On 25 May 2018, a new European data protection regulatory framework was introduced, i.e. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/ 46/EC (General Data Protection Regulation) (OJ EU L 119 of 4 May 2016, p. 1) (“GDPR”).
Accordingly, we would like to inform you about the processing of personal data that you provide to us, notably in connection with your stated request to receive marketing communications, including offers regarding our developments.
This Privacy Policy has been produced by Polski Holding Nieruchomości S.A., with its registered office at the address al. Jana Pawła II 12, 00-124 Warsaw, registered in the National Court Register under the number 0000383595 (hereinafter referred to as the “Controller” or “PHN”), and is addressed to persons interested in our property offers. In our capacity of Controller, we will process your personal data for direct marketing purposes, including the presentation of products offered by PHN.
Who is responsible for your personal data and how can you contact us?
1. The Personal Data Controller is Polski Holding Nieruchomości S.A., with its registered office at the address al. Jana Pawła II 12, 00-124 Warsaw.
2. In all matters concerning personal data protection, including the exercise of your rights related to data processing, you can contact us by e-mail at iod@phnsa.pl or in writing, at the Controller’s address indicated above.
What is the legal basis and purpose of your personal data processing?
1. Personal data will be processed by the Controller solely for the purposes for which they have been provided or collected.
2. Personal data may be processed in accordance with the rules set out in the GDPR, and in other applicable regulations, solely in cases where:
- you have given your voluntary consent to the processing;
- it is necessary for the conclusion or performance of an agreement;
- it is based on the legitimate interests pursued by the Controller.
3. Your personal data may be processed for the following purposes:
a. for direct marketing, including for presenting the products offered by PHN and for sending commercial information by electronic means. This processing is based on your voluntary consent to the processing of personal data.
b. for the purpose of providing the Newsletter service:
- the Newsletter service involves the sending by the Controller of electronic messages with commercial and marketing information about them, and the services or products offered by them or their partners;
- you can subscribe to the Newsletter service by providing your personal data indicated in the form, in particular your e-mail address, and by consenting to its use for direct marketing purposes and sending of commercial information;
- you may unsubscribe from the Newsletter at any time by clicking on the link provided in each electronic message sent as part of this service.
c. in order to send a request for quotation;
d. for the purpose of recruitment procedures.
Information on the requirement to provide personal data
1. Providing personal data for marketing purposes and subscribing to the Newsletter is voluntary.
2. Failure to give personal data may prevent us from providing certain services being the purpose of processing (necessary for the performance of the agreement).
3. How long do we retain your personal data?
Your personal data will be stored only for as long as necessary to achieve the purposes for which they are processed, i.e. for the duration of marketing activities or until you object to the processing, submit a request to restrict such processing or to delete data, or as required by other applicable regulations.
To whom your personal data will be disclosed?
1. Your personal data may be transferred to entities processing personal data on behalf of the Controller, i.e. IT service providers or any partners cooperating with PHN, as part of their activities, whereby such entities process data under an agreement concluded with the Controller and exclusively in line with the instructions of the latter.
2. Your personal data may be transferred to entities and authorities authorized to process such data when required by law.
3. In the case of services provided by external companies, your personal data may be transferred to recipients based or processing personal data in countries outside the European Economic Area (EEA), solely in compliance with the security measures required under the GDPR and outlined below.
Transfers of data outside the European Economic Area
1. If your personal data is transferred to third countries, i.e. to recipients based outside the European Economic Area or Switzerland, in countries which, according to the European Commission, do not provide sufficient data protection (third countries which do not provide an adequate level of protection), the Controller will perform their transfers using mechanisms that comply with applicable law, which include, among others:
a. EU “Standard Contractual Clauses”;
b. Privacy Shield certificate obtained from a third party (if based in the United States);
c. when the data are transferred to a third country for which the European Commission has found, based on a decision, that it does not meets an adequate level of protection.
2. For more information about the existing safeguards implemented by the Controller in order to ensure that personal data are processed in accordance with relevant regulations, and about the possibilities of obtaining a copy of the data or the place where such data are made available, please contact us as outlined in point 1 above.
Your rights as a data subject
1. In accordance with applicable regulations, you have the right to access your personal data and the right to request their rectification, deletion or restriction of their processing.
2. To the extent that the processing of your personal data is based on consent, you may exercise your right to withdraw your consent. Withdrawal of consent does not affect the lawfulness of processing performed prior to withdrawal.
3. To the extent that your data is processed based on consent and the processing is performed in an automated manner, you also have the right to transfer your personal data, i.e. to receive your personal data from the Controller in a structured, commonly used, machine-readable format.
4. You have the right to lodge a complaint with the supervisory authority responsible for personal data protection in Poland (the President of the Personal Data Protection Office), at any time.
In order to exercise the above rights, please contact the Controller or the Data Protection Officer with the contact details provided above, or contact directly the supervisory authority (regarding the right to lodge a complaint with that authority).
Cookie Policy
1. Cookies are IT data, in particular text files, stored on the User’s end device and intended for the use of the Controller’s websites. Cookies usually contain the name of their website, their storage time on the end device and a unique number.
2. The entity who embeds cookies on the User’s end device and accesses them is the Website Operator.
3. Cookies may be used to:
i. develop statistics to help understand how websites are browsed by their Users, with a view to improving their structure and content;
ii. maintain the Website User’s session (after logging in), allowing the User to navigate the Website without having to re-enter their login and password on every subpage;
iii. determine the User’s profile in order to display tailored advertising information.
4. Two basic types of cookies may be used on the Website: session cookies and persistent cookies. “Session” cookies are temporary files stored on the Use’s end device until they log out, leave the website or close the software (web browser). “Persistent” cookies are stored on the User’s end device for the time specified in cookie parameters or until they are deleted by the User.
5. Website browsing software (web browser) usually allows cookies to be stored on the User’s end device by default. Website Users may change their respective settings. The web browser allows Users to delete cookies. They may also opt to automatically block such files. For detailed information please consult the help section or documentation of the web browser.
6. Restrictions on the use of cookies may affect some of the functionalities available on the Website.
7. Cookies stored on the User’s end device may also be used by advertisers and partners working with the Website Operator.
8. We recommend to read the privacy policies of these companies to learn more about the rules applicable for cookies used in statistics: Google Analytics Privacy Policy.
9. Cookies may be used by advertising networks to display advertisements tailored to User’s browsing behavior on the Website. For this purpose, they may store information about the User’s browsing path or the time spent on a specific page.
10. With regard to information about user preferences collected by Google advertising network, the User may view and edit information from cookies using the Google Ads Settings tool.
11. If the User does not want to receive cookies, they can change their browser settings. Please note that disabling cookies necessary for authentication, security and maintaining user preferences may impeded, and in extreme cases may prevent the use of websites.