Privacy policy
1. INTRODUCTORY PROVISIONS
1.1 Commercial companies linked by capital or personal ties, in particular those linked to the company Grupa Kapitałowa IMMOBILE S.A. in Bydgoszcz, form a group of enterprises, hereinafter referred to as the "GKI Group"; List of companies of the GKI Group to which this document applies: Grupa Kapitałowa IMMOBILE S.A., PJP MAKRUM S.A., PROMSTAHL Sp. z o.o., Projprzem Budownictwo Sp. z o.o., Atrem S.A., Inicjatywa Północno-Zachodnia PW Sp. z o.o., QDS 24 Sp. z o.o., PBH S.A.
1.2 This document (hereinafter referred to as the "Privacy Policy") is information on the principles of processing and protection of personal data collected by entities from the GKI Group group of companies from you in connection with the purchase of products of entities from the GKI Group, use of services of entities from the GKI Group (including those provided electronically), inquiries addressed to entities from the GKI Group, the offer process, participation in events organized by entities from the GKI Group, participation in the recruitment process of employees of entities from the GKI Group, subscription to the Newsletter or other channels of information about products and services of entities from the GKI Group, exchange of correspondence, etc., including in particular in connection with the use of our websites.
1.3 The controller of your personal data, within the meaning of the provisions of the law on the protection of personal data, is: Grupa Kapitałowa Immobile S.A. with its registered office in Bydgoszcz (85-033) at Plac Kościeleckich 3, entered into the register of entrepreneurs maintained by the District Court in Bydgoszcz, under KRS number 33561, NIP 5540309005 (hereinafter referred to as: "GKI") or another entity from the GKI Group. We are responsible for using your data in a safe manner and in accordance with applicable regulations, in particular with the provisions of 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, p. 1), hereinafter referred to as "GDPR".
1.4 The Privacy Policy is of an informative nature, 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 fulfil the information obligation referred to in Article 13 of the GDPR.
2. FOR WHAT PURPOSE AND ON WHAT BASIS DO WE PROCESS YOUR PERSONAL DATA
2.1. Personal data obtained from you by the GKI Group companies are processed for the following purposes, depending on the entity (company) from the GKI Group and the situation in which the data was provided:
- a. conclusion and performance of an agreement concluded with an entity from the GKI Group (regardless of the form of its conclusion: in writing or by using our services provided electronically via the website) - to the extent necessary to establish, shape the content, amend, terminate and properly perform the agreement;
- b. performance of legal obligations incumbent on the GKI Group entity, e.g. issuing and storing invoices and accounting documents, responding to complaints, fulfilling obligations arising from the warranty for product defects, ensuring the safety of the services provided;
- c. determination, defense and pursuit of claims;
- d. direct marketing of the GKI Group entity's products and services;
- e. creating reports, analyses and statistics for the internal needs of the GKI Group, including in particular reporting, marketing research, advertising targeting, remarketing, service development planning, developmentwork in IT systems, creating statistical models; evaluation of the functioning of the GKI Group website, including statistics on the viewing of subpages;
- f. if you consent to the GKI Group company sending you commercial information electronically, your personal data will also be processed by us for the purpose of providing you with information about our services, offers and events organized by us, as well as information on the products and services of entities cooperating with us (with our knowledge and express consent).
2.2. Personal data is not used for purposes other than those specified in the Privacy Policy, unless the GKI Group company obtains your consent to process the data for other purposes, or another use of this information is required or permitted by law.
2.3. To the extent that the processing of your personal data is necessary for:
a. the performance of the contract concluded with you or to take action at your request before entering into the contract - the legal basis for the processing of your personal data by the GKI Group company is the contract;
b. fulfillment of a legal obligation incumbent on us - the legal basis is this legal obligation;
c. 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 pursuing and defending claims - the legal basis is the legally justified interest of the GKI Group company.
2.4. If our use of your data is not necessary for the performance of a contract, fulfilment of a legal obligation or does not constitute our legitimate interest, we may ask you to express your consent to certain uses of your data. Consent may take the form of ticking a box when browsing the website, selecting technical settings for using information society services or another statement or conduct that clearly indicates in a given context that you have accepted the proposed processing of personal data. You can withdraw your consent at any time (this will not affect the lawfulness of the use of your data before such withdrawal).
2.5. Providing your personal data is not mandatory, but failure to provide it will result in the GKI Group company not being able to perform the activities for which the data is required.
2.6. Based on your personal data, GKI Group companies will not make automated decisions regarding you, including decisions resulting from profiling.
