1. INTRODUCTION

The purpose of this privacy policy (“Privacy Policy” or “Policy”) is to outline the organisational and technical procedures, as well as measures for the protection of personal data, including the security, storage, and management of personal data by the structures of the Albanian Branch of Fundway LLC.

1.1 INFORMATION ABOUT THE DATA CONTROLLER

The Albanian Branch of Fundway LLC, registered in the Commercial Register with NUIS: M22316001A, with its business address at “Brigada VIII“, Pallati 8/1, Kati 4 Apartamenti 14, Tirana, Albania”, is engaged in various real estate activities, including but not limited to construction activities, economic activities in the real estate sector, design and construction of civil or industrial buildings, and management of project implementation of this nature for its own account and for third parties, involved in investing in urban, tourism, or residential area development projects, or investments of any nature, whether in the development of real estate in general, as well as other related activities.

1.2 SCOPE OF APPLICATION

This Privacy Policy applies solely to personal data processed as a result of the use of the website (“webpage” or “website”) www.fundway.com by individuals who visit it.

This Policy does not apply to information collected:

• through any other form, or websites operated by third parties;
• by any third party, including through sites or applications containing links that direct to this website.

1.3 PURPOSE AND LEGAL BASIS

In Albania, there is extensive legislation for the protection of personal data, the implementation of which is fundamental to the conduct of Fundway’s commercial activities.

This Policy is based on the following national legal framework:

• The Constitution of the Republic of Albania, Articles 15-58.
• Law No. 9887, dated 10.03.2008, “On the Protection of Personal Data,” as amended (“Personal Data Protection Law”).
• Orders, Guidelines, and Decisions issued by the Commissioner for the Right to Information and Protection of Personal Data (“Data Protection Commissioner” or “Commissioner”), accessible on the official website of this institution www.idp.al.
• Other applicable legal and sub-legal acts relevant to Fundway’s business activities, hereinafter referred to as the “Applicable Law.”

The purpose of the Privacy Policy is to set forth the general principles and organizational and technical measures for the protection, storage, security, and management of personal data that are collected and processed through the website as follows www.fundway.com.

It applies to all data processed by Fundway through this website www.fundway.com in accordance with the Personal Data Protection Law. Any processing of your data collected through this website is conducted in compliance with the Applicable Law.

If you have any questions, concerns, or seek information regarding your personal data collected through this website, please contact us through one of the contact methods provided in the “Contact Us” section of this Privacy Policy.

2. DATA PROCESSING THROUGH THE WEBSITE

The following section details the specific types of personal information we collect through this website, the reasons for collecting this data, and how we use it to enhance your experience and provide our services.

2.1 PURPOSES OF DATA PROCESSING THROUGH THE WEBSITE

We use your personal data to help us respond to your inquiries or expressions of interest and to ensure that we assist you in finding the right property that fits your needs.

In compliance with the Applicable Law, personal data is processed only for one of the following purposes:

To fulfill our contractual obligations in accordance with the terms and conditions of the website

This includes instances where we need to address your requests, questions, or expressions of interest regarding the real estate properties displayed on our website. In order to respond to your inquiries, we will use the contact information you provided through the contact form available on the website in section Contact Us as listed in section 2 of this Policy.

For the fulfilment of a legal obligation of Fundway.

In order to address your complaints or requests for information regarding the personal data we process, in compliance with the Personal Data Protection Law.

For pursuing the legitimate interests of Fundway as a result of the company's business operations.

To enhance your experience while using our website, Fundway collects and uses your personal information to:

• understand your interests and send you tailored content, such as notifications about events, discounts, and offers, in the event that we have obtained your express consent for this purpose in accordance with Applicable Law.
• assess your interests and adjust our marketing accordingly, in the event that we have obtained your express consent for this purpose in accordance with Applicable Law.
• display advertisements or send promotions via e-mail, and we may cooperate with third parties to facilitate this process, in the event that we have obtained your express consent for this purpose in accordance with Applicable Law.

You may withdraw your consent to receive the above communications at any time by simply clicking the "Unsubscribe" button located in any email that has been sent to you.

2.2 METHODS OF COLLECTING PERSONAL DATA THROUGH THE WEBSITE AND TYPES OF DATA PROCESSED FOR EACH CASE

2.2.1 THROUGH REQUESTS, INQUIRIES, OR EXPRESSIONS OF INTEREST SUBMITTED ON THE WEBSITE

We may collect your personal data when you send us a request, inquiry, or expression of interest via our website regarding one of our properties. In this context, we collect the following personal data:

• Name and surname,
• Personal number;
• Place of residence;
• Email address,
• Your address,
• Postal Code,
• Phone number,
• Details of your request, in line with our legitimate business interests..

