Privacy

PRIVACY

Privacy Policy

What does our Privacy Policy contain?

The Privacy Policy contains information about the protection of your personal data, including your rights.

Our Privacy Policy is divided into three parts:

I. General Part, including the Policy’s terminology, contact details and information on your rights as a data subject.

II. Part Two, containing information on the processing of your personal data;

Contact via the contact form.
Information on the processing of personal data of persons seeking a proposal for a project implemented by Invest Komfort.
Information on the processing of personal data of persons expressing their will to conclude an agreement on the purchase of real estate within the project implemented by Invest Komfort.
Marketing.
Newsletter.
Participation in competitions or events organised through or with the use of Invest Komfort’s website.

III. Part Three, including information on cookies.

Part I. General Provisions

Information about the Controller

1. The controller of your personal data is INVEST KOMFORT Spółka Akcyjna Spółka Komandytowa, KRS (National Court Register) number 0000504383 (hereinafter referred to as the “DC”), thereafter referred to as the “Controller” or “Invest Komfort”.

Insofar as INVEST KOMFORT conducts marketing activities (described in Part II of the Privacy Policy in paragraph 4) jointly with:

• Smolna Spółka z ograniczoną odpowiedzialnością Spółką Komandytową, KRS number 0000557327.
• Toruńska Spółka z ograniczoną odpowiedzialnością Spółka Komandytowa, KRS number 0000641611.

Personal data are controlled jointly by these entities. Joint Controllers (hereinafter referred to as the “JC”) determine jointly the purposes and methods of personal data processing. For persons whose personal data are processed by the JC, the entity responsible for fulfilling the obligations related to the protection of personal data is INVEST KOMFORT Spółka Akcyjna Spółka Komandytowa, KRS number 0000504383. The main content of the arrangements between the JC will be made available at the request of the present or future data subject.

2. You can contact us:

by post: ul. Hryniewickiego 6c/47, 81-340 Gdynia.
by e-mail: IOD_grupaIK@baltis.pl
Data Protection Officer’s mail address: Inspektor Ochrony Danych Osobowych Grupy IK, ul. Hryniewickiego 6c/47, 81-340 Gdynia.

Policy Terminology.

The following terms are to be understood in our Policy as such:

1. Website: the website https://investkomfort.pl/en.
2. Policy: this document, i.e., the Privacy Policy you are reading.
3. GDPR: 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. The text of the GDPR is available: here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0679

Security of Personal Data

1. We are committed to protecting the privacy of your personal data. We will use personal data in accordance with applicable data protection and privacy laws and regulations, including the GDPR.
2. We have undertaken technical and organisational measures in order to secure the personal data transmitted to us and, in particular, to prevent unauthorised persons from obtaining and modifying personal data transmitted electronically, i.e., within the framework of our Website, in accordance with the requirements of generally applicable legislation.

Your Rights

1. We process your personal data, hence:

You have the right to access the personal data;
You may request their rectification;
You may request their erasure, but only if it is allowed by the GDPR, which we will inform you about if you make such a request;
You have the right to restrict the processing of your personal data, to the extent specified in the GDPR.

2. You also have the right to object to the processing of your personal data. You may exercise this right if we process personal data:

for the purpose of direct marketing: in this instance, with or without a reason/cause;
on the basis of other legitimate interests: in this instance, a justification with regards to your specific situation is required (describe the reason why we should not process your data).

3. The second part of the Policy contains information on further rights, since, for some forms, you will have additional options.
4. If you exercise the above rights or need to learn more about them, please contact us. Contact details are available above, in the “Information about the Controller” section.

Complaint Concerning the Protection of Personal Data

If you deem our processing of your personal data unlawful, you may lodge a complaint with a supervisory authority. In Poland, it is the President of the Personal Data Protection Office, who can be contacted:

by post: ul. Stawki 2, 00-193 Warszawa
by means of Electronic Inbox available at: https://www.uodo.gov.pl/pl/p/kontakt
by telephone: +48 (22) 531 03 00

Questions about the Policy. Place of Publication

1. Should any questions about the Policy arise, please contact us by e-mail at IOD_grupaIK@baltis.pl.

2. The Policy is available at: https://investkomfort.pl/pl/polityka-prywatnosci

Information on Profiling

Natural persons’ personal data may be subject to profiling (creation of customer profiles) within the scope of and in respect of sales and marketing statistics, personalizing the content of displayed messages, advertisements, and offers, and tracking the user’s online activity. DC and JDCs will inform their users about the wish to initiate profiling. Profiling starts upon the user’s consent. If you need more information about the profiling applied to you, please contact us at the e-mail address above.

