PROIEX Privacy Notice

Document key: privacy_notice

Document version: 1.1

Effective date: [PUBLICATION DATE]

1. Who is responsible for your data

[PROIEX EU LEGAL NAME] [LEGAL FORM], registered at [REGISTERED ADDRESS] under number [REGISTRATION NUMBER], is the controller for the PROIEX website, user accounts and Platform workflow unless this notice or a transaction-specific notice identifies another controller (“PROIEX”, “we”, “us” or “our”).

The Albanian operating company, licensed real-estate intermediary, notary, bank, identity-verification provider and other transaction participants may be separate controllers for processing they determine independently. Their identity and role will be shown before the relevant service or disclosed in the applicable transaction document. [PROIEX ALBANIA LEGAL NAME] acts as [CONTROLLER / JOINT CONTROLLER / PROCESSOR—COMPLETE AFTER ROLE ASSESSMENT] for [DESCRIBE PROCESSING].

Privacy questions and rights requests: privacy@proiex.com Postal address: [PRIVACY POSTAL ADDRESS] Data Protection Officer: [NAME AND CONTACT, ONLY IF APPOINTED]

This notice is information about processing. Acknowledging it is not consent. Where consent is required, we ask for it separately and explain how to withdraw it.

2. Who and what this notice covers

This notice applies to website visitors, account holders, buyers, seller representatives, notaries, independent construction supervisors, organisation members and invitees, property owners, beneficial owners and directors whose details are supplied for business verification, support contacts and other people whose data enters a PROIEX workflow.

Depending on your relationship with us, we process:

• identity and contact data, including name, date of birth, nationality, residence, email, telephone number and address;
• account, role, organisation, authority, licence, professional-qualification and authentication data;
• identity-verification data, including provider session identifiers, status, extracted identity fields, document class, issuing country, expiry, fraud or review indicators, and identity-document or proof-of-address files where the workflow requires them;
• company, beneficial-owner, representative-authority and seller due-diligence data;
• property, listing, cadastral, ownership, occupancy, price and due-diligence information;
• transaction, appointment, power-of-attorney, notarial, signature, envelope, document and audit-trail data;
• mortgage-support data, such as proof of income, credit report, proof of address and the documents selected for a mortgage workflow;
• off-plan milestone data, including agreed deliverables, developer submissions, photographs, video, technical documents, inspection appointments, supervisor observations, review outcomes and reports;
• payment and escrow workflow data, including amount, status, reference and limited payer/payee details; PROIEX does not need your online-banking credential;
• messages, complaints, support-chat contents and communications;
• device and security data, such as IP address, request identifiers, cookie choices, login history and hashed user-agent information;
• legal evidence, including the exact documents and affirmation presented when terms are accepted; and
• optional analytics, map, environmental, translation or similar feature data described at the point of use and in the Cookie Notice.

Please do not upload information that the relevant workflow does not request. Property documents may contain data about owners, occupants or other third parties. The person supplying them must have a lawful basis and must provide any required notice to those people.

3. Why we use data and our legal bases

Where we rely on legitimate interests, you may ask for information about the balancing assessment and may object as described in section 13. We will not describe identity checks as a legal obligation unless the particular PROIEX entity and workflow are actually subject to that obligation.

4. Identity verification and biometric data

PROIEX selects Persona or Didit for the applicable identity or proof-of-address workflow. Before launch, the interface identifies the selected provider and links its own notice. The provider may collect an identity document, selfie, video/liveness signals, facial geometry, device information and proof-of-address material directly from you. It returns verification results and selected extracted fields to PROIEX.

PROIEX normally stores the provider name, inquiry/session identifiers, status, reasons, name/address match fields and minimised document metadata. In a mortgage workflow, PROIEX may also retrieve and store full-size identity-document front/back images and proof-of-address material in the transaction document package. Assigned notaries and other specifically authorised transaction participants can receive those documents where needed for their role. This is explained before retrieval or disclosure.

Identity-document images and face/liveness data can be highly sensitive. Before enabling production processing, PROIEX will document the applicable Article 6 basis and Article 9 condition. Where explicit consent is the chosen Article 9 condition, it is requested separately from account terms, recorded independently and can be withdrawn for future processing. We explain whether another verification route is available and what service cannot be provided if identity cannot be established. Withdrawal does not make prior lawful processing unlawful and may not require deletion of evidence that another legal ground requires us to retain.

The provider can act as our processor for instructed verification and can also act as an independent controller for limited purposes identified in its notice, such as meeting its own legal duties or preventing misuse of its service. See the Service Provider List and the provider notice shown in the verification flow.

5. Automated processing and human review

Provider results and Platform rules can automatically change a workflow status, request more information, prevent progression or refer a case for review. We do not permit a solely automated decision with legal or similarly significant effect unless it is necessary for a contract, authorised by law or based on explicit consent, and the required safeguards are in place.

If a verification or risk result materially affects you, you may contact support@proiex.com to request an explanation, provide additional information and ask for review by an authorised person. A bank, notary or identity provider may make its own decision under its own notice.

6. Where data comes from

We receive data:

• from you and people acting for you;
• from an organisation owner or administrator who invites you or supplies representative/beneficial-owner information;
• from Persona or Didit and other providers you use in a workflow;
• from sellers, buyers, agents, notaries, supervisors, banks and payment participants in the same transaction;
• from public registers, cadastral or company records and other lawful verification sources;
• from your browser, device and security interactions; and
• from documents and communications submitted through the Platform.

