PRIVACY

Privacy Policy 

What does our Privacy Policy contain? 

Information regarding the protection of your personal data, including information about your rights.

Our Privacy Policy is divided into three parts:

I. General Section, in which, among other things, we explain the terms used, present our contact details, and inform you about the rights to which you are entitled as a data subject.

II. Section Two, containing information on the processing of your personal data:

  1. Contact via the contact form.
  2. Information on the processing of personal data of individuals interested in receiving an offer relating to an investment carried out by Invest Komfort.
  3. Information on the processing of personal data of individuals expressing the intention to conclude an agreement for the purchase of real estate within an investment carried out by Invest Komfort.
  4. Marketing.
  5. Newsletter.
  6. Participation in contests and events organised through or by means of the Invest Komfort website.
  7. Public consultations

III. Section Three, information on Cookies
 

Part I. General Provisions 

Information on the Controller

1. The controller of your personal data is INVEST KOMFORT Spółka Akcyjna Spółka Komandytowa, entered into the register of entrepreneurs of the National Court Register under number KRS 0000504383 (hereinafter the “Controller” or the “Data Controller”, also referred to in this Privacy Policy as “Administrator” or “Invest Komfort”).

2. For the purposes of conducting marketing activities and activities related to handling the sales process, including presenting commercial offers concerning selected development projects, a situation may arise in which Invest Komfort and one of the entities listed below act as joint controllers within the meaning of Article 26 of the GDPR:

  • Smolna Spółka z ograniczoną odpowiedzialnością Spółka Komandytowa, KRS No.: 0000557327,
  • Toruńska Spółka z ograniczoną odpowiedzialnością Spółka Komandytowa, KRS No.: 0000641611,

(hereinafter in each case the "Joint Controller").
 

3. Joint controllership arises solely where a given investment project is implemented by one of the above-mentioned entities. In such a case, Invest Komfort and the relevant Joint Controller jointly determine the purposes and means of the processing of personal data in the scope of marketing and sales activities related to that investment project.

4. Joint controllership does not occur simultaneously between Invest Komfort and both of the above-mentioned entities. This means that, for a given investment project, the joint controllership relationship exists exclusively between Invest Komfort and one of the entities indicated above – i.e. either Smolna or Toruńska.

5. In its relationship with data subjects, Invest Komfort remains the entity responsible for the fulfilment of obligations arising from data protection legislation, including for ensuring the exercise of the rights laid down in the GDPR.

6. Information on the essential content of the arrangements between the Joint Controllers, concluded pursuant to Article 26(1) GDPR, is available upon request of the data subject.

7. You may contact us

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

Definitions Used in this Policy 

Where the following terms are used in this Policy, they shall be understood as follows:

1. Website / Service – the online service available at: https://investkomfort.pl/.

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/PL/TXT/?uri=celex%3A32016R0679
 

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 laws and regulations on data protection and privacy, including the GDPR.

2. We apply appropriate technical and organisational measures designed to safeguard the personal data entrusted to us, in particular measures preventing unauthorised access to or alteration of personal data transmitted electronically, i.e. through our Website, in accordance with the requirements arising from generally applicable laws.

 

Your Rights 

1.   Since we process your personal data, you have the following rights:

  • Right of access to your personal data;
  • Right to rectification of your personal data;
  • Right to erasure of your personal data, but only where permitted under the GDPR – we will inform you if you submit such a request;
  • Right to restriction of processing of your personal data, within the scope provided under the GDPR
     

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

  • for the purposes of direct marketing, without the need to justify your objection;
  • on the basis of other legitimate interests – in such a case, your objection must be justified by your particular situation (please explain why you believe we should not process your data).
     

3. In Section II of this Policy, you will find information on additional rights. For certain forms, you may have further possibilities depending on the context.

4. If you wish to exercise any of the above-mentioned rights, or if you would like to obtain more information regarding these rights, please contact us. You will find our contact details above, in the section titled “Information on the Controller.”
 

