PRIVACY POLICY

  1. PRELIMINARY PROVISIONS
  • Commercial companies related by capital or person, in particular related to the company Capital Group IMMOBILE S.A. in Bydgoszcz, form a group of enterprises, hereinafter referred to as the “GKI Group”; The list of GKI Group companies are: Grupa Kapitałowa IMMOBILE S.A., MAKRUM Development Sp. z o.o., PROJPRZEM MAKRUM S.A., PROMSTAHL Polska Sp. z o.o., Modulo Parking Sp. z o.o., Projprzem Budownictwo Sp. z o.o., Crismo Sp. z o.o., Aronn Sp. z o.o., Binkie Sp. z o.o., Hotel 1 Sp. z o.o., Cezaro Sp. z o.o., Carnaval Sp. z o.o. and Nobles Sp. z o.o., Kuchet Sp. z o.o.
  • This document (hereinafter referred to as “Privacy Policy”) is information about the processing and protection of personal data collected by entities from the GKI group from you in connection with the purchase of products from GKI Group entities, using the services of entities from the GKI Group (in including those provided electronically), inquiries addressed to entities from the GKI Group, the bids process, participation in events organized by entities from the GKI Group, participation in the recruitment process of GKI Group employees, subscription to the Newsletter or other channels of information about products and services of entities from the Group GKI and the exchange of correspondence, etc., in particular in connection with the use of our websites.
  • The administrator of your personal data, within the meaning of the law on the protection of personal data, is: the company Capital Group Immobile S.A. with headquarters in Bydgoszcz (85-719) at ul. Fordońska 40, entered in the register of entrepreneurs kept by the District Court in Bydgoszcz, under KRS 33561, NIP number 5540309005 (hereinafter: “GKI“) or another entity from the GKI Group. We are responsible for the use of your data in a safe and compliant manner with applicable regulations, in particular the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46 / EC (general regulation on data protection) (Dz.Urz. UE L 119, s. 1), hereinafter referred to as “RODO“.
  • The Privacy Policy is for information purposes, which means that it is not a source of obligations for persons whose personal data are processed in accordance with its provisions, and one of its main functions is to fulfill the information obligation referred to in art. 13 RODO.

 

  1. WHAT PURPOSE AND ON WHAT VITAL BASIS WE PROCESS YOUR PERSONAL DATA
    • Personal data obtained from you by the GKI Group companies is processed for the following purposes, depending on the entity (company) of the GKI Group and the situation in which the data was provided:
      1. conclusion and performance of the contract concluded with the entity from the GKI Group (regardless of the form of its conclusion: in writing or by using our services provided electronically via the Internet) – to the extent necessary to establish, shape the content, change, terminate and correctly implement the contract;
      2. performance of legal obligations imposed on the entity of the GKA Group, e.g. issuing and storing invoices and accounting documents, replying to complaints, fulfilling obligations resulting from the warranty for defects in products and ensuring the safety of services provided;
      3. establishing, defending and pursuing claims;
      4. direct marketing of products and services of the GKI Group entity;
      5. creating reports, analyzes and statistics for internal needs of the GKI Group, including, in particular, reporting, market research, advertising targeting, remarketing, service development planning, development work in information systems, creation of statistical models and evaluation of the functioning of the GKI Group website, including statistics on subpages;
      6. If you consent to the transmission of commercial information by the GKI Group company via email, your personal data will also be processed by us in order to provide you with information about our services, offers and events organized by us, as well as information on products and services of entities cooperating with us (with our knowledge and clear consent).
    • Personal data is not used for purposes other than those specified in the Privacy Policy, unless the GKI Group company obtains your consent to the processing of data for other purposes, any other use of this information will be required or permitted by law.
    • To the extent that the processing of your personal data is necessary for:
      1. performance of the contract concluded with you or to take action upon your request before the conclusion of the contract – the legal basis for the processing of your personal data by a company of the GKI Group is the contract;
      2. fulfilling the legal obligation imposed on us – this legal obligation is the legal basis;
      3. purposes resulting from legally justified interests pursued by the GKI Group company, i.e. for the purposes of direct marketing of our products and services, fraud prevention or assertion and defense of claims – the legal basis is the legitimate interest of the GKI Group company.
    • If the use of your data is not necessary for the performance of the contract, the fulfillment of the legal obligation or does not constitute our legitimate interest, we may ask for your consent for certain uses of your data. Granting consent may take the form of selecting a selection box when browsing a website, may involve choosing technical settings to use information society services or other statements or behavior that clearly indicates in your context that you have accepted the proposed processing of personal data. You can withdraw your consent at any time (this will not affect the lawful use of your data before withdrawal of such consent).
    • Providing your personal data is not mandatory, however failure to do so will result in the GKI Group company being unable to perform actions for which data is required.
    • On the basis of your personal data, the GKI Group companies will not take automated decisions about you, including decisions resulting from profiling.