Part II. Information on the Processing of Your Personal Data

Contact via the contact form.

1. Why do we need your data, i.e., what is our purpose in their processing?

For the purposes of responding to your messages and resolving matters;
based on your voluntary consent, for the marketing purposes, i.e., to the receipt of the proposals of our services at the e-mail address or telephone number you have provided.

2. What rights do you have?

This issue is described in the “Your Rights” section of the Part I of the Policy.

3. Is it obligatory to provide your data?

No, it is voluntary, but unless the data are provided we may be unable to resolve presented matters.

4. On what legal basis do we process your data?

Pursuant to Article 6(1)(f) of the GDPR, i.e. the legitimate interest of Invest Komfort;
if you have given your consent for us to mail you commercial proposals, the legal basis for such action is the Article 398 of the Electronic Communication Law Act of 12 July 2024, Journal of Laws 2024, item 1221 (art. 398 ustawy z dnia 12 lipca 2024 r. – Prawo Komunikacji Elektronicznej, Dz. U. 2024 poz. 1221), in conjunction with the Article 6(1)(a) of the GDPR (consent of the data subject).

Please note that you may withdraw your consent anytime. If you wish to do so, please contact us.

5. What do we mean by legitimate interest?

By legitimate interest we mean resolving your presented matters, responding to messages and activities related to mailing proposals.

6. Who are data recipients?

The entities responsible for hosting the Website or personal data for Invest Komfort;
marketing tools providers;
delivery and postal services;
based on your additional consent, our partners handling Invest Komfort’s marketing activities;
Controller’s subcontractors;
JCs.

7. Will the data be transferred outside the European Economic Area?

If your personal data must be transferred outside the EEA, it will occur on the legal basis provided for in the GDPR.

8. For how long will we process the data? For the time:

needed to resolve the matter. Depending on its nature, also for the time necessary to prove that we have resolved it, i.e. until the statute of limitations for claims expires;
of our marketing activities, or until you object to further processing of data for marketing purposes or withdraw your consent to the receipt of messages at the e-mail address you have provided. The withdrawal of consent does not affect the lawfulness of processing before its withdrawal.

Information on the processing of personal data of persons seeking a proposal for a project implemented by Invest Komfort.

1. Why do we need your data, i.e., what is our purpose in their processing?

For the purpose of replying to your message related to the proposal;
for the purposes of ensuring transparency and consistency in the form and content of the proposals provided to you and, in particular, of presenting terms and conditions corresponding, i.a., to the Controller's current pricing policy and other information included in the proposal;
based on your voluntary consent, for the marketing purposes, i.e. to the the receipt of proposals of our services at the e-mail address or telephone number you have provided.
for the purposes of exercise and defence of legal claims, if any.

2. What rights do you have?

This issue is described in the “Your Rights” section of the Part I of the Policy .

3. Is it obligatory to provide your data?

No, it is voluntary, but unless the data are provided we may be unable to draw up proposals and share them with you.

4. On what legal basis do we process your data?

Pursuant to Article 6(1)(f) of the GDPR, i.e. the legitimate interest of Invest Komfort;
if you have given your consent for us to mail you commercial proposals, the legal basis for such action is the Article 398 of the Electronic Communication Law Act of 12 July 2024, Journal of Laws 2024, item 1221 (art. 398 ustawy z dnia 12 lipca 2024 r. – Prawo Komunikacji Elektronicznej, Dz. U. 2024 poz. 1221), in conjunction with the Article 6(1)(a) of the GDPR (consent of the data subject). Please note that you may withdraw your consent anytime. If you wish to do so, please contact us.

5. What do we mean by legitimate interest?

By legitimate interest we mean resolving your presented matters, responding to messages and activities related to drawing up and mailing proposals.

6. Who are data recipients?

The entities responsible for hosting the Website or personal data for Invest Komfort;
audit service providers;
legal service providers;
marketing tools providers;
delivery and postal services;
based on your additional consent, our partners handling Invest Komfort’s marketing activities;
Controller’s subcontractors;
JCs.

7. Will the data be transferred outside the European Economic Area?

If your personal data must be transferred outside the EEA, it will occur on the legal basis provided for in the GDPR.