Complaint Regarding Personal Data Protection

If you believe that we are processing your personal data unlawfully, you have the right to lodge a complaint with the supervisory authority. In Poland, the competent supervisory authority is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych).

You may contact the supervisory authority in the following ways:

Questions Regarding the Policy and Its Publication 

1. If you have any questions regarding this Policy, please contact us at the following e-mail address: IOD_grupaIK@baltis.pl . 

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

Information on Profiling 

The personal data of natural persons may be subject to profiling (the creation of customer profiles) to the extent and in connection with sales and marketing analytics, the adjustment of displayed communications, advertisements and offers, as well as the tracking of a user’s activity on the Internet. The Controller (ADO) and the Joint Controller (WDO) inform their users of the intention to initiate profiling. Profiling begins only once the user has given their consent. If you wish to obtain more information regarding the profiling applied to you, please contact us at the e-mail address indicated above.

Section II. Information Relating to the Processing of Your Personal Data

Contact via the Contact Form.

1. Why do we need your data, i.e. for what purpose do we process it?

  • To respond to your message and to resolve the matter you have presented;
  • Based on your voluntary consent, for marketing purposes consisting of sending you offers concerning services we provide – via messages sent to the e-mail address or telephone number you have provided.
     

2. What rights do you have? 

  • This topic is described in Part I of the Policy under the section entitled “Your Rights.

3. Are you required to provide your data?

  •  No, providing your data is voluntary; however, without it we may be unable to resolve the matter you have submitted.

4. On what legal basis do we process your data

  • Article 6(1)(f) GDPR – the legitimate interest pursued by Invest Komfort;
  • If you have given your consent to receive commercial offers from us, the legal basis for such processing is Article 398 of the Polish Electronic Communications Law of 12 July 2024 (Dz.U. 2024, item 1221) in conjunction with Article 6(1)(a) GDPR (consent of the data subject).

Please remember that you may withdraw your consent at any time. If you wish to do so, please contact us.

5. What do we mean by a legitimate interest

  • Resolving the matter you have submitted, responding to your message, and activities related to sending offers.

6. Who are the recipients of the data?

  • Entities responsible for hosting (storing) the Website or personal data on behalf of Invest Komfort;
  • Providers of tools used for marketing activities;
  • Courier services and postal operators;
  • With your additional consent, our partners supporting Invest Komfort’s marketing activities;
  • Subcontractors of the Controller;
  • The Joint Controller (WDO)
     

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

  • If the transfer of your personal data outside the EEA becomes necessary, such transfer will take place on a legal basis provided for in the GDPR.

 8. For how long will we process your data?

For the period:

  • Necessary to resolve the matter. Depending on its nature, this may also include the period required to demonstrate that we have resolved it, i.e. the limitation period for possible claims;
  • During which we conduct marketing activities, or until you object to the further processing of your data for marketing purposes, or until you withdraw your consent to receive messages sent to the e-mail address you provided. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawa.
     

Information on the Processing of Personal Data of Individuals Interested in Receiving an Offer Concerning an Investment Carried Out by Invest Komfort.

1.    Why do we need your data, i.e. for what purpose do we process it?

  • To respond to your message relating to an offer;
  • To ensure transparency and consistency in the form and content of the offers provided to you, in particular to present conditions corresponding, among other things, to the Administrator’s current pricing policy and other information covered by the offer;
  • Based on your voluntary consent, for marketing purposes consisting of sending you offers concerning services we provide – via messages sent to the e-mail address or telephone number you have provided;
  • For the establishment, exercise or defence of potential legal claims

2. What rights do you have?

  • This topic is described in Part I of the Policy under the section entitled “Your Rights.”

3. Are you required to provide your data?

  • No, providing your data is voluntary; however, without it we may be unable to prepare and provide you with an offer.

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

  • Article 6(1)(f) GDPR – the legitimate interest pursued by Invest Komfort;
  • If you have given your consent to receive commercial offers from us, the legal basis for such processing is Article 398 of the Polish Electronic Communications Law of 12 July 2024 (Dz.U. 2024, item 1221) in conjunction with Article 6(1)(a) GDPR (consent of the data subject)

Please remember that you may withdraw your consent at any time. If you wish to do so, please contact us.