 

  1. entitlements which you are entitled to
    • Any person whose personal data is processed by a company of the GKI Group has the right to access their personal data and immediately correct the data which is incorrect. Taking into account the purposes of processing, the data subject has the right to request supplementing incomplete personal data, including by providing an additional statement.
    • If you consent to the processing of data, in particular for marketing purposes (including the transmission of commercial information by electronic means), consent may be withdrawn by you at any time. A user receiving certain information or services, such as an electronic newsletter (so-called Newsletter), may at any time unsubscribe from his subscription by following the instructions in each such sent document.
    • A person providing personal data to a GKI Group company has the right to request the company to delete their personal data immediately, and the company has the obligation to delete personal data without undue delay if one of the following circumstances occurs:
      1. personal data is no longer necessary for the purposes for which they were collected;
      2. the data subject has withdrawn the consent on which the processing is based and there is no other legal ground for processing;
      3. the data subject has objection to the processing;
      4. personal data was processed unlawfully;
      5. personal data must be removed in order to comply with the legal obligation provided for by Union law or the law of the Member State to which the GKI Group company is subject.
    • Persons providing their personal data to a GKI Group company have the right to demand limiting the processing of personal data in case when:
  2. the data subject disputes the correctness of personal data – for a period allowing the GKI Group company to check the correctness of such data;
  3. processing is unlawful and the data subject opposes the removal of personal data, requesting instead to limit their use;
  4. the GKI Group company no longer needs personal data for processing, but is needed to establish, assert or defend claims;
  5. the data subject has objected to the processing – until it is established whether the legitimate grounds on the part of the GKI Group company override the grounds for objection of the data subject.
    • If the processing of personal data by the GKI Group company takes place in an automated manner on the basis of a consent or contract, the data subject has the right to obtain, in a structured, commonly used machine-readable format, personal data concerning him that he provided to the GKI Group company, and has the right to send this personal data to another administrator. The data subject has the right to request that personal data be sent by a GKI Group company directly to another administrator, if it is technically possible.
    • In order to exercise the rights referred to above, you can contact the GKI Group company in the manner indicated in point 9 below.
    • The GKI Group Company will inform you about the rectification or deletion of personal data or the processing limitations that has been made at your request, to any recipient who has been disclosed personal information, unless this proves impossible or will require a disproportionate effort.
    • In connection with the processing of your personal data by the companies of the GKI Group, you have the right to lodge a complaint with the supervisory body, i.e. the President of the Office for the Protection of Personal Data.

 

  1. to whom we pass your personal data
    • We provide your data to:
      • entities processing data on our behalf, participating in the performance of our activities:
        1. entities dealing with information systems and computer hardware that we use;
        2. to entities managing our properties;
        3. to our business partners, advertising agencies and other intermediaries in the sale of our products and services or organization of marketing campaigns;
        4. subcontractors who support us, e.g. in the performance of our services, transport of ordered products, product service, handling correspondence or in the process of customer service;
        5. entities providing consulting, auditing, legal, tax and accounting assistance, research agencies acting on our behalf;
      • other data controllers that process data on their own behalf:
        1. entities operating postal or Courier services;
        2. entities purchasing receivables or dealing with debt recovery – if you do not pay our invoices within due date;
        3. entities cooperating with us when handling accounting, tax and legal matters – to the extent they become data controllers.
      • At present, the GKI Group does not plan to transfer your data outside the EEA (including the European Union, Norway, Liechtenstein and Iceland). But it may turn out that during the term of the contract we will decide to transfer data outside the EEA – only to the extent that we will be allowed by law.
      • The GKI Group may provide personal data at the request of the law enforcement authorities or authorities, or if it is required by applicable laws, court judgments or other state regulations. The need to disclose personal data may also be caused by audits of data or security privacy and / or when dealing with complaints or actions related to security risks. The GKI Group does not sell personal data to third parties, nor does it entrust the processing of personal data provided by users to third parties, and which information could be used by such third parties for their marketing purposes.

