Mutual fulfilment of the contract and access controls


Processing for mutual fulfilment of contracht

For what purpose will your personal data be processed?

CA Immo processes your personal data for the mutual fulfilment of contract, i.e. for conducting property purchases and sales, leasing of property, building maintenance, property valuation as well as for the establishment, fulfilment and termination of other orders placed by you with CA Immo, for the acceptance of services provided by you, but also for invoicing, business-related accounting and archiving and for the accompanying processes inherent in the business relationship between you and CA Immo, such as credit assessment, performance improvements or accompanying support measures.

Origin of data

In addition to the data collected directly from you, CA Immo also processes personal data from other sources:

CA Immo processes personal data received from publicly accessible sources (e.g. commercial register, land register, Internet), or credit rating agencies, brokers and their property management companies. Within the scope of project realisations (lettings with and without fit-out, property project realisations, property acquisitions and sales, etc), CA Immo also processes data that CA Immo receives from other clients and suppliers (e.g. service providers such as brokers, trades, lawyers, etc who work on behalf of clients, or data from subcontractors of CA Immo suppliers).

What is the legal basis on which your personal data is processed?

Insofar as the processing of your personal data for the aforementioned purposes is absolutely necessary for the fulfilment of the contract, fulfilment of the contract (Art 6 (1)(b) GDPR) constitutes the legal basis for the processing. Where data is processed in excess of what is necessary to fulfil the contract and no separate consent (Art 6 (1)(a) GDPR) has been given, applicable legal obligations (Art 6 (1)(c) GDPR), if any, or the legitimate interest of CA Immo (Art 6 (1)(f) GDPR) in such data processing may be the legal basis for processing your data. Such legitimate interest lies, in particular, in the preparation of revenue statistics, direct advertising, the efficient organisation of CA Immo's business processes and the maintenance of customer contacts.

Who does CA Immo pass your personal data on to?

The CA Immo Group is organised according to a matrix organisation with central units in Austria and Germany. Within the CA Immo Group, those departments or employees receive data from customers and suppliers that they need to fulfil their contractual, legal obligations and to safeguard their legitimate interests (supervisory duties, reporting structures, network maintenance).

In addition, CA Immo has concluded agency agreements for its subsidiaries under which personal data of customers and suppliers of the property holding companies may be passed on to the respective management companies.

Moreover, CA Immo operates a contact database for its subsidiaries in which the personal contact data of customers and suppliers of the subsidiaries can be passed on to the management companies.

Finally, CA Immo may be required to pass on your data to contractual partners or service providers as part of its business relationship with you.

A list of categories of recipients and information on possible data transfers to third countries can be found here. These may be located within and outside Europe, but CA Immo will ensure that European data protection standards are always observed when passing on your data outside Europe.

How long will CA Immo keep your personal data?

In general, CA Immo will keep your data for the duration of the performance of the contract. In addition, CA Immo is subject to a variety of retention obligations requiring CA Immo to keep your personal data and data on the contract even after the contract has been terminated, as is the case, for example, due to the retention periods under company law, and CA Immo will keep your data as long as legal claims arising from the business relationship with you can be asserted.

Access controls to the premises of CA Immo, to the properties and construction sites of CA Immo

For what purpose will your personal data be processed?

CA Immo processes personal data (e.g. name, date, person/company visited) as part of access controls to the premises of CA Immo for the purposes of securing buildings and protecting employees and business secrets. Furthermore, CA Immo processes personal data (e.g. name, ID number, company, date and time, photograph to carry out identification checks, video recordings) during access controls to construction sites under the property project realisation of CA Immo in order to secure buildings, to monitor construction sites and to comply with the Employment of Foreign Nationals Act (Ausländerbeschäftigungsgesetz).

What is the legal basis on which your personal data is processed?

If no separate consent (Art 6 (1)(a) GDPR) has been given, any applicable legal obligations (Art 6 (1)(c) GDPR) or the legitimate interest of CA Immo (Art 6 (1)(f) GDPR) in such data processing may be the legal basis for the processing of your data. Such legitimate interest lies, in particular, in securing buildings and in monitoring and access control of CA Immo's properties and construction sites.

Who does CA Immo pass your personal data on to?

Data is exchanged within the Group only to such extent that the management companies and the technical department are enabled to conduct business operations, as well as due to the centralised IT and in the course of an audit. As required, data is passed on to external service providers such as property/building management, IT/video security providers, insurance companies, construction site logistics companies/general contractors (depending on how construction work is executed), authorities, legal representatives & notaries and courts.

How long will CA Immo keep your personal data?

Unless CA Immo is subject to any other statutory retention obligations, CA Immo will keep your data regarding construction site monitoring for up to 12 months after completion of construction or for 12 months in case of access controls. Video material is stored for a maximum of 72 hours. This period may be extended when legal claims are asserted.

What rights do you have in connection with the processing of your personal data?

The General Data Protection Regulation (EU Regulation 2016/679) grants you as data subject certain rights to which we refer you below. Please note that they complement each other, so that you can only request either the correction or completion of your data or their deletion.

Withdrawal of consent 

In the event that CA Immo stores and processes your personal data on the basis of consent (Art 6 (1)(a) GDPR), you are entitled to withdraw your consent at any time. However, this does not affect the lawfulness of the processing up to the time of withdrawal.

Right to access personal data 

You can request information on the origin, the categories, the storage period, the recipients, the purpose of your personal data being processed by CA Immo and the type of processing.

Right to correction and deletion

If CA Immo processes your personal data that is incorrect or incomplete, you can request that it shall be corrected or completed. You may also request the deletion of unlawfully processed data.

Right to restriction of processing

If it is unclear whether your personal data processed is incorrect, incomplete or unlawfully processed, you may request that the processing of your data shall be restricted until this question has been finally clarified.

Right to object

Even if your personal data is correct and complete and processed lawfully by CA Immo, you can object to the processing of this data. However, this is possible only in special situations to be justified by you.

Right to data transferability

You may receive the personal data processed by CA Immo that CA Immo itself has received from you in a machine-readable format specified by CA Immo, or commission CA Immo with the direct transmission of this data to a third party of your choice, provided that this recipient enables CA Immo to do so from a technical point of view and that such data transmission is not subject to unjustifiable efforts, statutory or other secrecy obligations or considerations of confidentiality on the part of CA Immo or third parties.

Right to lodge a complaint

Finally, you are entitled to lodge a complaint with the data protection authority if you believe that the processing of your personal data is in breach of the General Data Protection Regulation (EU Regulation 2016/679).

Who can you contact to assert your rights as a data subject?

To assert the above rights, please contact the CA Immo Data Protection Coordination Team (dsb@caimmo.com) in writing (by letter or e-mail). 

While CA Immo always endeavours to safeguard and protect the integrity of your data, differences of opinion cannot be ruled out. If you believe that CA Immo is not using your data in a permissible manner, you can contact the CA Immo Data Protection Coordination Team (dsb@caimmo.com). You also have the right to lodge a complaint with the data protection authority.