PRIVACY POLICY

 Polityka prywatności -

PRIVACY POLICY OF POLNORD S.A. CAPITAL GROUP

In this Privacy Policy of Polnord S.A., we present the rules of processing your personal data, in particular when you use our websites of Polnord S.A., i.e. websites under the main domain polnord.pl and other websites operated by Polnord S.A. and entities belonging to the Polnord S.A. Capital Group. The purpose of this Privacy Policy is to ensure the protection of your personal data and to process the collected data in such a way as to interfere as little as possible with the privacy of persons using our websites. In the Policy we indicate to you exactly which data we collect, and we explain for what purposes we do so, on what legal basis, and for how long we store them. We also inform you of your rights.

We take the utmost care to ensure that all our personal data processing activities comply with the law, in particular: with

- 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. Official Journal of the European Union L. 2016 No. 119/1 ("GDPR"); („RODO”);

- Act of 18 July 2002 on the provision of electronic services, i.e. Journal of Laws of 2013, item 1422, as amended;

- Telecommunications Act of 16 July 2004, Telecommunications Law, i.e. Journal of Laws of 2014, item 243, as amended.

Who is the Controller of your personal data?

The Controller of your personal data is Polnord SA with its registered office in Warsaw, ul. Branickiego 15 (postal code: 02-972), a company entered into the Register of Enterprises kept by the District Court for the Capital City of Warsaw, under KRS number 0000041271, tax ID [NIP] 583-000-67-67, and in certain situations companies constituting Polnord S.A. Capital Group (hereinafter referred to as "Polnord"), telephone contact: 22 351 96 00, fax: 22 351 96 01.

Polnord data protection contact details

Contact in matters concerning privacy or protection of personal data: to the registered office address of Polnord S.A.: ul. A. Branickiego 15, 02-972 Warszawa [Warsaw] or via electronic correspondence to e-mail address: odo@polnord.pl

Where we obtain your personal data from

- from contact forms placed on our websites,

- from forms filled in by you during housing fairs, open days or other public events organised by Polnord or entities cooperating with us,

- from a contract (e.g.: reservation, development, sale or other types of contracts) concluded with Polnord or Polnord Group companies,

- from e-mail correspondence sent to our Sales Office,

- as soon as you enter our competitions (accept competition rules) and provide us with your data in order to participate in the respective competition,

- from an entity that has entered into a contract with Polnord/Polnord Group companies for the provision of services to you, or an entity that has provided us with your data on the basis of your consent (e.g. an internet service with Polnord flat listings).

When you use our website, we automatically collect anonymous data regarding, among other things:

- the time of the site visit

- number of visits

- type of device (e.g. mobile / stationary)

- type of browser, browser language

- type of operating system, etc.

- use of geolocalisation to tailor content on a website for a user from a specific location

- flats recently viewed and flats selected for comparison by the user

We ensure that this information is not disclosed to anyone other than those authorised to administer the website. The data may be used for: statistical analyses, personalisation of the content of our websites, personalisation of advertisements.

Detailed information on the Cookie Policy can be foundhere

Whose data we process and on what terms

Personal data processed in connection with the completion of the online contact form.

Your personal data may be processed for marketing and commercial purposes - the basis for this processing of your personal data is solely based on your consent (obtained in accordance with Article 6(1)(a) of GDPR) and also, within the scope of the controller's legitimate interest, for the purpose of establishing, investigating or defending against claims (Article 6(1)(f) of GDPR). The scope of your personal data processed may include: name and surname, email address, telephone number. By filling in the contact form you agree to receive from us:

  • commercial offers by telephone
  • commercial offers by e-mail or
  • marketing content by telephone
  • marketing content by electronic means.

In the body of the form we ask you to provide: your name and surname, e-mail address and/or telephone number. In response, you will receive our offer with a presentation of the flats or any other information you request.

Your personal data will be processed for the time necessary to fulfil the purpose as well as for the time necessary to defend against possible claims that could arise in relation to the subject of your consent. If you wish the information we process to be deleted sooner, or if you do not wish to receive commercial or marketing information from us, please send your objection to the email address odo@polnord.pl or by using the contact details provided above.

Personal data of Polnord's customers in connection with the conclusion and performance of the contract

Your personal data may be processed in order to carry out activities performed at your request prior to concluding the contract with Polnord (e.g. booking, development, etc.) and to perform the contract you concluded with us, i.e. on the basis of Article 6(1)(a) of GDPR. In connection with the conclusion of a contract with you, we also process your personal data in order to fulfil legal obligations, e.g. to issue an invoice (legal basis: Article 6(1)(c) of GDPR) and to establish, assert or defend claims, as well as for direct marketing (legal basis: Article section (1)(f) of GDPR).

Your personal data will be processed for the time necessary for the performance of the contract and the fulfilment of legal obligations, as well as for the time necessary to defend against possible claims. With regard to the processing of your data for direct marketing purposes, your data will be processed by us until you raise an objection.