8. For how long will we process the data? For the time:

needed to resolve the matter and related to the processing of the enquiry. Depending on the matter’s nature, also for the time necessary to prove that we have resolved it and, in particular, mailed the proposal, i.e., until the statute of limitations for claims expires;
of our marketing activities, or until you object to further processing of data for marketing purposes or withdraw your consent to the receipt of messages at the e-mail address you have provided. The withdrawal of consent does not affect the lawfulness of processing before its withdrawal.

Information on the processing of personal data of persons expressing their will to conclude an agreement on the purchase of real estate within the project implemented by Invest Komfort.

1. Why do we need your data, i.e., what is our purpose in their processing?

For the purposes of concluding an agreement and performing the agreement concluded with the Contractor and making the necessary accounts in respect of its conclusion for the time necessary for the performance of the agreement. After its termination, the personal data will be processed for the time necessary to demonstrate the correct performance of the obligations arising from the agreement, until the expiry of the periods as set forth in the regulations on archiving;
for the purpose of fulfilling the Contractor’s statutory obligations, in particular those related to the necessity of complying with the applicable legal regulations on the sale of real estate, as well as tax and reporting obligations, for the time necessary to perform the Controller’s statutory obligations, in particular until the expiry of the period of limitation for tax liabilities;
for the purposes of exercise and defence of legal claims, if any.

2. What rights do you have?

This issue is described in the “Your Rights” section of the Part I of the Policy .

3. Is it obligatory to provide your data?

No, it is voluntary; failing to do so, however, will result in the inability to conclude and perform the agreement.

4. On what legal basis do we process your data?

Pursuant to Article 6(1)(b) of the GDPR;
Pursuant to Article 6(1)(c) of the GDPR;
Pursuant to Article 6(1)(f) of the GDPR, i.e., the legitimate interest of Invest Komfort.

5. What do we mean by legitimate interest?

By legitimate interest we mean providing the necessary settlements in respect of the agreement you concluded, exercise and defence of legal claims, if any, and the assessment of the Controller and Controller’s image-building activities.

6. Who are data recipients?

The entities responsible for hosting the Website or personal data for Invest Komfort;
the providers of the software and tools used by the Controller;
IT service providers
e-mail service providers;
banks;
audit service providers;
legal service providers;
delivery and postal services;
subcontractors;
JCs.

7. Will the data be transferred outside the European Economic Area?

If your personal data must be transferred outside the EEA, it will occur on the legal basis provided for in the GDPR.

Marketing

1. Why do we need your data, i.e., what is our purpose in their processing?

For the purpose of building our image in the media, including social media and industry portals (Facebook, Instagram, YouTube, LinkedIn), by means of publishing posts and other social media activity.

2. What rights do you have?

This issue is described in the “Your Rights” section of the Part I of the Policy .

3. What personal data do we process?

We may process personal data published in the media, in particular in social media profiles, and other data related to our use of social media functions.

4. On what legal basis do we process your data?

Pursuant to Article 6(1)(f) of the GDPR, i.e., the legitimate interest of Invest Komfort.

5. Where have we obtained your personal data?

We have obtained the data from publicly available sources, i.e., for example websites and social media profiles (i.a., as a result of your interaction with our posts).

6. What do we mean by legitimate interest?

By legitimate interest we mean responding to your private messages sent to us via social media;
having conversations in comments under individual posts;
sharing our posts as a follower of our profile;
marketing, consisting in informing you about our services and ourselves through posts on our social media profiles;
analytical activities through statistics presented to us by social media entities, including the data on the display of our posts, their reach, the number of interactions, and the demographics of our followers. The data presented to us by social media entities are the statistics compiled by respective companies on the basis of monitoring your behaviour on our profile.

7. Who are data recipients?

Social media providers;
the entities responsible for hosting the Website or personal data for Invest Komfort;
marketing tools providers;
delivery and postal services;
based on your additional consent, our partners handling Invest Komfort’s marketing activities;
JCs.

8. Will the data be transferred outside the European Economic Area?

If your personal data must be transferred outside the EEA , it will occur on the legal basis provided for in the GDPR.

9. For how long will we process the data?

For the duration of our legitimate interest as defined above but no longer than until you object to the processing of your personal data.

10. Will you be subject to automated processing, including profiling, which will produce legal or likewise effects on you?

11. What options do you have if you would not like us to process your data and contact you?

You have the right to object to data processing. Should you wish to express such an objection, please contact us at the e-mail above or click the link you can find in each e-mail you receive from us. You do not need to provide any reasons for the objection.