 

  1. HOW LONG DO WE KEEP PERSONAL DATA
    • Your personal data will be kept for no longer than it is necessary, i.e. depending on the purpose of their processing:
      • conclusion and performance of a contract linking you with a GKI Group company – for the duration of the contract and settlements after its completion, including the duration of the warranty period for defects or quality assurance provided in the contract;
      • fulfillment of the legal obligation incumbent on the GKI Group company:
  1. for the duration of the duties;
  2. for the period in which the provisions require us to store data (e.g. tax); or
  3. for the time when we can suffer the legal consequences of non-performance, for example, to receive a financial penalty from state offices;
  • purposes resulting from legally justified interests carried out by the GKI Group company:
  1. direct marketing of our products and services – for the duration of the contract, and then for the period of warranty and / or post-warranty service;
  2. fraud prevention – for the duration of proceedings before competent authorities;
  3. investigation and defense of claims – for a period during which claims will expire.
  • If we process your personal data based on your consent for certain uses of your data, your data will be processed within the period indicated by obtaining consent, and in the absence of such indication – until you withdraw your consent.

 

 

  1. AUTOMATIC DATA COLLECTION
    COOKIE FILES.
    OPERATIONAL DATA. google tools

     

    • When using websites of GKI Group companies, user data is also collected automatically. These data can be collected in the system logs of the website, through the so-called Cookies. Cookies (cookies) are small text information in the form of text files, sent by the server and saved on the side of the person visiting the website (e.g. on the hard drive of the computer, laptop or on the smartphone’s memory card).
    • By saving cookies on the user’s device of the website (computer, smartphone, tablet, etc.), the GKI Group company may, among others:
  1. Adjust the functioning of the website to your needs.
  2. Eliminate the need to log in at every visit to the website (in the case of areas for registered users / clients).
  3. Memorize your settings from session to session.
  4. Increase the speed and safety of the website.
  5. Personalize your website according to your needs and enable users to find the information you need faster.
  6. Constantly improve the website with its users in mind.
  7. Increase the effectiveness of marketing activities.
  • Cookies do not contain data identifying the user, based on them you cannot determine anyone’s identity. These files are not harmful to the user’s end device in any way and do not change its settings or settings of the software installed on it. The content of these files can only be read by the server that created them.
  • When the user visits our website, GKI uses three types of cookies: session, permanent and marketing. Session files are temporary files that are stored in the user’s device memory until you log out of the website, leave the site or close the browser. Persistent files are stored in the user’s device memory for the time specified in the parameters of these files or until they are deleted by the user. Marketing files are “cookies” saved by other external scripts used on our website. They are used mainly by us for remarketing purposes (see paragraphs 6.11.-6.14 below).
  • By default, most web browsers available on the market accept cookies by default. The User has the option of changing the settings of Cookie files independently and at any time, specifying the conditions for their storage and access to the user’s device via Cookies. Changes to the settings referred to in the previous sentence, the user can make using web browser settings or by using the service configuration. These settings can be changed in such a way as to block the automatic handling of cookies in the web browser’s settings or to inform about each posting of Cookies on the user’s device. Detailed information about the possibilities and ways of handling cookies are available in the software (web browser) settings.
  • The User may at any time delete cookies using the functions available in the web browser he uses.
  • Limiting the use of cookies may affect some of the functionalities available on the GKI Group websites.
  • Detailed information on changing cookies settings and their self-removal in the most popular web browsers are available in the help section of the web browser.
  • The GKI Group also processes anonymized operational data related to the use of its website (so-called logs – IP address, domain) to generate statistics helpful in administering the website. From the moment the user connects to the website, information about the number (including IP) and type of the end device of the user from which the user connects to the website appears in the system’s website logs. This data is aggregate and anonymous, i.e. they do not contain features that identify visitors to the website. Logs are not disclosed to third parties.
  • The GKI Group may use the Google Analytics service which collects anonymous information about GKI websites visited by using cookies. Detailed rules regarding Google Analytics privacy policy can be found at:
    http://www.google.com/intl/pl/analytics/privacyoverview.html.
  • In addition, the GKI Group company may use Google AdWords and Google Analytics remarketing codes for display adverts. These codes are used to create remarketing lists to match the users who visited our website, individualized ads, and then display them on the Google AdWords Display Network, Google Search, as well as on the websites of entities participating in the Google content network.
  • Our website, using the “similar recipients” function, works within the Google AdWords system and checks how the browsing of the Display Network has been in the last thirty days and submits this information to the contextual targeting mechanism to determine the remarketing audience profile. On its basis, Google AdWords finds a group of new users who have similar browsing patterns as people on the GKI Group remarketing list. This list is never created based on the history of browsing websites about topics considered to be sensitive, for example related to issues of race, religion, sexual orientation or health.
  • Using the remarketing tools and the “similar recipients” function, our website does not collect your personal data through cookies, but only the browsing history and, consequently, the user remains anonymous.
  • You can opt out of Google AdWords and Google Analytics collection of remarketing codes and display advertiser codes, as well as the display of custom ads on the Google Display Network as described in paragraph 6.5 above.
  • On the GKI website, there may be functions that allow sharing content using social applications of third parties, such as “Like” button on Facebook or Twitter widget. All these social applications can collect and use user activity data on the GKI website. All personal data provided by users through such social applications can be collected and used by other users of the above social applications, and their interaction is subject to the privacy policy of companies that are the application providers. We have no influence and we do not take any responsibility for the above companies and their use of data.