In certain cases, your inquiry may relate to a specific service request, such as raising a question about a particular property.

For such requests, we need to use your personal data to assist us in responding to your inquiry and fulfilling our contractual obligations, following the terms and conditions of the requested service.

2.2.2 CONTACT

Fundway continuously takes the necessary steps to ensure your satisfaction with the use of our website.

To help us respond to your comments or complaints, we collect the following personal information:

• Name and Surname,
• Place of residence,
• Email address,
• Your address,
• Phone number,
• Details of your request, in line with our legitimate business interests.

3. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES

The recipients of your data collected through the website are solely those individuals at Fundway who are authorized and trained to process such data in accordance with legal and regulatory requirements.

In addition to these individuals, contractors (primarily Information Technology and Communication service providers, as well as back-office services) may also have access to your data to the extent necessary to perform the respective service.

All processors, within the scope of providing their respective services, are obligated to process the data based on the agreement they have entered into with Fundway for data processing and to maintain the confidentiality of your data.

If there is a legal or regulatory obligation from public authorities, these authorities may also be recipients of your data.

4. TRANSFER OF YOUR DATA TO RECIPIENTS IN OTHER COUNTRIES

The transfer of data to third countries (outside the European Economic Area - EEA) can only occur when necessary, if required by law, or if you have provided your explicit consent. The transfer of your data to a third country can only take place after obtaining authorization from the Commissioner, in accordance with the Applicable Law.

5. STORAGE TIME OF YOUR DATA COLLECTED THROUGH THE WEBSITE

We process your personal data for as long as necessary and reasonable to respond to your requests, inquiries, complaints, or expressions of interest submitted through this website. If your expression of interest in a real estate property is not followed by the signing of a reservation agreement for the right to purchase the said property, we will delete your data immediately, unless you have given consent for them to be stored in our database. Data archiving is subject to time limitations.

For more information regarding the storage time of your personal data, please contact us using the contact details provided in section Contact Us.

6. SECURITY OF YOUR PERSONAL DATA

Fundway has implemented appropriate organizational and technical measures to protect your personal data from unlawful or accidental destruction, accidental loss, unauthorized access or dissemination, particularly when data processing is conducted over a network, and from any other form of unlawful processing.

Fundway takes the following specific security measures:

• Defining roles and responsible individuals within the company for the use of data;
• Data usage is conducted under the orders of responsible individuals;
• Regularly instructing and training staff, without exception, on their obligations in accordance with the Personal Data Protection Law and internal data protection regulations, including data security regulations;
• Prohibiting unauthorized individuals from entering its premises;
• Access to data and programs is granted only to authorized personnel;
• Activation of data processing equipment is only done with authorization from the Responsible Person, and each device is secured with preventive measures against unauthorized activation;
• Recording and documenting modifications, corrections, deletions, transmissions, updates, etc.;
• Other security measures in compliance with the Applicable Law.

For more information, please contact us using the contact details provided in section Contact Us of this Privacy Policy.

7. YOUR RIGHTS AS A DATA SUBJECT

The dissemination or communication of personal data is carried out in accordance with the purpose for which these data were collected. In accordance with the Applicable Law, every individual has the right to access their personal data processed through a written request.

You may contact Fundway at any time to exercise your rights as a data subject, as follows:

a) the right to access your personal data collected through this website;
b) the right to request the correction or deletion of your personal data;
c) the right to object to automatic decision-making on your personal data;
d) the right to object to the processing of your personal data;
e) the right to complain about the processing of your personal data;
f) the right to compensation for damage, in accordance with the Applicable Law

The request must contain sufficient data to prove your identity as a requester. Fundway, within 30 days from the date of receipt of the request, informs the data subject or explains to him the reasons for not providing the information.

Any request to exercise your rights as a data subject should be sent to the contact person assigned by Fundway as follows:

Email: info@fundway.com

8. PRIVACY POLICY UPDATES

Fundway may adopt changes to this Privacy Policy from time to time. Your continued use of our website constitutes acceptance of these changes, so please check the Policy regularly for updates.

9. CONTACT US

For any questions, concerns, complaints, or requests to exercise your rights as a data subject in accordance with the Applicable Law, please contact the contact person as follows: Email: info@fundway.com