Privacy Policy

PRIVACY POLICY OF EQUILIS POLAND SERVICES SP. Z O.O.

In this Privacy Policy of Equilis Poland Services Sp. z o.o., we outline the principles governing the processing of your personal data, particularly when you use our Equilis Poland Services Sp. z o.o. websites   i.e., websites under the main domain equilispoland.pl and other websites operated by Equilis Poland Services Sp. z o.o. and entities belonging to the Equilis Poland Services Sp. z o.o. Capital Group .  The purpose of this Privacy Policy is to ensure the protection of your personal data and to process the collected data in a manner that interferes as little as possible with the privacy of individuals using our services. In this Policy, we specify exactly what data we collect and explain the purposes for which we do so, the legal basis for such processing, and how long we retain it. We also inform you of your rights.

We take the utmost care to ensure that all our activities related to the processing of personal data comply with the law, in particular: with

• Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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. OJ EU L 2016 No. 119/1 (“GDPR”);
• The Act of July 18, 2002, on the Provision of Electronic Services, as codified in the Journal of Laws of 2013, item 1422, as amended;
• The Telecommunications Law of July 16, 2004, as consolidated in the Journal of Laws of 2014, item 243, as amended.

Who is the controller of your personal data?

The controller of your personal data is Equilis Poland Services Sp. z o.o., with its registered office in Warsaw at ul. Chmielna 73, 00-801 Warsaw, a company entered in the Register of Entrepreneurs maintained by the District Court for the Capital City of Warsaw under KRS number 0000905030, NIP 5272960691, as well as the companies comprising theEquilis Poland Services Sp. z o.o. Capital Group( hereinafter “Equilis”); email contact:office.poland@equilis.net

Contact Information for Matters Related to Personal Data Protection at Equilis

For inquiries regarding privacy or the protection of personal data, please contactESERNILL INVESTMENTS SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ atits registered office at Aleje Jerozolimskie 93, 02-001 Warsaw, Poland, or via email at:  

Where do we obtain your personal information?

•  from the contact forms posted on our websites,
•  from forms you fill out during housing fairs, open houses, or other public events organized by Equilis or entities that partner with us,
•  under a contract (e.g., a reservation agreement, a development agreement, or other agreement) entered into with Equilis or companies of the Equilis Group,
•  from an email sent to our Sales Office,
•  Upon your entry into our contests (acceptance of the contest rules) and submission of your personal information to us for the purpose of participating in a given contest,
•  from an entity that has entered into a service agreement with Equilis or a company in the Equilis Group to provide services to you, or that has shared your data based on your consent (e.g., a website featuring Equilis apartment listings).

When you use our website, we automatically collect anonymous data regarding, among other things:

•  time spent on the website
•  number of visits
•  device type (e.g., mobile / desktop)
•  browser type, browser language
•  operating system type, etc.
•  using geolocation to tailor website content to users from a specific location
•  Recently viewed apartments and apartments selected by the user for comparison

We assure you that this information is not disclosed to anyone other than those authorized to administer the website. This data may be used for: statistical analysis, personalizing the content of our websites, and personalizing advertisements.

You can find detailed information about our Cookie Policy here.

Whose data do we process, and under what terms?

Personal data processed in connection with filling out the online contact form

Your personal data may be processed for marketing and commercial purposes—the basis for this processing of your personal data is solely your consent (obtained in accordance with Article 6(1)(a) of the GDPR), as well as—to the extent of the controller’s legitimate interest—for the purpose of establishing, exercising, or defending against legal claims (Article 6(1)(f) of the GDPR). The scope of your personal data being processed includes: first and last name, email address, and phone number. By filling out the contact form, you consent to receiving the following from us:

•  commercial offers made by phone or email, or
•  marketing communications by phone or email.

In the form, please provide your first and last name, email address, and/or phone number. In response, you will receive our offer along with a presentation of the apartments or any other information you request.

Your personal data will be processed for as long as necessary to fulfill the purpose and for the period necessary to defend against any potential claims that may arise in connection with the subject matter of your consent. If you wish to have the information we process deleted earlier, or if you do not wish to receive commercial or marketing communications from us, please send your objection tooffice.poland@equilis.netor to the contact information provided above.

