Privacy and Personal Data Protection Policy

 Privacy and Personal Data Protection Policy

This information is provided, in compliance with art. 13 and 14 of EU Regulation 679/2016 (hereinafter "Regulation"), to users (hereinafter: "Users" or "User") of the website in desktop and mobile version and platform of openskyvr.com and associated applications, (hereinafter: "Website and App") owned by Hospinet Infrastructure Private Limited, Data Controller of personal data (hereinafter: "Data Controller") and has the purpose of describing the methods of management of the Website and App with reference to the processing of personal data, as well as to allow Website and App Users to know the purposes and methods of processing personal data by the Data Controller in the event of their provision.

As specified in the General Conditions and Terms of Service, the services offered by the Data Controller are aimed at people over the age of 18. Should the Data Controller become aware of the processing of data of minors under 18 years of age without the valid consent of the parents or legal guardian, it reserves the right to unilaterally interrupt the use of the service offered as well as to delete the data acquired.

Terms that are not defined in this Privacy Policy have the same meaning as described in the General Conditions and Terms of Service.

Principles applicable to the Processing of Personal Data

The Data Controller, pursuant to and for the purposes of the Regulation, informs that the aforementioned legislation provides for the protection of natural persons with regard to the processing of personal data, and that such processing will be based on the principles of correctness, lawfulness, transparency and protection of confidentiality and fundamental rights.

Type of users

There are two types of Users who may access the Site and App: Simple Users and Professional Users.

Simple Users: These are private individuals or property buyers who use the Site and App for purposes different from Professional Users. They typically use the platform to evaluate the shortlisted properties and relevant information identified by their agent for them to evaluate. These users will be provided by user credentials to access the shortlisted properties.

Professional Users: These are real estate agents, construction companies, developers, builders and other professionals in the real estate industry who use the platform to showcase and market their projects and properties to Simple Users. Professional Users gain access to specialized Services only after contacting the Owner to activate their account, which is subject to signing a service contract (hereinafter "Service Contract").

The Owner reserves the right to verify the identity and qualification of both Simple and Professional Users before and after listing publication. Listings may be removed if the Owner’s verification requests are not met.

 Purpose, legal basis of the Processing and Optional Provision

The personal data provided by Users through the use of the Website and App will be processed with their consent, for the purposes described below:

A. Provision of the service for Simple Users:

In order to provide certain services such as showcasing properties for virtual site visits by the Simple Users, the Professional Users will provide access credentials provided by the Owner for viewing shortlisted properties or projects to the Simple Users through the Site and App. The data necessary for Registration are limited to the provision of:

·       Name

·       Surname

·       Email address

·       Phone Number

·       City

·       Country

By accessing their personal section on the Website and App (hereinafter referred to as the "User Profile"), the User may provide additional personal data by way of additional information (e.g. date of birth, gender, residence) that will be collected by the Data Controller if provided.

B. Provision of Advertiser Contact and Search Forwarding services:

In order for Simple Users to get the listings they may be expecting to see they may be required to enter their requirements which will be mapped to suitable Professional Users to ascertain their needs and provide them with user credentials, this service allows you to forward your personal data to real estate agencies, construction companies, other real estate companies and professionals and private users who publish real estate advertisements to Simple users.

In order to facilitate Users in their real estate search, the Search Forwarding service allows the Search Forwarding service to be forwarded to the real estate agencies and other competent companies and professionals in the search area.

C. Provision of the Mortgage Advisory service:

In order for Users to receive advice on financing from banks or financial intermediaries, the Mortgage Advice service allows Users to forward personal data and information on orientations and preferences regarding the location, type, characteristics of the properties and any financing, to receive proposals relating to mortgages and financing.

D. Information, promotional and profiling activities:

In order to allow the User to obtain sector information such as news and curiosities, as well as advertising information, the User may subscribe to the service of Information, promotional and profiling activities to receive informative, promotional and marketing communications on the basis, in some cases, of the activity carried out on the Site and App.

