PRIVACY POLICY – HOW WE PROCESS AND PROTECT YOUR PERSONAL DATA

In connection with the entry into force on 25 May 2018 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, and in accordance with Article 13(1) and (2) 2 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 (General Data Protection Regulation) (OJ EU L 2016.119.1) (hereinafter referred to as „GDPR”), we hereby inform you that:

I. Who is the controller of your data?
The administrator of your personal data is KUDOWA PROPERTY INVESTMENT Limited Liability Company and Kudowa Development Limited Liability Company with its registered office in Kudowa-Zdrój (hereinafter referred to as the „Personal Data Administrator” or „PDA”).
You can contact the person who can provide information about your personal data by e-mail: biuro@kapitalnieruchomosci.pl or by telephone: +48 575 739 839.

II. Basis for processing personal data:
ADO processes your personal data because it is necessary for the performance of contracts with you or the provision of services to you within the scope of ADO's activities. If your personal data is needed for other purposes, your consent to its processing is required.

Your personal data will be processed on the following grounds:

a) the consent you have given for one or more specific purposes;


b) when it is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;

c) when it is necessary to fulfil a legal obligation incumbent on us (in particular, tax and accounting obligations, obligations related to counteracting money laundering and terrorist financing);

d) when it is necessary for purposes arising from legitimate interests pursued by us, unless your interests or fundamental rights and freedoms override those interests; such interests include direct marketing, ensuring the security and integrity of data in our IT systems, as well as pursuing or defending against any claims.

III. Why we process your data

a) taking action at your request prior to entering into a contract, as well as providing information and services related to enquiries and contracts;


b) concluding a contract and fulfilling its terms and conditions, in particular for the purpose of providing real estate services;

c) performing financial settlements;


d) fulfil our legal obligations, in particular those relating to taxation and accounting, as well as those relating to the prevention of money laundering and terrorist financing;


e) pursuing our legitimate interests, in particular conducting marketing activities, pursuing and defending claims, preventing fraud, ensuring the authenticity, integrity and confidentiality of the personal data processed;
f) direct marketing of our products and services.

Furthermore, if you have consented to the processing of your personal data, in particular for the purpose of:

g) sending marketing and commercial information, in particular regarding real estate purchase offers, by means of electronic communication and/or using telecommunications terminal equipment and automatic calling systems, through communication by telephone and SMS/MMS messages to the telephone number you have provided;


h) marketing products and services of other partners, in particular by informing you about news and property purchase offers, analysing your personal preferences, activities and interests in order to present the most relevant content and offers (profiling), including creating your profile;

IV. Processing time
Your personal data processed by us is deleted when the purposes for processing cease to exist.

V. What is the source of the data?
Personal data is provided directly by the data subject. We may have received it when you submitted an enquiry using: a contact form, an email sent to the ADO address, or a telephone conversation. If personal data is obtained indirectly from the data subject, we will inform you of the source of the data.

VI. How do we ensure the security of your data?
Please be advised that ADO has implemented appropriate technical and organisational measures to ensure the security of personal data processing.

VII. Who can we entrust your data to?
ADO may cooperate with external partners to perform services on our behalf, such as providing notarial, accounting, legal, architectural, design, construction project implementation, marketing assistance, press release administration, data or statistics analysis, and IT services. This means that our partners will have access to your personal data. We may also disclose your personal data to third-party public authorities if we are required to do so by law or by a decision of a public authority.
Please be advised that we do not transfer your personal data to third countries or international organisations.

VIII. How do we use cookies?
ADO uses cookies on its website. These are text files that facilitate navigation on the website. They are used to improve user comfort, compile statistics on the number of visitors to the website and information on how it is used. Cookies are sometimes used to collect data considered personal, such as IP addresses and related data, but they cannot be considered data assigned to you as a natural person. If you do not accept the use of cookies, you can set your web browser to automatically reject the storage of cookies or to inform you each time a website requests to store a cookie. You can also delete previously stored cookies using your web browser. However, this will reduce the functionality of the website.

IX. Your rights regarding the processing of personal data:
a) You have the right to request access to your personal data and the right to request its rectification, deletion, restriction of processing, as well as the right to transfer data and the right to object.

b) You have the right to lodge a complaint with the competent supervisory authority for personal data protection: the President of the Personal Data Protection Office.


c) if data processing is based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of the processing that was carried out on the basis of your consent prior to its withdrawal.

d) Providing your personal data is voluntary, but failure to do so will result in the inability to conclude and perform the contract, provide services, or fulfil other purposes for which we collect your data.