If you do not wish to receive information from us related to direct marketing, please send your objection to the email address odo@polnord.plor by using the contact details provided above.

Polnord does not make any automated decisions, and your personal data are not profiled.

Personal data of contractors, collaborators of Polnord

We process your personal data and other information provided to us by you in your business relationship for the purpose of and within the framework of concluded cooperation, supply, execution, subcontracting and procurement contracts or agreements. Within the scope of performance of obligations arising from these contracts, there may ensue sharing, transmission of commercial, product and marketing information, or communication of the obligations performed by the parties. Within the scope of the aforementioned activities, we collect personal data from you such as: name, surname, position, company name and address, telephone number, e-mail address.

Your personal data are processed on the basis of Article 6(1)(a) of GDPR and, within the scope of the controller's legitimate interest, for the purpose of establishing, investigating or defending against claims, on the basis of Article 6(1)(f) of GDPR.

Your personal data will be processed for the time necessary for the performance of the contracts, as far as the fulfilment of legal obligations is concerned, for the time necessary to fulfil these obligations and for the time necessary to defend against possible claims.

Personal data processed in connection with public relations and investor relations activities

We process the personal data of journalists, investors, analysts, shareholders and other persons affiliated with the capital market. We obtain personal data in this area directly from you, the editorial office or your affiliates. The scope of the data processed may include: name and surname, email address, telephone number, affiliate details, editorial address.

We process these data on the basis of our legitimate interest in order to inform you about Polnord's activities, to send you current and periodic reports, and to manage our relationships in accordance with Article 6(1)(f) of GDPR, as well as on the legal basis resulting from obtaining your consent - Article 6(1)(af) of GDPR.

You may object to the processing of your data in the above extent at any time.

If you would like to keep in touch with us and receive press releases, current or periodic reports from us, please apply to the following email address: ir@polnord.pl. To the same address, please send any objections to the processing of your personal data for the purposes referred to in this paragraph, or information about unsubscribing from the list of persons receiving information from us referred to above.

Personal data of close persons, persons holding managerial positions in Polnord

We process the data of persons close to us - persons performing a management function in Polnord, an obligation arising from the applicable capital market regulations. The basis for the processing of these personal data is Article 6(1)(c) of GDPR. The data are processed for a period of 5 years after the list of close persons, persons performing a management function in our company, is drawn up or updated.

Personal data processed in connection with recruitment for positions at Polnord

We recruit new employees, co-workers, via the polnord.pl website, social networking sites and selected recruitment portals. Acquired personal data are used solely for the purpose of recruitment or, if we have your separate consent, your data may be stored longer and used in future recruitment processes for the same or other positions. This period will be defined each time in the recruitment rules or indicated individually.

We process your personal data in the aforementioned scope exclusively on the basis of your consent, i.e. Article 6(1)(a) of GDPR, and - in the scope of our legitimate interest - for the purpose of establishing, investigating or defending against claims, on the basis of Article 6(1)(f) of GDPR.

If you wish to have the information we process deleted sooner, please send your objection to the email address odo@polnord.pl or by using the contact details provided above.

Personal data processed in connection with the organisation of competitions

When organising a competition, we ask you to provide only the personal data that we will process for the purpose of the competition. We provide the scope of these data and the details of their processing each time in the dedicated contest rules. We only collect your email address, name and surname, and postal address. We process the data for the purpose of settling the competition and contacting you to inform you of the prize awarded, and for the purpose of establishing, investigating or defending against claims. The legal basis for processing for the above purposes and scope is Article 6(1)(b) of GDPR. The provision of your personal data is voluntary but necessary in order to participate in the competition.

After the competition in question has ended, we process your personal data in accordance with your consent or on the basis of our legitimate interest for the period of time necessary to fulfil the purpose of the competition, as well as to defend ourselves against possible claims that could arise from the competition or in connection with the outcome of the competition, thus on the basis of Article 6(1)(f) of GDPR.

Personal data processed through social networks

Polnord has profiles on portals such as:

LinkedIn https://www.linkedin.com/company/grupa-polnord/

Facebook https://www.facebook.com/PolnordSA/

Instagram https://www.instagram.com/polnordsa/?hl=pl

Our cooperation with the social networks on which we maintain our profiles is based on the terms and conditions set out by the operators of the portals - Facebook, Instagram or LinkedIn. The function of the controller of your personal data is performed by both the owner of the portal and Polnord, which maintains its profile via a given portal. However, it should be noted that Polnord, which maintains the profile, is itself a user of the portal and is not in a position to modify the portal's terms of use or the security measures it applies. Therefore, for full information on the processing of your personal data, please refer to the privacy policy of the respective portal (more information on this below).

Your personal data are processed as part of the profiles we maintain on these social networks, in particular for advertising, market research, and promotions. Based on this, we inform you about the activities we undertake, and events that Polnord organises, including investment promotions, competitions, etc.

Activity on profiles serves to build and maintain communication with us through profile following, comments, chats, messages, likes, reactions to posts, shares, etc.