3. RIGHTS THAT YOU HAVE
3.1. Every person whose personal data is processed by a GKI Group company has the right to access the content of their personal data and to immediately rectify data that is incorrect. Taking into account the purposes of processing, the person whose data is processed has the right to request that incomplete personal data be supplemented, including by submitting an additional declaration.
3.2. If you give your consent to the processing of data, in particular for marketing purposes (including the sending of commercial information by electronic means), you may withdraw your consent at any time. A user receiving specific information or services, such as an electronic information bulletin (so-called Newsletter), may unsubscribe from it at any time by following the instructions contained in each such document sent.
3.3. A person who provides their personal data to a GKI Group company has the right to request that the company immediately delete their personal data, and the company is obliged to delete personal data without undue delay if one of the following circumstances occurs:
- a. the personal data are no longer necessary for the purposes for which they were collected;
- b. the data subject has withdrawn the consent on which the processing is based and there is no other legal basis for the processing;
- c. the data subject objects to the processing;
- d. the personal data have been processed unlawfully;
- e. the personal data must be deleted in order to comply with a legal obligation under EU law or the law of the Member State to which the GKI Group company is subject.
3.4. Persons who provide their personal data to a GKI Group company have the right to request the restriction of the processing of personal data in the event that:
- a. the data subject questions the accuracy of the personal data – for a period enabling the GKI Group company to verify the accuracy of such data;
- b. the processing is unlawful and the data subject objects to the deletion of the personal data, requesting instead the restriction of their use;
- c. the GKI Group company no longer needs the personal data for the purposes of processing, but they are necessary for the data subject to establish, pursue or defend claims;
- d. the data subject has objected to the processing – until it is determined whether the legitimate grounds on the part of the GKI Group company override the grounds for objection of the data subject.
3.5. If the processing of personal data by a GKI Group company is carried out in an automated manner based on consent or a contract, the data subject has the right to receive the personal data concerning them that they have provided to the GKI Group company in a structured, commonly used and machine-readable format and has the right to transmit this personal data to another controller. The data subject has the right to request that the personal data be transmitted by the GKI Group company directly to another controller, if technically possible.
3.6. In order to exercise the rights referred to above, you can contact the GKI Group company in the manner indicated in point 9 below.
3.7. The GKI Group company will inform each recipient to whom the personal data has been disclosed of the rectification or deletion of personal data or the restriction of processing that it has carried out at your request, unless this proves impossible or requires a disproportionately large effort.
3.8. In connection with the processing of your personal data by the GKI Group companies, you have the right to lodge a complaint with the supervisory authority, i.e. the President of the Personal Data Protection Office.
1.1 Commercial companies linked by capital or personal ties, in particular those linked to the company Grupa Kapitałowa IMMOBILE S.A. in Bydgoszcz, form a group of companies, hereinafter referred to as the "GKI Group"; List of companies of the GKI Group for which this document applies: Grupa Kapitałowa IMMOBILE S.A., PJP MAKRUM S.A., PROMSTAHL Polska Sp. z o.o., Projprzem Budownictwo Sp. z o.o., Atrem S.A., Inicjatywa Północno-Zachodnia PW Sp. z o.o., QDS 24 Sp. z o.o., PBH S.A.
1.2 This document (hereinafter referred to as the "Privacy Policy") is information on the principles of processing and protection of personal data collected by entities from the GKI Group group of companies from you in connection with the purchase of products of entities from the GKI Group, use of services of entities from the GKI Group (including those provided electronically), inquiries addressed to entities from the GKI Group, the offer process, participation in events organized by entities from the GKI Group, participation in the recruitment process of employees of entities from the GKI Group, subscription to the Newsletter or other channels of information about products and services of entities from the GKI Group, exchange of correspondence, etc., including in particular in connection with the use of our websites.
1.3 The administrator of your personal data, within the meaning of the provisions of the law on the protection of personal data, is: Grupa Kapitałowa Immobile S.A. with its registered office in Bydgoszcz (85-033) at Plac Kościeleckich 3, entered into the register of entrepreneurs maintained by the District Court in Bydgoszcz, under KRS number 33561, NIP 5540309005 (hereinafter referred to as: "GKI") or another entity from the GKI Group. We are responsible for using your data in a safe manner and in accordance with applicable regulations, in particular with the provisions of 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, p. 1), hereinafter referred to as "GDPR".
1.4 The Privacy Policy is of an informative nature, 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 fulfil the information obligation referred to in Article 13 of the GDPR.
