This Privacy Policy (the “Policy”) has been prepared in accordance with the Law of the Republic of Moldova No. 195/2024 on the Protection of Personal Data and other applicable legislation of the Republic of Moldova concerning personal data protection.

This Policy describes how SET Real Estate Agency (“Operator”, “SET”, “we”, “us” or “our”) collects, processes and protects personal data when users access and use https://set.md/.

1. General Provisions

1.1. SET respects every person's right to privacy and family life and takes appropriate legal, organizational and technical measures to protect personal data.

1.2. This Policy applies to information that the Operator may receive about Users when they visit or use set.md, as well as when they contact SET through contact forms, email, telephone, messaging applications or other available communication channels.

1.3. Personal data is processed only to the extent necessary for specific, defined and legitimate purposes.

1.4. By using the website, the User confirms that they have read this Policy. Where applicable law requires separate consent for the processing of personal data, such consent will be obtained separately.

2. Definitions

2.1. Personal Data means any information relating directly or indirectly to an identified or identifiable natural person.

2.2. Processing means any operation performed on personal data, including collection, recording, organization, storage, modification, use, disclosure, transfer, deletion and destruction.

2.3. Operator means a natural or legal person who determines the purposes and means of processing personal data.

2.4. User means any natural person visiting or using the set.md website.

2.5. Consent means a freely given, specific, informed and unambiguous indication of the User's wishes by which the User agrees to the processing of personal data for specified purposes.

2.6. Anonymized Data means data that does not allow a specific User to be directly or indirectly identified without additional information.

2.7. Cookies are small text files stored on the User's device when visiting a website, allowing the website to function properly, analyze traffic and remember certain settings.

3. Information About the Operator

Company / Brand: SET Real Estate Agency
Website: https://set.md/
Address: Tighina 13, Chisinau, Moldova, MD-2001
Phone: +373 78 991 991
Email: hr@set.md — for employment-related communication; for personal data protection requests, Users may use the contact information published on the website or contact SET by telephone.

4. Personal Data That May Be Processed

Depending on the nature of the User's request, the Operator may process:

• first and last name;

• telephone number;

• email address;

• address or other information concerning a property;

• User preferences regarding property searches;

• information provided by the User in a message or form;

• information required to identify suitable properties;

• information provided by property owners;

• information required to prepare a consultation or offer;

• information submitted as part of a recruitment process;

• other information voluntarily provided by the User.

The Operator does not request excessive personal data where such data is not necessary for the relevant processing purpose.

When visiting the website, technical and anonymized information may also be collected automatically, including IP address, browser type and version, device type, operating system, browser language, date and time of visit, pages visited, referral source and technical interaction data.

5. Purposes of Personal Data Processing

Personal data may be processed for the following purposes:

• receiving and processing requests;

• contacting Users;

• providing consultations;

• selecting suitable properties;

• arranging property viewings;

• discussing property purchase, sale or rental conditions;

• preparing offers;

• communicating with property owners;

• processing investor requests;

• organizing and supporting real estate transactions;

• recruitment and candidate evaluation;

• improving the website and its functionality;

• analyzing website traffic and advertising performance;

• preventing fraud, abuse and security incidents;

• complying with legal obligations.

The website may use third-party services such as Google Analytics, Google Ads, Google Tag Manager, Meta Pixel and related technologies for analytics and advertising purposes.

6. Legal Bases for Processing

Personal data may be processed on one or more legal grounds provided by the legislation of the Republic of Moldova, including:

• the User's consent;

• taking steps at the User's request prior to entering into a contract;

• performance of a contract;

• compliance with legal obligations;

• protection of the legitimate interests of the Operator or third parties, where such interests are not overridden by the rights and freedoms of the User;

• other legal grounds provided by applicable legislation.

Where processing is based on consent, the User may withdraw consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

7. Use of Cookies

The set.md website may use Cookies and similar technologies.

Cookies may be used to ensure the proper functioning of the website, analyze traffic, improve the User experience and measure advertising effectiveness.

Depending on their purpose, Cookies may be:

• necessary Cookies — required for the technical operation of the website;

• analytics Cookies — used to analyze website traffic and User interaction;

• advertising Cookies — used to measure advertising effectiveness and campaign performance.

