Privacy Policy
Introductory Provisions
This Personal Data Processing Policy (the “Policy”) serves to fulfill the information obligation pursuant to Articles 13, 14, and 26 of Regulation (EU) 2016/679 of the European Parliament and of the Council (the “GDPR”).
This document describes how EPRE Medkova s.r.o., with its registered office at Hanusova 496/6, Michle, 140 00 Prague 4, ID No.: 61534811, registered in the Commercial Register maintained by the Municipal Court in Prague under File No. C 251454 (the “Controller”), processes the personal data of natural persons (the “Data Subject” or the “Client”) in connection with its real estate development activities, the sale of residential and non-residential units, the operation of the website www.rezidence-medkova.cz (the “Website”), the Realpad client portal, and related activities.
Relationship to the ENERGO – PRO Real Estate Group
The Controller is part of a business group with the parent company ENERGO – PRO Real Estate s.r.o. (“EP RE”). Within this group, data processing occurs under two distinct regimes:
1. Joint Controllership (Administration and Sales):
For the purposes of managing business cases in the Realpad CRM system, the Controller and EP RE act as joint controllers (Art. 26 GDPR). EP RE provides the technical platform and administrative support, while the Controller executes the sales. You may exercise your rights with either party; however, the Controller serves as the primary point of contact.
2. Independent Controllership (Group Marketing):
For the purpose of offering other real estate projects within the group, EP RE acts as an independent controller. The transfer of your data to EP RE for this purpose occurs exclusively on the basis of your consent.
Contact Details of the Controller
To exercise your rights under the GDPR or in case of inquiries, you may contact the Controller at:
The Controller has not appointed a Data Protection Officer (DPO), as no such legal obligation has arisen.
Purposes of Processing, Legal Bases, and Retention Periods
The Controller processes personal data to the extent necessary for the purposes set out below.
Contract Negotiation and Sales
- Purpose: Handling inquiries, organizing viewings, managing business cases in the shared Realpad CRM system, preparing and performing contracts (reservation agreements, future purchase agreements, purchase agreements), client changes, financing, and handover of units. These activities are carried out under joint controllership with EP RE.
- Legal Basis: Art. 6(1)(b) GDPR (performance of a contract and pre-contractual measures).
- Retention Period: For the duration of the contractual relationship and subsequently for 10 years (statutes of limitation for potential disputes). If no contract is concluded (inquiry only), for 6 months from the last communication.
Compliance with Legal Obligations
- Purpose: Bookkeeping, tax agenda, compliance with AML (Anti-Money Laundering) obligations, and archiving.
- Legal Basis: Art. 6(1)(c) GDPR.
- Retention Period: In accordance with the periods stipulated by legal regulations (e.g., 10 years for tax documents and AML identification).
Legitimate Interests of the Controller
- Purpose: * Defense of legal claims (debt collection, litigation).
- Direct marketing to existing customers (so-called "soft opt-in" regarding the same project).
- Basic website analytics and IT system security.
- Transfer of data to the property manager/Owners' Association (SVJ) to ensure property management.
- Legal Basis: Art. 6(1)(f) GDPR.
- Retention Period: For the duration of the legitimate interest, but no later than until a legitimate objection is raised.
Marketing Based on Consent
- Purpose: * Sending newsletters to non-clients.
- Transfer of data to EP RE (as an independent controller) for the purpose of offering other real estate projects of the group (cross-selling).
- Marketing cookies.
- Legal Basis: Art. 6(1)(a) GDPR.
- Retention Period: 36 months from the granting of consent/last interaction or until consent is withdrawn.
Scope of Processed Data
We process only data necessary for the given purpose:
- Identification Data: Name, surname, title, date of birth, personal identification number (if required by the Cadastral Act or AML Act), ID/passport number, permanent residence address.
- Contact Data: E-mail, telephone number, correspondence address.
- Data Concerning the Object of Purchase: Unit number, price, payment schedule, financing data (mortgage), client changes.
- Technical Data: IP address, logs, cookies (upon visiting the Website).
Recipients of Personal Data
Your data is disclosed only to the extent necessary to the following categories of recipients:
Joint Controllers:
- Parent company EP RE to the extent of Realpad CRM management and sales support. Sharing is based on a joint controllership agreement for the purpose of efficient inquiry processing and contract performance.
Independent Controllers:
- Parent company EP RE for the purpose of direct marketing of other group development projects. Transfer occurs only based on your explicit consent. EP RE subsequently processes the data according to its own privacy policy.
Other Recipients:
- Public authorities (Cadastral Office, Financial Office, courts).
- Banks (financing, escrows).
- Property management company and the Owners' Association (SVJ).
- Processors: IT service providers (hosting, technical operator of the Realpad platform), external accountants, marketing agencies.
Transfer to Third Countries
Data is primarily processed within the EU/EEA. If we utilize tools from providers in third countries (notably the USA), the transfer is based on:
- An adequacy decision (EU-US Data Privacy Framework), provided the provider is certified.
- Standard Contractual Clauses (SCCs) with the adoption of supplementary security measures.
Cookies and Profiling
The Website uses cookies.
- Necessary Cookies: Required for the technical operation of the website (not subject to consent).
- Analytical and Marketing Cookies: Used only with your consent.
- Profiling: The Controller may perform client segmentation (profiling) for marketing purposes based on preferences (e.g., 2+kk or 3+kk). This does not constitute automated decision-making with legal effects under Art. 22 GDPR. You may object to such profiling at any time.
Rights of the Data Subject
As a data subject, you have the following rights, which you may exercise via e-mail at realestate@energo-pro.com:
- Right of Access: To obtain confirmation as to whether and which data we process.
- Right to Rectification: To request the correction of inaccurate data.
- Right to Erasure (“Right to be Forgotten”): If the purpose of processing has ceased or consent was withdrawn and no other legal ground for retention exists.
- Right to Restriction of Processing: In cases of contested data until resolution.
- Right to Data Portability: To obtain data in a structured format (applies to automated processing based on contract/consent).
- Right to Object: If we process data based on legitimate interest (e.g., direct marketing to existing clients), you may object and we will terminate the processing. For direct marketing (including related profiling), we will terminate processing immediately.
- Right to Withdraw Consent: At any time, without penalty.
You also have the right to lodge a complaint with the Office for Personal Data Protection (Pplk. Sochora 27, 170 00 Prague 7, www.uoou.cz).
Final Provisions
This Policy is valid and effective as of December 1, 2025. The Controller reserves the right to amend the Policy in the future; Clients will be informed of material changes (e.g., via e-mail or a notice on the Website).
The provision of personal data for the purpose of concluding a contract is a contractual requirement. Failure to provide data may result in the inability to conclude a contract or make a reservation. The provision of data for marketing purposes (beyond the scope of legitimate interest) is entirely voluntary.