4. WHO DO WE TRANSFER YOUR PERSONAL DATA TO
4.1. We transfer your data to:
4.1.1. entities processing data on our behalf, participating in the performance of our activities:
- a) entities dealing with the servicing of IT systems and computer equipment that we use;
- b) entities managing our real estate
- c) our business partners, advertising agencies and other entities intermediating in the sale of our products and services or organizing marketing campaigns;
- d) subcontractors supporting us, e.g. in the performance of our services, transport of ordered products, product service, handling correspondence or in the customer service process;
- e) entities providing us with advisory, consulting, auditing services, legal, tax and accounting assistance, research agencies acting on our behalf;
4.1.2. other data controllers processing data on their own behalf:
- a) entities conducting postal or courier activities;
- b) entities acquiring receivables or dealing with their collection - in the event of your failure to pay our invoices on time;
- c) entities cooperating with us in handling accounting, tax and legal matters - to the extent to which they become the data controller.
4.2. Currently, the GKI Group does not plan to transfer your data outside the EEA (including the European Union, Norway, Liechtenstein and Iceland). However, it may turn out that during the term of the agreement we will decide to transfer data outside the EEA - only to the extent permitted by law.
4.3. GKI Group may share personal data at the request of authorities or law enforcement agencies, or when required by applicable laws, court orders or other state regulations. The need to share personal data may also be caused by conducting audits regarding data privacy or security and/or when dealing with complaints or taking action related to security threats. 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, which information could be used by such third parties for their marketing purposes.
5. HOW LONG DO WE STORE PERSONAL DATA
5.1. Your personal data will be stored no longer than necessary, i.e. depending on the purpose of their processing:
5.1.1. conclusion and performance of the agreement between you and the GKI Group company – for the duration of the agreement and settlements after its termination, including the duration of the warranty period for defects or quality guarantee provided in the agreement;
5.1.2. fulfillment of a legal obligation incumbent on the GKI Group company:
a) for the duration of the performance of obligations;
b) for the period during which the regulations require us to store data (e.g. tax); or
c) for the period during which we may suffer legal consequences of failure to fulfill the obligation, e.g. receive a financial penalty from state offices;
5.1.3. purposes resulting from legitimate interests pursued by the GKI Group company:
a) 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;
b) fraud prevention – for the duration of proceedings before the competent authorities;
c) pursuing and defending claims – for the period in which the claims become time-barred.
5.2. In the event that we process personal data based on your consent to specific ways of using the data, your data will be processed for the period indicated when obtaining consent, and in the absence of such indication – until you withdraw your consent.
6. AUTOMATIC DATA COLLECTION, COOKIES. OPERATIONAL DATA. GOOGLE TOOLS
6.1. When using the websites of the GKI Group companies, data concerning the user is also collected automatically. This data can be collected in the system logs of the website, through so-called 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 a computer, laptop, or on the memory card of a smartphone).
6.2. By saving Cookies on the device of the website user (computer, smartphone, tablet, etc.), the GKI Group company can, among other things:
- a. Adjust the functioning of the website to your needs.
- b. Eliminate the need to log in each time you visit the website (in the case of areas for registered users/customers).
- c. Remember your settings from session to session.
- d. Increase the speed and security of the website.
- e. Personalize the website according to your needs and enable users to find the information they need faster.
- f. Continually improve the website with its users in mind.
- g. Increase the effectiveness of marketing activities.
6.3. Cookies do not contain data identifying the user, and it is not possible to determine anyone's identity based on them. These files are not harmful to the user's end device in any way and do not change its settings or the settings of the software installed on it. The content of these files can only be read by the server that created them.
6.4. When the user uses our website, GKI uses three types of cookies: session cookies, permanent cookies and marketing cookies. Session cookies are temporary files that are stored in the user's device memory until the user logs out of the website, leaves the website or closes the browser. Permanent files are stored in the user's device memory for the time specified in the parameters of these files or until the user deletes them. Marketing files are "cookies" saved by other external scripts used on our website. They are used by us mainly for remarketing purposes (see items 6.11.-6.14 below).
6.5. By default, most web browsers available on the market accept the storage of Cookies by default. The User can independently and at any time change the settings for Cookies, specifying the conditions for their storage and access by Cookies to the User's device. The User can change the settings referred to in the previous sentence using the web browser settings or by configuring the service. These settings can be changed in particular in such a way as to block the automatic handling of Cookies in the web browser settings or to inform each time Cookies are placed on the User's device. Detailed information on the possibilities and methods of handling Cookies is available in the software (web browser) settings.
