Crownburg Development S.R.L. is a European heritage real estate, residential and hospitality company engaged in the identification, acquisition, restoration, development and long-term stewardship of architecturally and culturally significant properties.
At Crownburg Development S.R.L. (“Crownburg Development”, “we”, “us” or “our”), privacy is treated as an integral part of the trust placed in us by clients, investors, partners, advisors, collaborators and visitors to our digital environments.
Crownburg Development is committed to processing personal data lawfully, fairly, transparently and with appropriate discretion and security.
This Privacy Policy and Data Protection Notice explains how Crownburg Development collects, uses, stores, discloses and protects personal data when you visit our website, communicate with us, submit an enquiry, enter into a professional or commercial relationship with us, or otherwise interact with Crownburg Development.
Our processing of personal data is governed principally by Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), Romanian Law no. 190/2018 implementing the GDPR, and other applicable European and national data protection and electronic communications legislation.
For the purposes of the GDPR, the controller of personal data collected through this website is:
Crownburg Development S.R.L. Cluj-Napoca, Romania Unique Registration Code (CUI): 50525317
For questions concerning this Privacy Policy, the exercise of your data protection rights or any matter relating to the processing of your personal data, you may contact Crownburg Development through the contact details published on this website or at:
office@crownburg-development.com
Where another entity, project company, operating company or affiliated entity of Crownburg Development acts as the controller of personal data in connection with a particular project, property, transaction or service, the relevant entity may provide a separate or supplementary privacy notice identifying that entity and the applicable processing arrangements.
The personal data we collect depends upon the nature of your relationship with Crownburg Development.
We may collect and process the following categories of personal data:
Identity data, including your name, title, professional designation, nationality, date of birth and, where required for legitimate verification or compliance purposes, identification documentation.
Contact data, including postal address, email address, telephone number and professional contact details.
Professional and business data, including your organisation, position, professional background, business interests and information relating to your relationship with Crownburg Development.
Investor, transaction and counterparty data, including information relevant to investment discussions, acquisitions, transactions, contractual relationships, beneficial ownership, corporate structures and professional mandates.
Financial data, where relevant, including payment information, bank account details, transaction information and information necessary for financial or regulatory due diligence.
Compliance and due diligence data, where appropriate, including identity verification information, beneficial ownership information, politically exposed person status, sanctions screening information and source-of-funds or source-of-wealth information where such information is reasonably required for a proposed or existing relationship.
Communication data, including correspondence with Crownburg Development, meeting records, enquiries, requests and information voluntarily provided during communications with us.
Technical data, including internet protocol address, browser type and version, device information, operating system, time zone, website access information and related technical identifiers.
Usage data, including information concerning how you interact with our website and digital services.
Marketing and communication preferences, including whether and how you wish to receive information from Crownburg Development.
Crownburg Development seeks to collect only information proportionate to the purpose for which it is required.
Crownburg Development does not ordinarily seek to collect special categories of personal data through its corporate website.
Special category data includes information concerning health, racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, genetic or biometric information used for identification purposes, or information concerning a person’s sex life or sexual orientation.
Where processing of special category data becomes necessary in a particular operational, contractual, hospitality, wellness, employment or compliance context, such processing will take place only where permitted under Article 9 GDPR and subject to the additional safeguards required by applicable law.
Where explicit consent constitutes the appropriate legal basis, that consent will be requested separately and may subsequently be withdrawn.
Crownburg Development may obtain personal data through several channels.
We collect information directly from you when you contact us, submit an enquiry, correspond with us, attend a meeting, provide documentation, enter into negotiations or contractual relationships, participate in due diligence or otherwise communicate with Crownburg Development.
We may collect certain information automatically through our website, including technical and usage information obtained through cookies or comparable technologies, subject to applicable consent requirements.
Crownburg Development may also receive information from third parties, including professional advisers, introducers, family offices, financial institutions, counterparties, service providers, compliance providers, public registers, corporate databases and other publicly available sources where such collection is lawful and relevant to a legitimate purpose.
Where personal data has not been obtained directly from you, Crownburg Development will provide any information required under Article 14 GDPR within the applicable statutory framework.