The website may use Google and Meta technologies, including Google Analytics, Google Ads, Google Tag Manager and Meta Pixel.

These services may place their own Cookies or collect technical information concerning the User's interaction with the website in accordance with their respective privacy policies.

Users may restrict or disable Cookies through their browser settings.

Disabling certain Cookies may affect the operation of some website functions.

Where applicable law requires prior consent for specific categories of Cookies, such technologies will only be used after the required consent has been obtained.

8. Disclosure of Personal Data to Third Parties

8.1. The Operator does not sell Users' personal data to third parties.

8.2. Where necessary, personal data may be provided to service providers acting on behalf of or under instructions from the Operator, including:

• hosting providers;

• IT service providers;

• developers and technical support specialists;

• analytics providers;

• advertising technology providers;

• other data processors whose involvement is necessary for website operation or service provision.

8.3. The Operator takes appropriate measures to ensure the protection of personal data when engaging data processors.

8.4. Personal data may be disclosed to public authorities or other persons where required or permitted by the legislation of the Republic of Moldova.

9. International Transfers

Due to the use of international analytics, advertising, technical and infrastructure services, personal or technical data may be processed in other countries.

Where personal data is transferred internationally, the Operator takes the measures required by the legislation of the Republic of Moldova to ensure an appropriate level of protection.

Such transfers may involve Google, Meta and other technology partners used by the website.

10. Data Retention

Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by law.

The retention period may depend on:

• the purpose of the request;

• the nature of the services provided;

• contractual relationships;

• legal requirements;

• the need to protect the legitimate interests of the Operator.

After the purposes of processing have been fulfilled, personal data will be deleted, destroyed or anonymized unless continued retention is required by law.

11. Data Security

The Operator applies appropriate technical and organizational measures to protect personal data against:

• unauthorized access;

• unlawful use;

• alteration;

• disclosure;

• destruction;

• accidental loss;

• other forms of unlawful processing.

Such measures may include access restrictions, information system security measures, backups, access control and other measures appropriate to the nature and risks of processing.

12. User Rights

Under applicable legislation, Users may have the right to:

• obtain information about whether their personal data is being processed;

• access their personal data and information concerning its processing;

• request correction of inaccurate or incomplete data;

• request deletion of personal data where permitted by law;

• request restriction of processing in cases provided by law;

• object to certain types of processing;

• withdraw previously given consent;

• where provided by law, receive personal data in a structured format and request its transfer to another operator;

• lodge a complaint with the National Center for Personal Data Protection of the Republic of Moldova (CNPDCP) if the User believes their data protection rights have been violated.

13. Exercising User Rights

Users may exercise their rights by contacting the Operator using the contact details published on set.md.

Requests should preferably include:

• first and last name;

• contact details;

• description of the request;

• information necessary to identify the relevant interaction or request.

The Operator may request additional information to verify the identity of the requester where necessary to prevent unauthorized access to personal data.

Requests will be handled within the time limits and according to the procedure established by applicable legislation of the Republic of Moldova.

14. User Responsibility

Users are responsible for ensuring that the personal data they provide is accurate and up to date.

Users must not provide personal data belonging to third parties through website forms without an appropriate legal basis or consent where such consent is required by law.

15. Third-Party Websites

The website may contain links to third-party websites, social networks, messaging applications and other external services.

The Operator is not responsible for the content, security or personal data processing practices of third-party resources.

Users are advised to review the privacy policies of such third-party resources before using them.

16. Changes to This Policy

The Operator may periodically update this Policy due to changes in legislation, technologies, website functionality or personal data processing practices.

The updated version becomes effective upon publication on the website unless otherwise stated.

Continued use of the website after publication of an updated version constitutes acknowledgment of the updated Policy.

17. Contact Information

SET Real Estate Agency

Address: Tighina 13, Chisinau, Moldova, MD-2001

Website: https://set.md/

Phone: +373 78 991 991

Email: hr@set.md

18. Final Provisions

This Policy is effective from the date of publication on the website and remains in force until replaced by a new version.

The current version of the Policy is available on:

https://set.md/

Last updated: August 23, 2026.