We process your data, such as your name and surname/nick, image, public profile and other information provided in messages or comments, on the basis of our legitimate interest, in order to respond to comments and messages, to maintain relationships with people interacting with us, and to establish, investigate or defend against possible claims, on the basis of Article 6(1)(f) of GDPR. The basis for the processing of your personal data is Article 6(1)(a), that is your implied consent granted by joining Polnord's profile on social networks.

Facebook transfers data outside Poland/EU/European Economic Area using contractual clauses applied by Facebook approved by the European Commission and decisions of the European Commission declaring an adequate level of data protection in respect of specific countries in accordance with the principles set out by Facebook at https://www.facebook.com/about/privacy. The Instagram service is one of Facebook's products provided by Facebook Ireland Limited, and processes data under the same rules.

According to information downloaded from the LinkedIn website https://www.linkedin.com/help/linkedin/answer/62533?trk=microsites-frontend_legal_privacy-policy&lang=en which puts professionals in touch with each other and enables them to take advantage of economic opportunities around the world, they require transfer of data between the European Union (EU), the European Economic Area (EEA), and Switzerland and the United States (US). Personal data are properly protected when transferred outside the EU; the GDPR requires that such transfers must be based on specific legal mechanisms. .

Providing us with data about other people

If you share personal information about third parties with us in any capacity or form (e.g. as part of our competitions), you are required to obtain the consent of that individual and comply with any obligations under GDPR in relation to the data shared in that manner. We ask that you ensure that you have obtained the express consent of the individual concerned or have a legal basis for providing us with information about that individual, and direct those individuals to read and accept our Privacy Policy.

To whom your personal data may be communicated

  • to state authorities or other entities authorised by law,
  • entities processing personal data on our behalf in order to fulfil our obligations, i.e. our subcontractors, suppliers, postal or courier companies,
  • entities with whom we permanently cooperate and who are responsible for Polnord's IT services, Polnord's accounting services. These entities act on the basis of contracts of entrustment for the processing of personal data and are equally obliged to protect them.

Transfers of personal data outside the European Economic Area (EEA)

Your personal data are processed exclusively within the EEA, with the proviso that only social network processing may involve the transfer of your personal data to third countries.

In case the need arises to transfer personal data outside the EEA, Polnord will apply such legal and factual instruments that will ensure the security and an adequate degree of protection of your personal data. In particular, it will take all actions in accordance with the applicable legislation, in particular the GDPR and the principles and guidelines set out by the President of the Personal Data Protection Office https://uodo.gov.pl/pl/138/665 https://uodo.gov.pl/pl/138/1768

The rights you have in relation to the processing of your personal data by Polnord

right to information about the processing of personal data - on this basis, Polnord provides to a person whose data is processed information about the processing of data, including, in particular, the purposes and legal grounds for the processing, the scope of data held, the entities to which the data are disclosed, and the planned date of deletion of the data;

right to obtain copies of data – on this basis, Polnord provides the person with a copy of the processed data concerning the person placing such a request;

right of rectification – Polnord is obliged to rectify any inconsistencies or errors in the personal data processed and to complete them if they are incomplete;;

right to delete data – on this basis, a person may request the deletion of data whose processing is no longer necessary for any of the purposes for which they were collected;

right to restrict processing - if such a request is made, Polnord shall cease performing operations on personal data - with the exception of operations to which the data subject has consented - and storing them, in accordance with the accepted principles of data erasure, or until the reasons for restricting data processing cease to exist (e.g. a decision is issued by a supervisory authority authorising further data processing);

right to data portability - on this basis - insofar as the data are processed in connection with a concluded contract or consent given - Polnord issues the data provided by the data subject in a computer-readable format. It is also possible to request that these data be sent to another entity - provided, however, that the technical capacity to do so exists both on the part of Polnord and that other entity; .

right to object to processing for marketing purposes the data subject may object at any time to the processing of personal data for marketing purposes, without having to justify such an objection;

right to object to processing for marketing purposes the data subject may object at any time to the processing of personal data for marketing purposes, without having to justify such an objection;

right to object to other purposes of processing the data subject may object at any time to the processing of personal data which is carried out on the basis of a legitimate interest (e.g. for analytical or statistical purposes); an objection in this respect should contain a justification;

right to withdraw consent – where data are processed on the basis of expressed consent, the data subject has the right to withdraw them at any time, but this does not affect the lawfulness of processing carried out prior to the withdrawal of consent.

right to complain if the processing of personal data is considered to be in breach of the provisions of the GDPR or other data protection legislation, the data subject may lodge a complaint with President of the Personal Data Protection Office https://uodo.gov.pl/pl/p/skargi. You may request to exercise the above rights in writing to the address of Polnord S.A. registered office: ul. A. Branickiego 15, 02-972 Warszawa [Warsaw] via electronic correspondence to e-mail address: odo@polnord.pl

We reserve the right to amend this Privacy Policy by publishing a new Privacy Policy on this website..