Newsletter

1. Why do we need your data, i.e., what is our purpose in their processing?

For the purpose of marketing, i.e., the promotion of us and our services, including providing marketing information by e-mail, text messaging or calling the telephone number you have provided.

2. What rights do you have?

This issue is described in the “Your Rights” section of the Part I of the Policy .

3. Is it obligatory to provide your data?

No, it is voluntary, but unless the data are provided you will not be able to subscribe to the newsletter and receive commercial information from us.

4. On what legal basis do we process your data?

Pursuant to Article 6(1)(f) of the GDPR, i.e., our legitimate interest;
the Article 398 of the Electronic Communication Law Act of 12 July 2024, Journal of Laws 2024, item 1221 (art. 398 ustawy z dnia 12 lipca 2024 r. – Prawo Komunikacji Elektronicznej, Dz. U. 2024 poz. 1221), in relation to the Article 6(1)(a) of the GDPR (consent of the data subject).
Please note that you may withdraw your consent to receive newsletter and commercial information anytime. If you wish to do so, please contact us.

5. What do we mean by legitimate interest?

By legitimate interest we mean promoting Invest Komfort’s services by mailing to you commercial information.

6. Who are the recipients of your data?

The providers of tools for: - marketing, - newsletter mailing.
The entities hosting the Website and personal data for us;
JCs.

7. For how long will we process the data?

For the duration of the marketing activities, or until you object to further processing of data for marketing purposes, or withdraw your consent to sending messages to your e-mail address or being contacted by telephone. The withdrawal of consent does not affect the lawfulness of processing before its withdrawal.

8. Will the data be transferred outside the European Economic Area?

If your personal data must be transferred outside the EEA , it will occur on the legal basis provided for in the GDPR.

Participation in Competitions or Events Organised Through or With the Use of Invest Komfort’s website

1. Why do we need your data, i.e., what is our purpose in their processing?

For the purpose of performing the agreement you have concluded with Invest Komfort, regarding your participation in an event or competition;
fulfilling the obligations arising from the provisions of tax law and the provisions on withdrawal from a remote agreement;
exercise and defence of legal claims arising from the agreement you have concluded or service-related services.

2. What rights do you have?

This issue is described in the “Your Rights” section of the Part I of the Policy .

3. Is it obligatory to provide your data?

No, it is voluntary, but unless the data are provided you will not be able to subscribe to the newsletter and receive commercial information from us.

4. On what legal basis do we process your data?

Pursuant to Article 6(1)(b) of the GDPR, i.e., for the purpose of concluding an agreement and performing the concluded agreement;
Pursuant to Article 6 (1)(f) of the GDPR, i.e., the legitimate interest;
Pursuant to Article 6(1)(c) of the GDPR, i.e., the fulfilment of the Controller’s legal obligations.

5. What do we mean by legitimate interest?

By legitimate interest we mean communication and handling the event in order to properly perform the competition or event;
investigation and response to claims.

6. Who are data recipients?

The providers of tools for handlings competitions or events;
The entities hosting the Website and personal data for us;
the agencies whose services the Controller will use to organise the competition or event in question;
JCs.

7. For how long will we process the data?

For the duration of the agreement and the time necessary to demonstrate that we have performed the agreement properly, i.e., until the statute of limitations for claims expires;
for as long as it is necessary to demonstrate our proper performance of the obligations, i.e., until the statute of limitations for claims and the period of limitation for tax liabilities expire;
for the duration of the dispute and for the time necessary to enforce the claim.

8. Will the data be transferred outside the European Economic Area?

If your personal data must be transferred outside the EEA , it will occur on the legal basis provided for in the GDPR.

Part III. Information about Cookies.

1. Cookies are small text files stored on your computer or mobile device and then retrieved from them on subsequent visits to our website. Cookies usually contain the names of websites of their origin, the period of time they are stored on the device, and a unique number. The use of cookies does not essentially lead to us identifying you as the particular person.
2. Cookies, which are essential for the functioning of the website and applications, are saved automatically. With regard to other types of cookies, your consent is required.
3. Cookies are managed through a tool provided on the website, which displays automatically on first visit on the Website, where you can consent to the use of particular categories of cookies.
4. You may also change cookies settings in your browser’s settings. More information is available on the sites of the providers of individual browsers:

5. More information about the cookies used by Invest Komfort is available here:
https://investkomfort.pl/en/cookie.

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