PRIVACY POLICY

Information on personal data processing in Polski Holding Nieruchomości Group

 

Dear Sir/Madam,

On May 25, 2018 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 (hereinafter the "General Data Protection Regulation" or "GDPR", OJ EU L 2016, No. 119) came into force. The Regulation imposes a number of new obligations on entities that collect, process and use personal data.

An important obligation of Polski Holding Nieruchomości[1] (PHN) is to ensure adequate protection and proper use of personal data.

We have prepared the necessary information for you regarding the processing of personal data at PHN. You will learn how we process your personal data and what your rights in this respect are.

 

Who is the controller of your personal data?

If you use our services and provide us with your personal data, then the indication of the competent entity responsible for the processing depends on the purpose for which we collect such data. For example: if you use the services of one of the companies within Polski Holding Nieruchomości Group, then the data controller, i.e. the entity that decides on how your personal data is used, is the company being the service provider.

The leading company in Polski Holding Nieruchomości Group is:

 Polski Holding Nieruchomości S.A. with its registered office at: Al. Jana Pawła II 12, 00-124 Warszawa.

 

Who should you contact to learn more about the processing of your personal data?

Please contact the Data Protection Officer. The contact details can be found below:

email address: IOD@phnsa.pl

postal address: Inspektor Ochrony Danych, Al. Jana Pawła II 12, 00-124 Warszawa.

 

On what basis and for what purpose do we process personal data?

The legal basis for the processing of personal data by Polski Holding Nieruchomości is Article 6(1)(a), (b) or (c) and (f) of the General Data Protection Regulation.

Your personal data will be processed:

1)   In order to fulfill the legal obligations incumbent on PHN (Article 6(1)(c) of the General Data Protection Regulation), including:

– fulfilling the information obligations of the company towards the capital market;

– keeping a share register and a book of minutes

  of meetings of shareholders and general meetings of shareholders;

– obligations resulting from powers of attorney, subscription warrants.

 

2)   In order to implement the agreements concluded with PHN (Article 6(1)(b) of the General Data Protection Regulation) with regard to:

– execution and deliveries;

– implementation of construction projects;

– purchase of premises;

– rental and sale of properties;

– hotel operations;

– awarding contracts and cooperating with external contractors;

– acquisition and use of appraisal reports.

 

3)   On the basis of your consent, to the extent and for the purpose set out in such consent (Article 6(1)(a) of the General Data Protection Regulation), including:

– conducting marketing activities and promoting the services offered

  by PHN;

– conducting tender procedures;

– submitting confidentiality statements and letters

  of intent;

– presenting the offer;

– implementing the surveyor selection process.

 

4)   On the basis of our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation), including:

– correspondence in the event of a request for contact (e.g. via the contact form);

– verification and validation of internal and operational processes;

– servicing the company's governing bodies.

 

In addition, PHN processes personal data, among others, for the following purposes:

-       keeping accounting records, making money transfers;

-       implementing legal regulations which the employer/principal is obliged to comply with;

-       fulfilling the payer's obligations related to handling and sending of tax returns;

-       accomplishment of recruitment processes;

-       implementation of agreements/contracts with external entities (data entrusted by other entities – personal data controllers);

-       implementation of the provisions of the Act on the Social Insurance System and other provisions of law which the Payer is obliged to comply with;

-       implementation of the newsletter service ordered by the user;

-       exchange of business cards during various events;

-       retaining data for archiving purposes and ensuring accountability (demonstrating that we comply with our legal obligations).

 

What categories of personal data does PHN process?

These include, in particular:

-         identification data or data related to the verification of a person, i.e.  determination or verification of their identity;

-         financial data;

-         data about professional or business activity in connection with the performance of contracts and activities undertaken by PHN;

-         data about searches on the website, which are personal data and are retrieved in accordance with the cookie and privacy policies or other statements/consents in this respect.

 

Is the provision of personal data mandatory?

If the processing of your personal data takes place on the basis of your consent, the provision of such data is voluntary.

Where the grounds for the processing of your personal data are the provisions of generally applicable law or an agreement concluded between the parties, then providing the data is necessary for the performance of the obligations arising therefrom.