Filling out online forms to schedule a phone call with one of our advisors

The basis for scheduling a phone call with one of our advisors is solely your consent, which you provide via the form in which we ask you to provide your phone number. Selected calls automatically scheduled in this manner may be recorded. Our Sales Office advisors will always inform you about the recording of phone calls before the call begins. If we do not obtain your consent to the recording, the call will be immediately terminated and will not continue. Your consent to the processing of personal data in connection with the recording is given through an explicit confirmatory action—namely, your consent to continue the phone call.

During our conversation, you may provide us with additional information or details that will allow us to tailor our housing offerings to your needs. The legal basis for processing your personal data is Article 6(1)(a) of the GDPR. If you decide to provide us with additional information, such as your first and last name or email address, we will ask for your explicit consent in accordance with applicable law.

Your personal data recorded by the recording device will be processed for the purpose of providing proper customer service to Equilis customers, documenting your consents, and establishing any grounds for asserting, pursuing, or defending claims pursuant to Article 6(1)(a) of the GDPR and Article 6(1)(f) of the GDPR.

In cases where recordings of a recorded telephone conversation constitute evidence in legal proceedings, the retention period may be extended until the legal proceedings are finally concluded or until you withdraw your consent, and after such withdrawal, solely for the purpose of safeguarding Equilis’s legal interests in order to establish, pursue, or defend claims.

If you wish to have the information we process deleted earlier than scheduled, or if you do not wish to receive any commercial or marketing communications from us, please send your request tooffice.poland@equilis.netor to the contact information provided above.

Personal data of Equilis customers in connection with the conclusion and performance of a contract

Your personal data may be processed for the purpose of carrying out activities requested by you prior to entering into a contract with us (e.g., a reservation agreement, a real estate development agreement, etc.) and for the performance of the contract you have entered into with us, i.e., pursuant to Article 6(1)(a) of the GDPR. In connection with the conclusion of a contract with you, we also process your personal data to comply with legal obligations, such as issuing an invoice (legal basis: Article 6(1)(c) of the GDPR) and for the purposes of establishing, exercising, or defending legal claims, as well as for direct marketing (legal basis: Article 6(1)(f) of the GDPR).

Your personal data will be processed for the time necessary to fulfill the contract and comply with legal obligations, as well as for the period necessary to defend against any potential claims. With regard to the processing of your data for direct marketing purposes, we will process your data until you object.

If you do not wish to receive direct marketing communications from us, please send your objection tooffice.poland@equilis.netor to the contact information provided above.

Equilis does not make any automated decisions, and your personal data is not used for profiling

Personal data of Equilis' business partners and associates

We process your personal data and other information you provide to us in the course of our business relationship for the purposes specified in and within the scope of the cooperation agreements, supply agreements, performance agreements, subcontracting agreements, orders, and other arrangements we have entered into. In connection with the performance of obligations arising from these agreements, we may share or transmit commercial, product, and marketing information, as well as communications regarding the fulfillment of obligations by the parties. As part of these activities, we collect the following personal data from you: first name, last name, job title, company name and address, phone number, and email address.

Your personal data is processed pursuant to Article 6(1)(a) of the GDPR and, to the extent necessary to pursue the controller’s legitimate interests, for the purpose of establishing, exercising, or defending against legal claims, pursuant to Article 6(1)(f) of the GDPR.

Your personal data will be processed for as long as necessary to fulfill the terms of the agreements; to the extent required to comply with legal obligations, for as long as necessary to fulfill those obligations, as well as for as long as necessary to defend against any potential claims.

Personal data processed in connection with public relations and investor relations activities

We process the personal data of journalists, investors, analysts, shareholders, and other individuals associated with the capital markets. We obtain personal data in this area directly from you, from editorial offices, or from entities associated with you. The scope of the data processed may include: first and last name, email address, phone number, affiliation, and editorial office address.

We process this data based on our legitimate interest in providing information about Equilis’s activities, sending current and periodic reports, and managing relationships in accordance with Article 6(1)(f) of the GDPR, as well as on the legal basis of your consent—Article 6(1)(af) of the GDPR.