Crownburg Development processes personal data only where a lawful basis exists under the GDPR.
Depending upon the circumstances, Crownburg Development may rely upon one or more of the following bases:
Performance of a contract or pre-contractual steps. Processing may be necessary to perform an agreement with you or to take steps at your request before entering into an agreement.
Compliance with a legal obligation. Processing may be necessary to comply with legal, regulatory, tax, accounting, court, anti-fraud, anti-money laundering, sanctions or other obligations applicable to Crownburg Development.
Legitimate interests. Crownburg Development may process personal data where this is necessary for legitimate business interests pursued by Crownburg Development or by a third party, provided those interests are not overridden by your fundamental rights, freedoms or interests.
Such legitimate interests may include the protection and administration of our business, evaluation of opportunities and counterparties, management of professional relationships, protection of confidential information, prevention of fraud, security of our systems, defence of legal claims and considered development of our professional network.
Consent. Where processing requires your consent, Crownburg Development will seek a freely given, specific, informed and unambiguous indication of your wishes before conducting that processing.
Where processing is based upon consent, you may withdraw that consent at any time by contacting Crownburg Development at:
office@crownburg-development.com
Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
Crownburg Development may process personal data for the following purposes:
To respond to enquiries and correspondence.
To establish, develop and administer professional, commercial and contractual relationships.
To evaluate potential properties, transactions, investments, partnerships, professional appointments and other opportunities.
To communicate with investors, prospective investors, advisors, partners, clients, purchasers, operators, suppliers and other counterparties.
To conduct appropriate counterparty, integrity, identity and compliance verification.
To prepare, negotiate, execute and administer agreements and transactions.
To manage projects, properties, professional appointments and operational relationships.
To maintain corporate, financial, legal, governance and compliance records.
To protect Crownburg Development, its projects, stakeholders, systems, confidential information and intellectual property against fraud, security threats, misuse and unlawful activity.
To comply with applicable laws, regulations, judicial orders and requests from competent authorities.
To establish, exercise or defend legal rights and claims.
To manage and improve our website, technology and digital infrastructure.
To understand the manner in which our website is used and improve its functionality and performance.
To provide communications concerning Crownburg Development, its work, projects or activities where such communications are lawful and appropriate.
Crownburg Development will not use personal data for purposes materially incompatible with the purpose for which the information was originally collected without establishing an appropriate legal basis and, where required, providing further notice.
Given the nature and scale of transactions that may arise within real estate, investment and hospitality activities, Crownburg Development may conduct proportionate due diligence upon prospective or existing counterparties.
Where appropriate or legally required, this may include verification of identity, corporate ownership and control, ultimate beneficial ownership, sanctions screening, politically exposed person screening, litigation or adverse-information checks, source-of-funds assessment and other integrity or regulatory checks.
Information may be obtained directly from you, from your representatives, from professional advisers, from public registers or from reputable specialist compliance databases and service providers.
Such processing will be conducted only to the extent proportionate to the relevant relationship and on an appropriate lawful basis, including compliance with legal obligations and the legitimate interests of Crownburg Development in protecting the integrity, security and lawful conduct of its activities.
Enhanced due diligence may be undertaken where the nature, jurisdiction, ownership structure or circumstances of a transaction or relationship reasonably warrant additional review.
Crownburg Development follows a restrained approach to communications.
Crownburg Development may contact you regarding its projects, activities or relevant professional matters where you have requested such information, where communications form part of an existing professional or contractual relationship, where applicable law permits reliance upon legitimate interests, or where you have provided consent.
Electronic direct marketing will be conducted in accordance with applicable GDPR and electronic communications requirements, including Romanian Law no. 506/2004 where applicable.
Where consent is required, communications will be sent only after appropriate consent has been obtained.
You may object to direct marketing or withdraw your consent at any time.
Where electronic communications include an unsubscribe mechanism, you may use that mechanism. You may also contact Crownburg Development at:
office@crownburg-development.com
to change your communication preferences.
An objection to marketing will not prevent Crownburg Development from sending communications that are necessary for an existing contractual, legal, operational or professional relationship.
Crownburg Development limits the disclosure of personal information to circumstances in which disclosure is appropriate, necessary and lawful.