5. What do we mean by legitimate interest? 

  • Resolving the matter you have submitted, responding to your message, and activities related to preparing and sending an offer.

6. Who are data recipients? 

  • Entities responsible for hosting (storing) the Website or personal data on behalf of Invest Komfort;
  • Entities providing audit services;
  • Entities providing legal services;
  • Providers of tools used for marketing activities;
  • Courier services and postal operators;
  • With your additional consent, our partners supporting Invest Komfort’s marketing activities;
  • Subcontractors of the Administrator;
  • The Joint Controller (WDO).

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

  • If the transfer of your personal data outside the EEA becomes necessary, such transfer will take place on a legal basis provided for in the GDPR.

8. For how long will we process your data?

For the period:

  • Necessary to resolve the matter and to handle your offer enquiry. Depending on its nature, this may also include the period required to demonstrate that we have addressed your request, in particular that we have provided you with an offer, i.e. the limitation period for possible claims;
  • During which we conduct marketing activities, or until you object to the further processing of your data for marketing purposes, or until you withdraw your consent to receive messages sent to the e-mail address you provided. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Information on the Processing of Personal Data of Individuals Expressing the Intention to Conclude an Agreement for the Purchase of Real Estate within an Investment Carried Out by Invest Komfort.

1.    Why do we need your data, i.e. for what purpose do we process it?

  • For the purpose of entering into and performing the agreement concluded with the Controller and carrying out the necessary settlements arising from its conclusion — for the period required for the performance of the agreement; after its completion, the personal data will be processed for the time necessary to demonstrate the proper fulfilment of the obligations arising from it, until the expiry of the retention periods indicated in the archiving regulations;
  • For the performance of the Controller’s statutory obligations, in particular those arising from legal regulations applicable to the sale of real estate, as well as tax and reporting obligations — for the period necessary to fulfil the Controller’s statutory duties, especially until the expiry of the tax limitation periods;
  • For the establishment, exercise, or defence of potential legal claims.

2. What rights do you have? 

  • This topic is described in Part I of the Policy under the section entitled “Your Rights.”

3. Are you required to provide your data?

  • Providing your data is voluntary; however, failure to provide it will make it impossible to conclude and perform the agreement.

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

  • Article 6(1)(b) GDPR – processing necessary for the performance of a contract;
  • Article 6(1)(c) GDPR – processing necessary for compliance with a legal obligation to which the Controller is subject;
  • Article 6(1)(f) GDPR – the legitimate interest pursued by Invest Komfort.
     

5. What do we mean by a legitimate interest?

Ensuring the necessary settlements arising from the agreement, establishing or defending legal claims, as well as conducting assessments of the Controller and activities related to the Controller's reputation.

6. Who are the recipients of the data?

  • Entities responsible for hosting (storing) the Website or personal data on behalf of Invest Komfort;
  • Entities providing software and tools used by the Controller;
  • IT service providers;
  • Providers of electronic mail services;
  • Banks;
  • Entities providing audit services;
  • Entities providing legal services;
  • Courier services and postal operators;
  • Subcontractors;
  • The Joint Controller (WDO)
     

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

  • If the transfer of your personal data outside the EEA becomes necessary, such transfer will take place on a legal basis provided for in the GDPR.

Marketing 

1.    Why do we need your data, i.e. for what purpose do we process it?

  • To build and develop our public image in various media, including social media platforms and industry portals (Facebook, Instagram, YouTube, LinkedIn), by publishing posts and engaging in other forms of activity on social media.

2. What rights do you have?

  • This topic is described in Part I of the Policy under the section entitled “Your Rights.”

3. What personal data do we process?

  • We may process personal data published in the media, in particular on social media profiles, as well as other data related to our use of social media features.

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

  •  Article 6(1)(f) GDPR – the legitimate interest pursued by Invest Komfort.

