopolis application.

GROUP 1 – Contractual & Legal Purposes

• Maintenance and administration of      properties and common areas;
• Fulfilling legal obligations in      case of property acquisition or sale, through collaboration with      specialized departments of the Opus group (sales, accounting, legal,      administration, etc.);
• Transmitting necessary data to      authorities and service providers (notaries, utility providers, waste      management, banks, debt recovery companies, courts, tax authority ANAF,      etc.);
• Managing resident/customer      relationships via the Realtynno back-end CRM system integrated with      MyCosmopolis.

Legal basis:

• Contract performance or      pre-contractual steps (Art. 6(1)(b) GDPR);
• Compliance with legal obligations      (Art. 6(1)(c) GDPR).

GROUP 2 – Operational Communication

• Official updates about the      residential complex;
• Announcements regarding      maintenance or modernization works;
• Emergency notifications or      service interruptions;
• Legal or inspection updates      affecting residents.

Legal basis: Legitimate interest (Art. 6(1)(f) GDPR).

GROUP 3 – Marketing & Community Engagement

• Promotional campaigns within the      Cosmopolis complex;
• Information about events and      contests;
• Managing participation in such      activities.

Legal basis: Explicit consent (Art. 6(1)(a) GDPR), obtained via acceptance in the app.

DATA RETENTION

• For legally mandated processing:      data are kept as required by applicable law.
• For marketing: data are kept      until consent is withdrawn or until termination of property      ownership/usage rights.
• For administrative purposes: data      retention depends on operational needs and GDPR principles.

YOUR RIGHTS

Under GDPR, you have the following rights:

• Right of access;
• Right to rectification;
• Right to restrict processing;
• Right to erasure (“right to be      forgotten”);
• Right to data portability;
• Right to object (e.g., against      marketing or legitimate interest processing);
• Right to file a complaint with      the Romanian Data Protection Authority (ANSPDCP) or the competent courts.

CONTACT FOR DATA PROTECTION REQUESTS

For any requests regarding the processing of your data by Cosmopolis, please contact our Data Protection Officer (DPO), who will respond within 30 days of receiving your written request:

• Email: gdpr@opus.com.ro
• Postal address: SC SOLAR S.R.L.,      Ștefăneștii de Jos, Str. Europa no. 9bis, space 21–23, Corp C, Cosmopolis      Plaza, Cosmopolis Residential Complex, Ilfov County, Romania.