Crownburg Development may share personal data with:
Affiliated entities, project companies or operating companies of Crownburg Development where necessary for legitimate corporate or project purposes and subject to appropriate data protection arrangements.
Professional advisers, including lawyers, tax advisers, accountants, auditors, architects, consultants, financial advisers, insurers and other retained professionals who are themselves subject to professional or contractual duties of confidentiality.
Banks, financing providers, investment counterparties and transaction advisers where necessary in connection with a legitimate transaction or relationship.
Technology, hosting, cloud, cybersecurity, communications and administrative service providers acting on behalf of Crownburg Development.
Specialist compliance, identity verification, sanctions-screening and due diligence providers where appropriate.
Competent public authorities, regulators, supervisory authorities, courts or law-enforcement bodies where disclosure is required or permitted by law.
Prospective purchasers, investors, financing parties or successor entities in connection with a corporate transaction, financing, restructuring, merger, acquisition or transfer of business or assets, subject to appropriate confidentiality and data protection safeguards.
Crownburg Development requires processors acting on its behalf to process personal data only in accordance with documented instructions, applicable contractual safeguards and data protection law.
Crownburg Development does not sell or rent personal data to third parties for their independent commercial use.
Crownburg Development conducts and intends to conduct activities across several jurisdictions and may engage professional advisers, technology providers, counterparties and affiliated entities located outside the European Economic Area.
Where personal data is transferred outside the European Economic Area, Crownburg Development will ensure that the transfer takes place in accordance with Chapter V of the GDPR.
Depending upon the destination and circumstances, safeguards may include:
A European Commission adequacy decision;
European Commission Standard Contractual Clauses;
Additional technical, contractual or organisational safeguards where appropriate;
Binding Corporate Rules where applicable to a future group structure; or
A specific derogation permitted by Article 49 GDPR in limited circumstances.
Crownburg Development will assess relevant international transfers with the objective of preserving a level of protection materially consistent with the standards applicable within the European Economic Area.
You may contact Crownburg Development at:
office@crownburg-development.com
for further information concerning safeguards applicable to a particular transfer of your personal data.
Crownburg Development applies appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, misuse or access.
These measures are calibrated according to the nature, sensitivity and context of the information concerned and may include access controls, restricted permissions, confidentiality obligations, secure digital environments, encryption where appropriate, controlled information distribution, backup and recovery measures, security monitoring and periodic review of relevant systems and procedures.
Access to personal data is limited to persons whose role reasonably requires access to that information.
Service providers processing personal data on behalf of Crownburg Development are required to maintain appropriate security and confidentiality standards.
Although no technological environment can provide absolute security, Crownburg Development maintains its information governance with a standard proportionate to the sensitivity of the relationships and information entrusted to it.
Crownburg Development maintains procedures for identifying, assessing, containing and documenting personal data breaches.
Where a personal data breach is likely to result in a risk to the rights and freedoms of natural persons, Crownburg Development will notify the competent supervisory authority without undue delay and, where feasible, within 72 hours after becoming aware of the breach, in accordance with Article 33 GDPR.
Where a breach is likely to result in a high risk to the rights and freedoms of affected individuals, Crownburg Development will communicate the breach to those individuals without undue delay where required under Article 34 GDPR.
Appropriate remedial and preventive measures will be taken following a material incident.
Crownburg Development retains personal data only for as long as reasonably necessary for the purpose for which it was collected and for any subsequent period required to satisfy legal, regulatory, contractual, tax, accounting, reporting, audit, compliance or legitimate evidential requirements.
Retention periods vary according to the category and purpose of the information.
In determining an appropriate retention period, Crownburg Development considers the nature and sensitivity of the personal data, the purpose of the processing, the relationship concerned, applicable limitation periods, statutory retention requirements, regulatory expectations and the need to establish, exercise or defend legal claims.
Where personal data is no longer required and no continuing lawful basis exists for its retention, it will be securely erased, deleted or irreversibly anonymised.
Certain corporate, contractual, architectural, property or heritage records may require long-term or permanent archival retention. Personal information contained within such records will be managed in accordance with applicable data protection principles and retained only where an appropriate legal or legitimate basis exists.