You can unsubscribe from the aforementioned communications at any time by unchecking the following items on the Profile page of each Simple User whenever this facility is provided in the Website and App:

   1. "I would like to receive informative and promotional communications"

   2. "I would like to receive the 1verse.live News newsletter"

   3. "I would like to receive promotional communications and commercial offers from third parties"

The Data Controller will thus be able to carry out analysis of the interests, habits and choices of Users, also in order to be able to send them personalized promotional material on the services offered.

E. Provision of the service for Professional Users:

In order to allow professional operators to qualify, subject to the stipulation of a Service Contract with the Data Controller, as Professional Users, it is necessary for the operator to provide the personal data indicated below, in order to be contacted in order to learn about the services dedicated to professionals:

   1. Name

   2. Surname

   3. Name

   4. Common

   5. Email address

   6. Phone Number

The processing of data for the purposes referred to in letters A to E finds its legal basis in art. 6 (a) of the Related Regulation the data subject has expressed consent to the processing of his or her personal data for one or more specific purposes).

In the case referred to in letter A (II), failure to provide it will not compromise the provision of the service provided therein.

In particular, in the case of letter A (I), failure to provide the data necessary for the registration of the User will make it impossible to provide the services referred to in letters B, C and D below.

Methods of Processing and Storing Personal Data

The Data Controller ensures that personal data are processed in full compliance with the Regulation, using manual, computer or telematic systems. The processing may also be carried out through automated tools designed to store, manage and transmit the data themselves. The data collected and processed will be protected with physical and logical methods such as to minimize the risks of unauthorized access, dissemination, loss and destruction of data, pursuant to Articles 25 and 32 of the Regulation.

The processing of the data will last no longer than is necessary to fulfil the purposes for which they were collected, such as the storage of search criteria, notification, publication of advertisements and contact of professional operators.

Pursuant to art. 7 paragraph 3 of the Regulation, the data subject has the right to obtain at any time the withdrawal of consent to the processing. To request the deletion of their personal data, the interested party may send a request to the email address: product@hospinetinfra.com

If the Data Controller does not receive a request for cancellation, the personal data will be stored for a period not exceeding 10 (ten) years, starting from the date of the last access to the Website and/or App by the User.

Recipients of Personal Data

The personal data collected may be processed by subjects or categories of subjects who act as Data Processors pursuant to art. 28 of the Regulation or who are authorized to process data pursuant to art. 29 of the Regulation.

In addition, for some services, the data may be communicated to companies that collaborate or use the services of the Data Controller (for example, individual proposers for information on properties; banks or credit intermediaries for the provision of mortgages and loans and other financial services related to the purchase and sale of a property), with the sole intention of providing the services requested by the User. In these cases, the companies are independent owners, therefore the Data Controller is not responsible for the processing of data by them. The Data Controller is also not responsible for the content and compliance with the legislation on the protection of personal data by sites not managed by the Data Controller.

Apart from the above-mentioned cases, personal data will not be communicated except to subjects, bodies and authorities to whom communication is mandatory by virtue of legal provisions or regulations.

Transfer of Data to a Third Country or International Organization

The personal data collected through the Website and App may be transferred outside the national territory, only and exclusively for the execution of the services requested through the Website and App and in compliance with the specific provisions of the Regulation.

Some personal data may be shared with recipients located outside the European Economic Area. The Data Controller ensures that the processing of personal data by these recipients is carried out in compliance with the Regulation.

Browsing Data Collection

The computer systems and the technical and software procedures underlying the operation of the Website and App acquire, during their normal operation, some personal data whose transmission is implicit in the access and operation mechanisms and protocols in use on the Internet.

Each time the User connects to the Site and App and each time he calls up or requests content, the access data are stored in our systems, in the form of tabular or linear data files.

This category of data includes, for example, IP addresses, the domain names of the computers used by users who connect to the Site and App, the request by the User's browser, in the form of URI (Uniform Resource Identifier) addresses, the date and time of the request to the server, the method used to submit the request to the server, the amount of data transmitted, the numerical code indicating the status of the response given by the server and other parameters relating to the operating system and the User's IT environment.