 

  1. how we secure personal data
  • The GKI Group strives to ensure a high level of security of personal data processed by them. All events that affect the security of data, including the suspicion of sharing files containing viruses and other files of a similar nature or other than destructive mechanisms files should be reported to the e-mail address indicated in point 9 below.
  • The GKI Group applies technical and organizational measures to ensure that personal data being processed is protected against hazards and categories of data protected. In particular, protection against unauthorized access, being taken by an unauthorized person, processing in violation of applicable laws and changes, loss, damage or destruction. In addition, the GKI Group makes special care so that personal information is:
  • correct and processed in a lawful manner,
  • obtained only for specific purposes and not further processed in a manner inconsistent with these purposes,
  • adequate, appropriate and not excessive,
  • accurate and current,
  • not kept longer than necessary,
  • processed in accordance with the rights of persons (whom they relate to), including the right to reserve access,
  • safely stored,
  • not transferred without proper protection.
  • Personal data is stored in a database in which technical and organizational measures ensuring the protection of data processed comply with the requirements set out in the generally applicable law on the protection of personal data. Access to the database is available only to persons authorized by the data controller.
  • The GKI Group applies appropriate policies and procedures for the protection of personal data against unauthorized loss, misuse, alteration or destruction. We make every effort to ensure that access to your personal data is limited to people who need to know this information. Persons who have access to data are obliged to keep them confidential. Additionally, one of the rules of the GKI policy in this respect is the storage of personal information only for such period in which they are necessary to complete the user’s application or until the user requests removal of such information.

 

  1. CONTACT

In matters related to the processing of personal data, you can contact each of the companies with the GKI Group as their administrator by contacting the appointed Data Protection Representative, by writing to the following address: rodo@immobile.com.pl

  1. CHANGES IN THE PRIVACY POLICY

The GKI Group may make changes to this document, which reflect the current Privacy Policy. In the case of modifications, the date of the last update, as shown below, also changes.

 

The last date of the Privacy Policy: 03/01/2019.

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