5. Where have we obtained your personal data?

  • We obtain it from publicly available sources, such as websites or social media profiles (including in connection with your activity under our posts).

6. What do we mean by legitimate interest? 

  • Responding to your private messages sent to us via social media;
  • Communicating through comments under individual posts;
  • Sharing our posts as a follower of our profile;
  • Conducting marketing activities by informing you about our services and our company through posts on our social media profiles;
  • Carrying out analytical activities using statistics provided to us by social media platforms, including data on the views of our posts, their reach, the number of interactions, and demographic information about our followers; the data presented to us by social media platforms consists of aggregated statistics based on the platform’s observation of your behaviour on our profile
     

7. Who are the recipients of the data?

  • Social media platform providers;
  • Entities responsible for hosting (storing) the Website or personal data on behalf of Invest Komfort;
  • Providers of tools used for marketing activities;
  • Courier services and postal operators;
  • With your additional consent, our partners supporting Invest Komfort’s marketing activities;
  • The Joint Controller (WDO

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

  • If the transfer of your personal data outside the EEA becomes necessary, such transfer will take place on a legal basis provided for in the GDPR.

9. For how long will we process the data? 

  • For the duration of our legitimate interest, as described 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? 

  • No.

11. What options do you have if you do not want us to process your data or contact you? 

  • You have the right to object to the processing of your data. If you wish to exercise this right, please write to us at the e-mail address provided above or click the link included in every message you receive from us. You do not need to provide any reasons for your objection.

Newsletter 

1.    Why do we need your data, i.e. for what purpose do we process it?

  • For marketing purposes, including promoting our company and our services, in particular by sending marketing information via e-mail, SMS, or telephone calls to the telephone number you provide.

2.    What rights do you have?

  • This topic is described in Part I of the Policy under the section entitled “Your Rights.”

3.   Are you required to provide your data?

  • No, providing your data is voluntary; however, without it you will not be able to subscribe to the newsletter or receive commercial information from us.

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

  • Article 6(1)(f) GDPR – our legitimate interest;
  • Article 398 of the Polish Electronic Communications Law of 12 July 2024 (Dz.U. 2024, item 1221) in conjunction with Article 6(1)(a) GDPR – consent of the data subject.

Please remember that you may withdraw your consent to receive the newsletter and commercial information at any time. If you wish to do so, please contact us

5. What do we mean by a legitimate interest?

  • Promoting Invest Komfort’s services by sending you commercial information.

6. Who are the recipients of your data?

  • Providers of tools for: conducting marketing activities, sending newsletters.
  • Entities responsible for hosting (storing) our website and personal data on our behalf;
  • The Joint Controller (WDO

7. For how long will we process your data?

  • For the duration of our marketing activities, or until you object to the further processing of your data for marketing purposes, or until you withdraw your consent to receive messages to your e-mail address or via telephone contact. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. 

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

  • If the transfer of personal data outside the EEA becomes necessary, such transfer will take place on a legal basis provided for in the GDPR

Participation in Contests and Events Organised Through or Using the Invest Komfort Website 

1.    Why do we need your data, i.e. for what purpose do we process it?

  • For the performance of the agreement concluded between you and Invest Komfort regarding participation in the event or contest;
  • For the fulfilment of obligations arising from tax law and regulations concerning the right to withdraw from a distance contract;
  • For the establishment, exercise, or defence of claims arising from the agreement concluded or related to the provision of services.

2. What rights do you have?

  • This topic is described in Part I of the Policy under the section entitled “Your Rights.”

3. Are you required to provide your data?

  • No, providing your data is voluntary; however, without it you will not be able to register for the event or contest, nor participate in related activities.

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

  • Article 6(1)(b) GDPR – processing necessary for entering into and performing the agreement;
  • Article 6(1)(f) GDPR – the legitimate interest pursued by the Controller;
  • Article 6(1)(c) GDPR – processing necessary for compliance with a legal obligation to which the Controller is subject

5. What do we mean by legitimate interest?

  • Managing communication and handling the event in order to ensure the proper performance of the contest or event;
  • Establishing, pursuing, and responding to claims.