These data may be used by the Data Controller for the sole purpose of obtaining anonymous statistical information on the use of the Site and App in order to identify the pages preferred by Users and thus provide increasingly appropriate content and to check its correct functioning. At the request of the Authority, the data may be used to ascertain responsibility in the event of hypothetical computer crimes against the Site and App or its Users.

Information on Cookies, Search Engines and Location Data

Cookies are intended to speed up the analysis of traffic on the Internet, facilitate Users access to the services offered by the Site and App and provide useful and relevant advertising to visitors. With the use of cookies, no personal data is transmitted or acquired and no User tracking systems are used. If you do not want the information you provide to be collected through the use of cookies, you can implement a simple procedure in your browser that allows you to refuse the function of cookies.

The information relating to the real estate proposals included in the Site and App will be visible in the searches carried out in the internal search engine and may be made available to third-party search engines as the Site and App allow the indexing of their content by third-party engines.

If the ad page has already been removed from the Site and App, the cached copy may remain in search results for a few days. The search results are not managed by the Site and App, but the user can report the removal of the page and request the update of the cached copy directly to the search engine itself.

When using the Site and App with the active location feature, the Site and App may collect and process information about your current location. This data is processed anonymously, in a format that does not allow the User to be personally identified, and used for the sole purpose of facilitating the use of certain location-based functions of the Site and Apps. Location services can be activated or deactivated by the User at any time by accessing the settings of their device.

For more information, please see the Use of Cookies page.

Rights of the Data Subject

In particular, in the case of letter A (I), failure to provide the data necessary for the registration of the User will make it impossible to provide the services referred to in letters B, C and D below.

1. confirmation of the existence or otherwise of personal data concerning him/her, even if not yet recorded, in a concise, transparent, intelligible and easily accessible form, in simple and clear language;

2. The indication:

-          the origin of the personal data;

-          the purposes and methods of processing;

-          the legitimate interests pursued by the Data Controller or by third parties;

-          any recipients or categories of recipients of personal data;

-          whether the controller intends to transfer personal data to a third country or an international organisation;

-          the period for which personal data will be retained;

-          the logic applied, as well as the importance and envisaged consequences of such processing for the data subject, in the case of processing carried out with the aid of electronic tools as part of an automatic collection and/or profiling process;

-          the identification details of the Data Controller, the Data Processors, any Designated Representative and the Data Protection Officer (DPO);

-          of the subjects and categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representatives in the territory of the State, data processors or persons in charge;

3. the possibility of lodging a complaint with a supervisory authority;

4. updating, rectification or, when interested, integration of data;

5. the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;

6. the limitation of processing;

7. the portability of personal data concerning him to another Data Controller;

8. the revocation of processing;

9. certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfilment proves impossible or involves the use of means manifestly disproportionate to the protected right;

10. objection, in whole or in part, for legitimate reasons, to the processing of personal data concerning him/her, even if pertinent to the purpose of the collection.

Data Controller and Data Protection Officer

To exercise the rights referred to in the previous point, the data subject may contact the Data Controller and/or the Data Protection Officer at any time for any communications regarding the processing of their Personal Data, or to obtain an updated list of any Data Processors appointed by the Company, by sending communication to the contacts below:

The Data Controller: openskyvr.com, e-mail: product@hospinetinfra.com

The Data Protection Officer (DPO): sivaramp@hospinetinfra.com

Whistleblowing

The reports referred to in Legislative Decree no. 24 of 10 March 2023, on the "Implementation of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and laying down provisions on the protection of persons who report breaches of national law", can be made through the platform accessible at the following link https://italia.1verse.live/whistleblowing, where the relevant procedure and privacy policy are indicated in the appropriate sections.

 Changes

This policy may be subject to change. If we make material changes to the use of your data by the Owner Hospinet Infrastructure Private Limited and we will notify you and publish them prominently on our pages.