I. INFORMATION FOR THE PERSONS WHOSE DATA ARE OR SHALL BE PROCESSED

In connection with the performance of obligations resulting from the provisions of the 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 transfer of such data as well as the repealing Directive 95/46 / WE (hereinafter referred to as “GDPR“), this is to advise you as below:

• INVEST KOMFORT Spółka Akcyjna Spółka Komandytowa, KRS 0000504383 is your personal data administrator (hereinafter called „PDA”).
• To the extent that INVEST KOMFORT Spółka Akcyjna Spółka Komandytowa, KRS 0000504383, carries out investments jointly with: Smolna Limited liability company Spółka Komandytowa, KRS 0000557327 or Toruńska Limited liability company Spółka Komandytowa, KRS 0000641611, the process of co-administering personal data by INVEST KOMFORT Spółka Akcyjna Spółka Komandytowa and one of the abovementioned entities takes place respectively. The co-administrators (hereinafter referred to as “PDC“) agree on the purposes and means of processing the personal data. In respect of persons whose personal data are processed by the PDCs, the entity responsible for fulfilling the obligations related to the protection of personal data is INVEST KOMFORT Spółka Akcyjna Spółka Komandytowa, KRS 0000504383. The detailed content of the arrangements between the PDC will be made available at the request of the person whose data is or will be processed. Regardless of the above, the persons whose personal data are processed jointly by PDC, have the right to exercise their rights vis-à-vis the above-mentioned entity, which processes their personal data.
• The registered office address and correspondence address for each company is: Hryniewickiego 6c / 47, 81-340 Gdynia.
• In order to improve the handling of applications filed in relation to personal data of natural persons processed, PDO and PDC have appointed the Data Protection Inspector. All enquiries related to the processing of your personal data should be sent directly to the Inspector of Personal Data Protection.
• Notifications can be sent via e-mail or traditional mail.

E-mail address of the Data Protection Inspector: IOD_grupaIK@baltis.pl

Postal address of the Inspector of Personal Data Protection: Personal Data Protection Inspector of the IK Group, ul. Hryniewickiego 6c / 47, 81-340 Gdynia

• Please be advised that in any case you have the right to request: access to your personal data, rectification, deletion, introduce restrictions or oppose the processing. In a situation where the processing takes place in an automated manner, as much as it is technically possible, you may also request the transfer of your personal data to another administrator. You have the right to lodge a complaint with the President of the Office for Personal Data Protection at any time.
• If processing of personal data is necessary for the performance of the contract, to take action at the request of the person the data refers to before the conclusion of the contract, due to the justified interests of PDA or to fulfill the obligation of PDA, the recipient of your personal data will be PDA of PDC. The recipients of personal data may also be parties with whom PDA and PDC cooperate with to implement tasks to which they have committed (including law firms, notary offices, banks holding trust accounts, service contractors, property administrators, etc.).
• In the case when the processing of personal data is based on the consent of a given person, personal data may be transferred to entities with whom PDO or PDC cooperate in connection with the implementation of the specific purposes for which the processing takes place (marketing agencies, companies performing research questionnaires etc.).
• Personal data of natural persons may be subject to profiling (creation of customer profiles) in the scope and in relation to sales and marketing statistics, adjusting the contents of displayed notices, adverts, offers and tracing the user’s activity in the internet network. PDA and PDC inform their users on the intention of starting profiling activities. Profiling activities are started upon the acceptance of the user.
• Objectives and legal grounds for the processing of personal data:
  a) performing the provisions of contracts or taking actions at the request of the data subject before concluding the contract. Legal basis: art. 6 par. 1 letter b) THE GDPR. Providing personal data is a condition for the conclusion of the contract, and the lack of providing them prevents its conclusion;
  b) legitimate interest of PDA. Legal basis: art. 6 par. 1 letter f) GDPR. Processing of personal data of individuals in order to determine, defend and enforce claims arising from the contract, performing direct marketing activities, participating opinion research are the legitimate interests of PDA. Providing personal data by a natural person is not necessary because PDA is already in possession of such data;
  c) sending a traditional and electronic bulletin containing information about new investments, news about the company’s activities, open days and other organized events. Legal basis: Article 398 of the Electronic Communications Law (the consent of the data subject) depends on art. 6 par. 1 letter a) GDPR (consent of the data subject). Expressing consent and providing data is voluntary. Lack of consent or failure to provide personal data makes it impossible to send a bulletin by PDO or PDC;
  d) fulfilling legal obligations imposed on ADO resulting from universally binding legal regulations – in the scope of accounting, tax and archiving obligations. Legal basis: art. 6 par. 1 lit. c) GDPR.
• If the legal basis for the processing of your personal data is consent (see point 10 subsection c) of this information), you may withdraw your consent to the processing of your personal data. Withdrawal of consent does not affect the legality of the processing which was carried out on the basis of consent before its withdrawal.
• The period of time which your personal data will be processed depends on the purpose for which it has been collected, i.e.:
  a) in the case of natural persons being a party to an agreement concluded with PDO or PDC, or natural persons aiming to conclude a contract (conducting trade negotiations) with PDO or PDC at least until the lapse of time of claims of each party to the contract or for a period resulting from generally applicable provisions of law;
  b) in the case of natural persons interested in purchasing a real estate from the current PDO or PDC offer, in connection with the need to take action at the request of the person whose data is processed – for a period not longer than 3 years from the moment of request submission;
  c) in the case of natural persons expressing interest in purchasing a real estate that will be offered in the future – for a period not longer than 6 months from the date of the real estate’s introduction to the generally available public offer of PDA or PDC;
  d) in the case of natural persons who have consented to the processing of their personal data – until the withdrawal of consent.