If the processing of personal data is based on your consent, you have the right to withdraw such consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

 

What are your rights against PHN with regard to the processing of your data?

We guarantee that all your rights under the General Data Protection Regulation, i.e. the right to access, rectify and delete your data, the right to restrict their processing, the right to transfer them, the right not to be subject to automated decision-making, including profiling, and the right to object to the processing of your personal data, will be fulfilled.

You may exercise these rights:

-         regarding the request for rectification: when you notice that your data is incorrect or incomplete;

-         regarding the request to delete data: when your data is no longer necessary for the purposes for which it was collected by PHN; when you withdraw your consent to the processing of your data; when you object to the processing of your data; when your data is processed unlawfully; when your data should be deleted in order to comply with a legal obligation;

-         regarding the request to limit the processing of data: when you notice that your data is incorrect – you may request that the processing of your data be restricted for a period allowing us to check the correctness of such data; when your data is processed unlawfully, but you do not want to have it removed; when we will no longer need your data, but they may be necessary for you to defend or pursue claims; or when you object to the processing of the data – until the time of determination whether the legitimate grounds on our side override the grounds for objection;

-         regarding the request for transfer of data: when the processing of your data is carried out on the basis of your consent or contract concluded with you.

-         you have the right to lodge a complaint regarding the processing of your personal data with the supervisory authority, which is the General Inspector for Personal Data Protection (address: ul. Stawki 2, 00-193 Warszawa).

 

Who do we share your personal data with?

PHN may transfer your personal data to entities authorized to obtain such data under the provisions of generally applicable law, to which entities the transfer of data is necessary for the performance of a specific activity, such as provision of a service; to which entities the data may be transmitted on the basis of your consent or authorization; or which entities are clearing houses or other entities conducting settlement activities, financial institutions, insurance companies or their representatives.

If necessary, your personal data may be shared between the entities of Polski Holding Nieruchomości Group on the basis of the principles set forth in the provisions of law.

Your personal data may be entrusted to third parties for processing within the framework of services provided by them on the basis of agreements on entrusting the processing of personal data, and such third parties are also obliged to maintain the confidentiality of the data processed. These will include, in particular, entities supporting PHN, e.g. providing consulting or audit services.

 

How long do we keep your personal data?

From the moment personal data is collected, it will be processed for the period necessary to fulfill the purposes set out above, and then for the period required by the generally applicable law.

Your personal data will be stored:

-         for the implementation of the agreement concluded between you and PHN, for the duration of its performance, and thereafter for the period and to the extent required by law or to secure any potential claims;

-         for fulfilling the legal obligations incumbent on PHN in connection with the conduct of its business and the performance of concluded agreements, for the period until such obligations are fulfilled by PHN;

-         for the marketing and promotion of the services offered by PHN, for the period necessary to achieve the purpose or until your consent to such processing is withdrawn;

-         for internal administrative purposes, for a period until the fulfillment of the legitimate interests of PHN, which interests constitute the basis for such processing, or until you object to such processing.

 

At the same time, in order to maintain accountability, we will store data for the period for which PHN is obliged to retain data or documents containing data to document compliance with legal requirements, including to allow public authorities to control such compliance.

Do we transfer your data to countries outside the European Economic Area?

 

Your personal data will not be transferred to entities outside the European Economic Area.

Do we process your personal data automatically, in a way that affects your rights?

In some cases, PHN and its service providers use cookies, beacons and other technologies to automatically collect information of a certain type when you visit our website. Gathering this type of information will allow us to better understand and improve our actions and to determine the effectiveness of our marketing activities. 
Not always information gathered in this way is personal data, i.e. allows us to identify you personally, but this may be possible, for example, when we are able to link an IP address or location information to a particular e-mail address.




[1] Polski Holding Nieruchomości, PHN – refers to Polski Holding Nieruchomości Group. The leading company is Polski Holding Nieruchomości S.A. with its registered office at Al. Jana Pawła II 12, 00-124 Warszawa. The list of entities included in the PHN Group is available at www.phnsa.pl

 

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