6. Who are the recipients of your data?

  • Providers of tools used for handling the contest or event;
  • Entities responsible for hosting (storing) our website and personal data on our behalf;
  • Agencies whose services the Controller uses in connection with the organisation of a given event or contest;
  • The Joint Controller (WDO).

7. For how long will we process your data?

  • For the duration of the agreement and for the time necessary to demonstrate its proper performance, i.e. until the expiry of the limitation periods for potential claims;
  • For the time necessary to demonstrate the proper fulfilment of our obligations, i.e. until the expiry of the limitation periods for claims or tax obligations;
  • For the duration of any dispute and for the period necessary to enforce claims.

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

If the transfer of personal data outside the EEA becomes necessary, such transfer will take place on a legal basis provided for in the GDPR.

 

Public Consultations

1.    Why do we need your data, i.e. for what purpose do we process it?

  • To fulfil legal obligations related to conducting public consultations, arising in particular from the Spatial Planning and Development Act, the Construction Law, and regulations concerning environmental impact assessments;
  • To ensure transparency of the investment process and the proper conduct of consultations;
  • To prepare and archive minutes, summaries, and reports documenting the course of the consultations;
  • To review and assess comments and submissions received


2.    What rights do you have?

  • This topic is described in Part I of the Policy under the section entitled “Your Rights”.

3.   Are you required to provide your data?

  • The provision of data is voluntary, but may be necessary in order to effectively make a comment or participate in the consultations, in particular if required by applicable law (e.g. the need to identify the person making the comment).

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

  • Article 6(1)(c) of the GDPR – fulfilment of a legal obligation incumbent on the Controller,
  • Article 6 (1)(f) of the GDPR, i.e., the legitimate interest.

5.    What do we mean by legitimate interest?

  • Ensuring transparency of development activities, actions related to proper conduct of public dialogue, and reviewing comments during the preparation and implementation of an investment project;
  • Establishing, pursuing, and responding to claims

6.    Who are data recipients?

  • Public authorities conducting planning, environmental, and construction proceedings;
  • Entities supporting the Controller in organising consultations (e.g. PR agencies, providers of consultation platforms);
  • Subcontractors of the Controller providing technical and organisational services;
  • The Joint Controller (WDO).


7.   For how long will we process your data?

  • For the period necessary to conduct and review the public consultations;
  • Thereafter for the period required by laws governing the archiving of documentation related to investment processes and administrative proceedings;
  • Where comments may form the basis of claims, until the expiry of the relevant limitation periods under civil or administrative law.

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

  • As a rule, no. If the transfer of personal data outside the EEA becomes necessary, it will occur on the basis of one of the legal grounds provided for in the GDPR.
     

 

Part III. Information about Cookies. 

1. Cookies are small text files stored on your computer or mobile device and subsequently retrieved from them during future visits to our Website. Cookies typically contain the name of the website from which they originate, the period for which they will be stored on your device, and a unique identifier. As a rule, the use of cookies does not allow us to identify you as a specific individual.

2. Cookies that are necessary for the functioning of the Website and applications are stored automatically. For all other categories of cookies, your consent is required.

3. Cookie management is carried out through a tool made available on the Website, which appears automatically during your first visit. Within this tool, you may give your consent to the use of specific categories of cookies.

4. You may also manage cookie settings directly through your browser settings. More information can be found on the websites of the respective browser providers 

a. Edge - https://support.microsoft.com/pl-pl/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy

b. Firefox - https://support.mozilla.org/pl/kb/W%C5%82%C4%85czanie%20i%20wy%C5%82%C4%85czanie%20obs%C5%82ugi%20ciasteczek 

c. Google/Chrome/Android - https://support.google.com/chrome/answer/95647?hl=pl 

d. Opera - http://help.opera.com/Windows/12.10/pl/cookies.html 

e. Safari - https://support.apple.com/kb/PH5042?locale=pl_PL

5. More information on the cookies used by Invest Komfort can be found here: https://investkomfort.pl/pl/cookie.

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