II. PRIVACY POLICY

What information about the Users is collected by the website www.investkomfort.pl and how can it be used?

The website www.investkomfort.pl uses and collects information about its visitors only to the extent that it is necessary to provide services at the highest level.

In individual cases, we collect information about Users, such as: e-mail address or personal address data (e.g. in the case of surveys or queries sent via the form available on the website).

However, none of the above information will be passed on to third parties for the purposes other than the purpose for which the information has been collected.

The IP addresses of the Website Users are used in such cases as:

• the diagnosis of problems related to the work of our server;
• the analysis of security breaches or in connection with the management of our website;
• collecting or identifying demographic data of people who visit our website.

In special cases, we may prepare aggregate reports or general thematic lists that will be disclosed to third parties. These reports and statements, however, do not contain data allowing the identification of the Website Users.

Cookies

The website www.investkomfort.pl uses “Cookies”. “Cookies” files contain useful information and are stored on the User’s computer; our server can read them only when you re-connect to this computer. Disabling the “Cookies” function in the browser does not deprive the User of access to the resources of our website. The website www.investkomfort.pl uses “cookies” to provide content that best suits the interests of people visiting it and for other purposes, such as setting the ranking of the most-viewed investments.

In order to manage “Cookies” easily you must choose your browser from the list below and follow the instructions:

• Internet Explorer;
• Safari;
• Chrome;
• Firefox;
• Opera.

For mobile devices:

• Android;
• Safari;
• Windows Phone;
• Blackberry,
• Apple.

Failure to change the settings in the scope of “cookies” means that they will be placed on the end device of the User, and thus the administrator of the site will store information on the User’s terminal device and have access to it.

How do we use information from contact forms, surveys and participants of competitions at www.investkomfort.pl?

The website www.investkomfort.pl uses the contact form, through which you can submit inquiries and obtain the necessary information. This form allows the company to collect contact information from people visiting us, such as: name and surname, telephone number, e-mail address.

The information coming from the form is used to contact the person who submitted the query. Users of the website also have the opportunity to grant their consent to receive commercial information sent electronically from INVEST KOMFORT Spółka Akcyjna Spółka Komandytowa.

During the surveys conducted, we ask Users to provide contact information, such as an e-mail address. In justified cases, i.e. after expressing appropriate consent, we use contact information from completed surveys to send information about our company and promotional materials that may be of interest to people who participated in such research.

Users’ contact details are also used to make contact with them when necessary.

Protection of privacy of minors

The website www.investkomfort.pl does not monitor and does not verify information on the age of its Users. Contact information from people visiting the www.investkomfort.pl website, such as e-mail addresses, is used in accordance with the purpose in connection with which it was obtained. Minor users should not send any information nor subscribe to services provided by our website without consent of their parents or guardians.

Profiling activities

Profiling activities mean undertaking automated decisions (without the use of human factor), which may result in legal consequences or may adversely influence the situation of persons which they refer to. Personal data of users may otherwise influence the situation of persons which they refer to. Personal data of users may undergo profiling (creating the client’s profiles) in the scope and in the relation with the sales and marketing statistics, adjusting the contents to the displayed notices, advertisements, offers and tracking activity of the user of the internet network. PDA and PDC inform their users on the intention to start profiling activities. Profiling activities are started once the user has given his consent.

Security
The website www.investkomfort.pl is provided with security measures to protect against loss, misuse or modification of data under our control. We undertake to protect all information disclosed to us by Users in accordance with the principles of security and confidentiality. The right of access to personal data of Website users has been restricted in a restrictive way so that this information is not in the possession of unauthorized persons. Access to personal and address data is limited to a restricted number of authorized persons, on principles consistent with the provisions on the protection of personal data of individuals.

Contact
Users who have additional questions regarding this privacy policy, the practices used on this website or shared forms may, optionally, send messages to the e-mail address of the Personal Data Protection Inspector: IOD_grupaIK@baltis.pl.

Grupa Invest Komfort