You may object to the processing of your data for the purposes described above at any time.

If you would like to stay in regular contact with us and receive press releases, current reports, or periodic reports from us, please contact us at the following email address: office.poland@equilis.netPlease send any objections regarding the processing of your personal data for the purposes described in this paragraph, or requests to unsubscribe from our mailing list for the information described above, to the same email address.

Personal information of relatives of individuals holding management positions at Equilis

We process the personal data of close relatives—specifically, individuals holding management positions at Equilis—a requirement arising from applicable capital market regulations. The legal basis for processing this personal data is Article 6(1)(c) of the GDPR. The data is processed for a period of 5 years from the date the list of close relatives and individuals holding management positions at our company was created or updated.

Personal data processed in connection with recruitment for positions at Equilis

We recruit new employees and associates through our website, equilispolska.pl, social media, and selected job boards. The personal data we collect is used exclusively for recruitment purposes; however, if we have obtained your separate consent, your data may be stored for a longer period and used in future recruitment processes for the same or other positions. This period will be defined in the recruitment guidelines on a case-by-case basis or specified individually.

We process your personal data in the above-mentioned scope solely on the basis of consent, i.e., Article 6(1)(a) of the GDPR, as well as—to the extent of a legitimate interest—for the purpose of determining, assert, pursue, or defend against claims, pursuant to Article 6(1)(f) of the GDPR

If you wish to have the information we process deleted earlier, please send your request tooffice.poland@equilis.netor use the contact information provided above.

Personal data processed in connection with the organization of contests

When organizing a contest, we ask that you provide only the personal data that we will process for the purpose of conducting the contest. We specify the scope of this data in the contest rules for each contest. We limit ourselves to collecting your email address, first and last name, and mailing address. We process this data to determine the contest results, contact you to notify you of your prize, and to establish, exercise, or defend against legal claims. The legal basis for processing for the above purposes and to the extent described is Article 6(1)(b) of the GDPR. Providing your personal data is voluntary but necessary to participate in the contest.

After a given contest has ended, we process your personal data in accordance with your consent or on the basis of our legitimate interest for the period necessary to fulfill the purpose of the contest and to defend against any claims that may arise from the course of the contest or in connection with its outcome, that is, pursuant to Article 6(1)(f) of the GDPR.

Personal data processed through social media platforms

Equilis has profiles on websites such as:

• LinkedIn  
• Facebook  
• Instagram  

Our collaboration with social media platforms where we maintain our profiles is based on the terms and conditions set forth by the platform operators—Facebook, Instagram, and LinkedIn. Both the platform owner and Equilis, which maintains its profile on the platform, act as controllers of your personal data. However, please note that Equilis, as the profile owner, is itself a user of the platform and cannot modify the platform’s terms of use or the security measures it employs. Therefore, for complete information regarding the processing of personal data, please refer to the privacy policy of the respective portal (more information on this topic is provided below).

Your personal data is processed through the profiles we maintain on these social media platforms, specifically for advertising, market research, and promotional purposes. Based on this, we inform you about our activities and events organized by Equilis, including investment promotions, contests, etc.

Activity on profiles helps build and maintain communication with us through following profiles, comments, chats, messages, likes, reactions to posts, shares, etc.

We process your data—such as your first and last name/username, image, public profile, and other information provided in messages or comments—based on our legitimate interest, in order to respond to comments and messages, maintain relationships with people who interact with us, and to establish, pursue, or defend against claims, pursuant to Article 6(1)(f) of the GDPR. The basis for processing your personal data is Article 6(1)(a), i.e., your consent implied by following the Equilis profile on social media platforms.

Facebook transfers data outside of Poland, the EU, and the European Economic Area using Facebook’s standard contractual clauses approved by the European Commission and European Commission decisions confirming an adequate level of data protection for specific countries, in accordance with the rules set forth by Facebook athttps://www.facebook.com/about/privacy. Instagram is one ofFacebook’s productsprovided by Facebook Ireland Limited and processes data under the same terms.