Subject to the conditions and limitations established by applicable law, you may have the following rights in relation to your personal data:
Right of access. You may request confirmation as to whether Crownburg Development processes personal data concerning you and obtain a copy of relevant personal data.
Right to rectification. You may request correction of inaccurate personal data or completion of incomplete information.
Right to erasure. You may request deletion of personal data in circumstances recognised under Article 17 GDPR.
Right to restriction of processing. You may request that processing be restricted in circumstances recognised under Article 18 GDPR.
Right to data portability. Where the legal requirements are satisfied, you may request personal data provided by you in a structured, commonly used and machine-readable format or request its transmission to another controller where technically feasible.
Right to object. You may object, on grounds relating to your particular situation, to processing based upon legitimate interests.
Where personal data is processed for direct marketing purposes, you may object at any time. Following such an objection, your personal data will no longer be processed for direct marketing purposes.
Right to withdraw consent. Where processing is based upon consent, you may withdraw that consent at any time.
Rights concerning automated decision-making. You have the right, in the circumstances established by Article 22 GDPR, not to be subject to a decision based solely upon automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you.
Unless expressly notified in a specific context, Crownburg Development does not use solely automated decision-making producing legal or similarly significant effects in connection with visitors to its corporate website.
You may exercise any of these rights by contacting Crownburg Development at:
office@crownburg-development.com
Crownburg Development will respond within the period prescribed by applicable law, ordinarily within one month following receipt of a valid request. In cases permitted by the GDPR, that period may be extended by a further two months having regard to the complexity and number of requests.
Crownburg Development may request information reasonably necessary to verify your identity before acting upon a request.
The exercise of data protection rights is generally free of charge. Where a request is manifestly unfounded or excessive, the measures permitted by applicable law may apply.
The Crownburg Development website may use cookies and comparable technologies necessary for its operation and, where enabled, technologies used for preferences, measurement, analytics or other functions.
Cookies that are strictly necessary for the operation and security of the website may be used without consent where permitted by law.
Non-essential cookies and comparable tracking technologies will be activated only where the applicable legal requirements, including consent requirements, have been satisfied.
Where a cookie-management interface is provided, you may use it to review or modify your choices.
Detailed information concerning the categories of cookies used, their purposes, duration and relevant third parties will be provided in the separate Cookie Policy available on this website.
The Crownburg Development website may contain links to websites or digital services operated by third parties.
Crownburg Development does not control the privacy practices of independent third-party websites and this Privacy Policy does not govern their processing activities.
We encourage users to review the privacy information provided by the relevant third party before providing personal data through an external service.
The Crownburg Development corporate website and services are directed towards professional and adult audiences and are not designed for children.
Crownburg Development does not knowingly seek to collect personal data from children through its corporate website.
If Crownburg Development becomes aware that personal data concerning a child has been collected in circumstances inconsistent with applicable law, appropriate steps will be taken to address the matter.
If you have concerns regarding the manner in which Crownburg Development processes your personal data, we encourage you to contact Crownburg Development first at:
office@crownburg-development.com
so that the matter can be considered and addressed directly.
You also have the right to lodge a complaint with a competent supervisory authority.
For Crownburg Development S.R.L. in Romania, the principal supervisory authority is:
Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal — ANSPDCP
Further information concerning the authority and its complaint procedures is available at:
Where permitted by the GDPR, you may also lodge a complaint with the data protection supervisory authority in the European Union or European Economic Area Member State in which you habitually reside, work or consider that an infringement has occurred.
Crownburg Development may revise this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, corporate structure, activities, website functionality, technology or the manner in which personal data is processed.
The current version will be published on the Crownburg Development website together with the date of its latest revision.
Where a change materially affects the manner in which personal data is processed, additional notice will be provided where required by applicable law.
Questions concerning privacy, data protection or the exercise of data subject rights may be addressed to:
Crownburg Development S.R.L. Cluj-Napoca, Romania CUI 50525317
Data Protection Contact: office@crownburg-development.com
Crownburg Development regards privacy, confidentiality and the responsible custody of information as continuing obligations throughout every relationship entrusted to the company.