Privacy (data protection) policy

Dear Sirs,  

Aurec Capital Group companies take the security of your personal data and privacy very seriously. Acting in accordance with the requirements 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 (hereinafter: the “GDPR”), we provide you below with information on how your data is processed and what rights you have as a result. 

1. Pursuant to Article 4.7 of the GDPR, the controller of the personal data is Aurec Home Holding sp. z o.o. with its registered office in Warsaw (00-107), at ul. Próżna 7/9, entered in the register of entrepreneurs kept by the District Court for the capital city of Warsaw in Warsaw, 12th Commercial Division of the National Court Register under number 0000826670, NIP: 5272919932, REGON: 385486790 (hereinafter: the “Company”). 

2. The Company has appointed a Data Protection Officer (DPO) who can be contacted on matters relating to data protection and the exercise of related rights. For this purpose, it is possible to contact the Company by e-mail at iod@aurechome.com or by post to the Company’s registered office address. 

3. Your personal data may be processed for the following purposes and on the following legal bases:  

1. to carry out correspondence, including ongoing communication relating to enquiries you make (e.g., enquiries about premises in which you are interested), which constitutes a legitimate interest of the Company (legal basis for processing: Article 6(1)(f) of the GDPR), 

2. to carry out activities in the form of direct marketing, which constitutes a legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) of the GDPR), 

3. to send commercial information by electronic means (e-mail) concerning offers for sale and lease of premises and other related services offered by Aurec Home Holding sp. z o.o. and other entities of the Aurec Capital Group operating in Poland – if a particular person has agreed to receive this type of information (legal basis for data processing: Article 6(1)(a) of the GDPR), 

4. for marketing communication with the use of telecommunication terminal devices and automatic calling systems (telephone calls, SMS/MMS messages) in order to present offers for the sale and rental of premises and other related services offered by Aurec Home Holding sp. z o.o. and other entities of the Aurec Capital Group operating in Poland – if a specific person has given separate consent for such communication to the indicated telephone number (legal basis for data processing: Article 6(1)(a) of the GDPR), 

5. to carry out statistical analyses, which constitutes a legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) of the GDPR), 

6. to store data for archiving purposes and for the purpose of demonstrating the correctness of the fulfilment of the Company’s legal obligations, which constitutes its legitimate interest (legal basis for processing: Article 6(1)(f) of the GDPR), 

7. for the internal administration of the business and administrative processes carried out within the Aurec Capital Group, which constitutes the Company’s legitimate interest (legal basis for processing: Article 6(1)(f) of the GDPR). 

4. Your personal data may be disclosed to the following entities:  

1. entities supporting the Company with technical and IT services (including the provision, implementation and maintenance of software and IT hardware services, hosting services and similar), 

2. marketing agencies providing services to the Company,  

3. law firms providing services to the Company, 

4. consulting, auditing and advisory entities – within the scope of the services provided by these entities to the Company, 

5. providers of financial intermediation, interior design and fit-out services, 

6. Aurec Capital Group entities – in the administration of internal administrative and business processes within the Capital Group. 

5. Personal data may be transferred by the Company outside the European Economic Area (EEA). In this case, the Company will guarantee the legally required personal data protection measures, which may include (as the case may be): I) data transfer to an entity located in a third country for which an adequacy decision has been issued as required by Article 45 of the GDPR, II) data transfer carried out on the basis of a data transfer agreement concluded with a third party based on the Standard Contractual Clauses adopted by a decision of the European Commission, III) data transfer carried out within the framework of adopted binding corporate rules referred to in Article 47 of the GDPR. The person to whom data is transferred in the aforementioned case has the right to obtain a copy of the information on the safeguards applied. For more information on the Company’s security measures relating to the transfer of data outside the EEA, please contact us by email at iod@aurechome.com or by post at the Company’s registered office. 

6. The Company ensures the right to exercise the rights provided under the GDPR, i.e., the right to request access to one’s personal data, the right to rectify, erase or request the restriction of processing, the right to data portability, as well as the right to object to its processing, under the terms and in the cases provided for by the GDPR. 

7. In the case of processing of personal data by the Company for the purpose of pursuing legitimate interests (as mentioned above), we inform you of your right to object to the processing of your data on grounds relating to your particular situation, and furthermore of your right to object at any time in the case of processing for direct marketing purposes. 

8. In cases of processing of personal data on the basis of consent given, we inform you of the right to withdraw consent at any time without stating a reason, which will not, however, affect the compliance of the processing that took place before the withdrawal of consent. 

9. Personal data will be stored by the Company: 

1. for the period of time necessary for the Company to document before public authorities, including the supervisory authority for the protection of personal data, the correctness of the fulfilment of its legal obligations, 

2. for archiving purposes, where this concerns the history of correspondence and responses to queries raised, for a period of up to 3 years after the data was obtained, 

3. for direct marketing purposes – until such time as you object to the processing of your data or until the data is rendered obsolete, 

4. for the purpose of sending commercial communications by electronic means (e-mail) or for marketing communications using telecommunications terminal equipment and automatic calling systems – until you withdraw your consent for these purposes or until your data becomes obsolete. 

10. We inform you of your right to lodge a complaint in relation to the processing of your personal data with the supervisory authority, which is the President of the Office for Personal Data Protection. 

11. Your data will not be processed in an automated manner that could at the same time lead to decisions being made against you that produce legal effects or similarly significantly affect you. 12. The provision of personal data for the above-mentioned purposes is voluntary, but necessary for the above-described purposes.