If another person gives us your data, we use it only for the disclosed workflow, verification, security and legal purposes. You may contact us for more detail, subject to rights and confidentiality that protect others.

7. Data you must provide

Fields and documents marked as required are needed to create or secure the requested account, establish identity/authority, comply with a confirmed legal duty, or perform the selected transaction step. Without basic identity, contact and authentication data we cannot create an account. Without required verification, property, professional or transaction evidence, we may be unable to approve the relevant role or continue that workflow. Optional fields and optional processing are identified separately; declining them does not remove a service unless the information is genuinely necessary for that service.

8. Who receives data

Access is role-based and limited to what is reasonably needed. Recipients may include:

• the buyer, seller representative, assigned PROIEX agent, assigned notary, assigned supervisor and authorised organisation members participating in a transaction, limited to the information needed for their role;
• an identified bank only when a real bank integration or user-directed transfer is enabled and the user has been told what will be sent; the current mortgage-document collection feature must not be described as a completed bank submission by itself;
• identity, signature, notarial technology, payment, communications, support, analytics, hosting, storage, security, map and translation providers listed in the Service Provider List;
• professional advisers, auditors, insurers and prospective corporate transaction advisers under confidentiality safeguards;
• courts, regulators, law-enforcement bodies and public authorities where disclosure is required or lawfully necessary; and
• a successor in a genuine merger, reorganisation or sale, subject to confidentiality, notice and applicable rights.

We do not sell personal data. We do not allow a service provider to use transaction documents for its own advertising.

9. International transfers

Data may be processed in the EEA and in Albania. Albania is outside the EEA and must not be treated as covered by an EU adequacy decision. Some providers or their subprocessors may process data in the United States or another country.

Where the GDPR requires a transfer safeguard, we use an applicable adequacy decision, the European Commission's Standard Contractual Clauses, approved Binding Corporate Rules or another lawful mechanism, together with supplementary safeguards where necessary. The Service Provider List identifies known locations and the mechanism after contract verification. You may request information about a safeguard or a copy with confidential material redacted at privacy@proiex.com.

10. How long we keep data

We retain personal data only for the shortest period compatible with the purpose, legal duties and establishment or defence of claims:

• ordinary account and profile data: while the account is active and then for the applicable contract/claim limitation period, with unnecessary fields deleted or isolated earlier;
• unsuccessful or abandoned onboarding data: for a short anti-fraud and support period set in the retention schedule, then deleted or anonymised unless a legal hold applies;
• verification data and documents: according to the documented KYC/identity purpose, provider configuration, legal-duty assessment and claim period; raw biometric material is not retained by PROIEX longer than required for that purpose;
• property and transaction documents, signatures, construction-milestone evidence and reports, notarial and payment evidence: for the period required by the relevant property, tax, accounting, professional, escrow and limitation rules;
• legal acceptance records and exact accepted document versions: for the life of the agreement and the period necessary to prove it; network evidence such as encrypted IP data is held separately and purged earlier;
• security and access logs: for a risk-based security period, extended only for an incident, fraud investigation or legal hold;
• consent and objection records: while needed to honour and prove the choice; and
• support and complaint records: until resolution and for the applicable claim or regulatory period.

The internal retention schedule must set and technically enforce the exact periods before publication. When retention ends, we securely delete or irreversibly anonymise data, including instructing processors where applicable. Backups age out under a restricted backup cycle. A deletion request does not override a lawful retention duty or legal hold; we will explain any refusal or restriction.

11. Security

We use proportionate technical and organisational measures, including transport encryption, access controls, role separation, audit logging, secret management, backups and provider due diligence. No internet service can guarantee absolute security. Please use a unique password, protect authentication codes and report suspected compromise to security@proiex.com.

12. Cookies and communications

Necessary cookies support login, session refresh, request-forgery protection and consent choices. Optional vendors are controlled through Cookie Settings. Details, storage names and choices are in the Cookie Notice.

Service and security messages are not marketing and may be necessary to operate your account or transaction. You can opt out of marketing at any time without losing service messages.

13. Your rights

Subject to the GDPR and applicable limitations, you may:

• access your personal data and obtain a copy;
• correct inaccurate or incomplete data;
• request erasure;
• restrict processing;
• receive data you supplied in a portable format where the right applies;
• object to processing based on legitimate interests and object at any time to direct marketing;
• withdraw consent prospectively as easily as it was given;
• request the safeguards used for an international transfer; and
• request human intervention, express your view and contest a qualifying automated decision.

Send a request to privacy@proiex.com. We may ask for information needed to verify identity and authority, but we will not collect unnecessary identification. We normally respond within one month; the GDPR permits an extension for complex or numerous requests, in which case we explain it within the first month. Rights can be limited where law protects another person's rights, professional secrecy, legal claims or mandatory records.

You may complain to [LEAD SUPERVISORY AUTHORITY AFTER EU ESTABLISHMENT IS CHOSEN], [ADDRESS / WEBSITE]. You may also contact the supervisory authority where you live or work or where the alleged infringement occurred.

14. Children

PROIEX accounts and property transactions are for people aged 18 or over. Do not create an account or submit identity data if you are under 18. Contact us if you believe a child's data has been supplied incorrectly.

15. Changes to this notice

We may update this notice to reflect a change in processing, law, providers or safeguards. We publish the new version and effective date. If a change materially affects you, we give prominent or direct notice before it takes effect where required. A notice update does not create a new processing purpose or remove a right; where consent or a new agreement is required, we ask separately.

Last updated: [LAST UPDATED DATE]