According to information obtained from the LinkedIn websitehttps://www.linkedin.com/help/linkedin/answer/62533?trk=microsites-frontend_legal_privacy-policy&lang=pl, LinkedIn’s services—which connect professionals and enable them to take advantage of business opportunities around the world—require the transfer of data between the European Union (EU), the European Economic Area (EEA), and Switzerland, and the United States (U.S.). Personal data is adequately protected during transfers outside the EU; the GDPR requires that such transfers be based on specific legal mechanisms.

Sharing Information About Other People With Us

If you provide us with the personal data of third parties in any scope or form (e.g., as part of contests we organize), you are required to obtain that person’s consent and to comply with all obligations under the GDPR regarding the data provided in this manner. Please ensure that you have obtained the explicit consent of the individual concerned or that you have a legal basis for providing us with information about that person, and please direct those individuals to review and accept our Privacy Policy.

To whom your personal data may be disclosed

• state authorities or other entities authorized by law,
• entities that process personal data on our behalf in order to fulfill our obligations, i.e., our subcontractors, suppliers, and entities providing postal or courier services,
• entities with which we have an ongoing working relationship and which are responsible for Equilis’s IT services and accounting services. These entities operate under data processing agreements and, like us, are obligated to protect personal data.

Transfer of Personal Data Outside the European Economic Area (EEA)

Your personal data is processed exclusively within the EEA, with the exception that only the processing of data on social media platforms may involve the transfer of your personal data to third countries.

If it becomes necessary to transfer personal data outside the EEA, Equilis will implement legal and practical measures to ensure the security and an adequate level of protection for your personal data; in particular, it will take all necessary steps in accordance with applicable regulations—specifically the GDPR—and the rules and guidelines established by the President of the Personal Data Protection Officehttps://uodo.gov.pl/pl/138/665

What rights do you have regarding the processing of your personal data by Equilis?

the right to information regarding the processing of personal data—on this basis, Equilis provides the data subject with information about the processing of their data, including, in particular, the purposes and legal grounds for processing, the scope of the data held, the entities to which the data is disclosed, and the planned date for the deletion of the data;

the right to obtain a copy of the data—on this basis, Equilis provides the individual with a copy of the data being processed that pertains to the person making the request;

right to rectification– Equilis is required to correct any inaccuracies or errors in the personal data it processes and to complete such data if it is incomplete;

the right to erasure– on this basis, an individual may request the erasure of datawhose processing is no longer necessary for any of the purposes for which it was collected;

the right to restrict processing—if such a request is made, Equilis will cease processing personal data—with the exception of processing for which the data subject has given consent – and ceases to store such data, in accordance with the established data deletion policies or until the grounds for restricting data processing no longer apply (e.g., a decision is issued by a supervisory authority authorizing further data processing);

Right to data portability– on this basis – to the extent that the data is processed in connection with a contract or consent – Equilis provides the data supplied by the data subject in a machine-readable format.

It is also possible to request that this data be transferred to another entity—provided, however, that the technical capabilities to do so exist on the part of both Equilis and that other entity;

the right to object to the processing of data for marketing purposes—the data subject may at any time object to the processing of personal data for marketing purposes without having to provide a reason for such objection;

Right to object to other purposes of data processing– the data subject may at any time object to the processing of personal data that is carried out on the basis of a legitimate interest (e.g., for analytical or statistical purposes); such an objection must be supported by a statement of reasons;

the right to withdraw consent– if data is processed on the basis of consent, the data subject has the right to withdraw that consent at any time; however, this does not affect the lawfulness of the processing carried out prior to the withdrawal of consent.

Right to File a Complaint– If a data subject believes that the processing of personal data violates the provisions of the GDPR or other data protection laws, they may file a complaint with the President of the Personal Data Protection Officeat https://uodo.gov.pl/pl/p/skargi

You may submit a request to exercise the above rights in writing to the registered office of SERNILL INVESTMENTS SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ at Aleje Jerozolimskie 93, 02-001 Warsaw, Poland, or via email to:office.poland@equilis.net

We reserve the right to modify this Privacy Policy by publishing a new Privacy Policy on this page.