6.6. The User can delete Cookies at any time using the functions available in the web browser they use.
6.7. Limiting the use of Cookies may affect some functionalities available on the GKI Group websites.
6.8. Detailed information on changing the settings for Cookies and their independent removal in the most popular web browsers is available in the help section of the web browser.
6.9. 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 user's end device from which the user connects to the website appears in the system logs of the website. This data is aggregated and anonymous, i.e. it does not contain features identifying persons visiting the website. The logs are not disclosed to third parties.
6.10. The GKI Group may use the Google Analytics service, which collects anonymous information about the GKI websites visited by you using Cookies. Detailed information regarding the Google Analytics privacy policy can be found at: http://www.google.com/intl/pl/analytics/privacyoverview.html.
6.11. Additionally, a GKI Group company may use Google AdWords and Google Analytics remarketing codes from display advertisers. These codes are used to create remarketing lists in order to match individualized ads to users who have visited our website, and then display them in the Google AdWords advertising network, the Google search engine, and on the websites of entities that are participants in the Google partner network.
6.12. Our website, using the "similar audiences" function, operates within the Google AdWords system and checks how browsing of websites in the advertising network looked like in the last thirty days and subjects this information to the contextual targeting mechanism in order to determine the remarketing recipient profile. On this basis, Google AdWords finds a group of new users who have similar browsing patterns to people from the GKI Group company's remarketing list. This list is never based on browsing history on topics deemed sensitive, such as race, religion, sexual orientation or health.
6.13. When using remarketing tools and the “similar audiences” function, our website does not collect your personal data via Cookies, but only your browsing history, and as a result, the user remains anonymous.
6.14. The user has the option to opt out of the collection of remarketing codes and display advertiser codes via Google AdWords and Google Analytics, as well as the display of non-standard ads on the Google Display Network in the manner specified in point 6.5 above.
6.15. The GKI website may contain features that allow content to be shared using third-party social media applications, such as the “Like” button on Facebook or the Twitter widget. All of these social media applications may collect and use data regarding user activity on the GKI website. Any personal data provided by users via such social media applications may be collected and used by other users of the above social media applications, and interactions conducted using them are subject to the privacy policies of the companies that provide the applications. We have no influence on and take no responsibility for the above companies and their use of user data.
7. HOW WE PROTECT YOUR PERSONAL DATA
7.1 The GKI Group makes every effort to ensure a high level of security of the personal data it processes. Any events affecting data security, including suspicions of sharing files containing viruses and other files of a similar nature or other than files with destructive mechanisms, should be reported to the e-mail address indicated in point 9 below.
7.2 The GKI Group applies technical and organizational measures to ensure the protection of processed personal data appropriate to the threats and categories of data subject to protection, and in particular protects data against disclosure to unauthorized persons, removal by an unauthorized person, processing in violation of applicable regulations and change, loss, damage or destruction. In addition, the GKI Group takes special care to ensure that personal information is:
- correct and processed in a lawful manner,
- obtained only for specific purposes and not further processed in a manner incompatible with those purposes,
- adequate, relevant and not excessive,
- accurate and up-to-date,
- not stored longer than necessary,
- processed in accordance with the rights of the persons (to whom they relate), including the right to restrict disclosure,
- safely stored,
- not transferred without appropriate protection.
7.3 Personal data are stored in a database in which technical and organizational measures are applied to ensure the protection of processed data in accordance with the requirements specified by generally applicable legal provisions on the protection of personal data. Only persons with authorizations granted by the data controller have access to the database.
7.4 GKI Group has appropriate policies and procedures in place to protect personal data from unauthorized loss, misuse, alteration or destruction. We make every effort to ensure that access to your personal data is limited to those who need to know the information. Those who have access to the data are required to maintain its confidentiality. Additionally, one of GKI's policies in this area is to retain personal information only for as long as it is necessary to fulfill the user's request or until the user requests that such information be deleted.
8. CONTACT
In matters related to the processing of personal data, you can contact any of the GKI Group companies, as their administrator, by contacting the designated Data Protection Officer, writing to the following address: rodo@immobile.com.pl
9. CHANGES TO THE PRIVACY POLICY
The GKI Group may introduce changes to this document, which reflect the current Privacy Policy. In the event of modification, the date of the last update, which is shown below, also changes. Date of the last update of the Privacy Policy: 28.06.2023