Privacy and Personal Data Protection Policy

Partners International Sp. z o.o. attaches particular importance to protecting the privacy and security of the personal data of its clients, persons interested in properties, property owners, business partners and users of its website.

This Privacy and Personal Data Protection Policy (the “Policy”) explains how Partners International processes personal data in connection with its business activities, in particular in connection with:

1) the use of the Partners International website;

2) the use of contact forms, property listing forms and property search forms;

3) contact by telephone, by e-mail, via instant messaging services or via social media;

4) searching for, selling, purchasing, renting or letting properties;

5) the provision of brokerage services and the handling of the transaction process;

6) presenting property offers and matching them to clients’ needs;

7) the use of the new-offer notification feature or other services requested by the user;

8) subscribing to the newsletter and receiving commercial or marketing information;

9) contacts established via property listing portals, real estate websites and other online platforms;

10) cooperation between Partners International and developers, other real estate agencies and domestic or foreign partners;

11) the use of Partners International’s social media profiles.

This Policy is informational in nature and fulfils the obligation under Art. 13 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) (“GDPR”).

2. INFORMATION ABOUT THE CONTROLLER AND CONTACT DETAILS

The controller of personal data is Partners International Sp. z o.o., with its registered office in Warsaw, ul. Wiejska 19, 00-480 Warszawa, entered in the Register of Entrepreneurs of the National Court Register under KRS number 0000811650, NIP 5213881240, REGON 384790266 (“Partners International” or the “Controller”).

The Controller may be contacted:

1) in writing – at the address of the Controller’s registered office;

2) by e-mail at: info@partnersinternational.pl;

3) in matters relating to the protection of personal data – as set out in section 3 of the Policy.

3. DATA PROTECTION OFFICER

The Controller has appointed a Data Protection Officer. In matters relating to the protection of personal data, you may make contact at the following address: iod@partnersinternational.pl

The following may in particular be sent to the above address:

1) questions concerning the manner in which personal data are processed;

2) requests to exercise rights under the GDPR;

3) objections to the processing of data;

4) notices of withdrawal of consent;

5) questions concerning the source from which the data were obtained;

6) questions concerning the recipients of data or transfers of data outside the European Economic Area;

7) reports concerning privacy or the security of personal data.

4. SCOPE AND PURPOSES OF PERSONAL DATA PROCESSING

4.0. Is the provision of data mandatory?

The provision of data is, as a rule, voluntary. Certain data may be necessary in order to:

1) respond to an enquiry;

2) make contact regarding a property;

3) perform a requested service;

4) take steps prior to entering into a contract;

5) enter into or perform a contract;

6) comply with a specific legal obligation.

Failure to provide the data necessary for a particular process may make it impossible to carry out that process. Giving consent to marketing or to receiving commercial information is not a condition for submitting an enquiry to Partners International or for using its brokerage services.

4.1. Handling enquiries and contact with Partners International

Where a person contacts Partners International, the Controller may process that person’s data for the purpose of:

1) responding to a question;

2) handling the message sent;

3) putting the person in contact with the appropriate agent or branch;

4) establishing the person’s area of interest;

5) conducting further correspondence concerning the matter raised.

For this purpose, the Controller may process identification data, including first name and surname, contact details, including e-mail address, telephone number and correspondence address, as well as data concerning the course of contact with Partners International, including the history of correspondence, conversations, arrangements, offers presented and preferences communicated to the agent.

The data may originate from a telephone conversation or meeting, an e-mail message, an online form, correspondence conducted via social media or instant messaging services, and from operators of property listing portals and real estate websites.

Data may also be received via real estate portals, listing websites and other online platforms where a person has sent an enquiry concerning a specific Partners International offer, requested contact with an agent, submitted a contact form addressed to Partners International or otherwise initiated contact concerning Partners International’s properties or services. In such a case, Partners International processes the data received as a controller for the purposes of its own handling of the enquiry, the client or the transaction. The operator of the portal or platform may at the same time process the data as a separate controller for its own purposes, in accordance with its own privacy policy.

The mere transfer of data via a portal or platform does not mean that the data will automatically be used for direct marketing through any communication channel.

We process the data provided in the contact form in order to handle your enquiry, respond to it and conduct further correspondence concerning the matter raised. The legal basis for the processing is Art. 6(1)(f) GDPR — our legitimate interest in handling persons who contact us — or Art. 6(1)(b) GDPR where the contact serves to take steps at your request prior to entering into a contract.

4.2. Property search and matching of offers

Data may be processed for the purpose of:

1) establishing the criteria for the property sought;

2) selecting offers that match the stated preferences;

3) presenting property offers;

4) making contact regarding offers that match previously specified criteria;

5) arranging property viewings;

6) conducting arrangements concerning a potential transaction.

The scope of the data processed may include contact details, information concerning the property sought, including the preferred location, type of property, floor area, standard, price range, budget, expected transaction date and other stated preferences, as well as data concerning the course of contact with Partners International, including offers presented and preferences communicated to the agent.

The data may originate from a property search request, a telephone conversation or meeting, an e-mail message, an online form, property listing portals and real estate websites, as well as from developers, other real estate agencies, brokers or partners cooperating with Partners International.

In handling a specific matter, Partners International may cooperate in particular with developers, other real estate agencies, brokers, property owners or managers and other entities involved in the preparation or handling of a transaction. Data are shared only to the extent necessary to handle the specific matter, consistent with the person’s expectations or resulting from another appropriate legal basis.

The basis for the processing is Art. 6(1)(b) GDPR, where steps are taken at the person’s request in connection with a property search or the preparation of a transaction, or Art. 6(1)(f) GDPR as regards organising and ensuring continuity of customer service and managing the history of the matter.

4.3. Listing a property for sale or rent

The data of an owner, landlord or person representing the owner may be processed for the purpose of:

1) assessing the possibility of establishing cooperation;

2) making contact regarding the listed property;

3) preparing an offer for the provision of services;

4) entering into and performing a contract;

5) preparing and presenting the property offer;

6) making contact with persons interested in the property;

7) handling the sale or letting process.

For this purpose, the Controller may process identification and contact data, information concerning the property listed for sale or rent, information concerning legal title to the property, the manner of representation or authority to act on behalf of another person, as well as data necessary to enter into and perform the contract and to settle the services provided.

The data may originate from the property listing, a telephone conversation or meeting, an e-mail message, an online form, as well as from attorneys, representatives or other persons involved in the matter.

The basis for the processing is Art. 6(1)(b) GDPR and, to the relevant extent, Art. 6(1)(f) GDPR.

4.4. Conclusion and performance of contracts and handling of transactions

Partners International processes data to the extent necessary to enter into and perform contracts and to handle the services provided. The basis for the processing is Art. 6(1)(b) GDPR.

Where representatives, attorneys, employees or other persons acting on behalf of a party to the contract are involved in the process, their data may be processed on the basis of Art. 6(1)(f) GDPR. The Controller’s legitimate interest is the proper performance of the contractual relationship and the ability to contact the persons involved in its performance.

The scope of the data processed may include data necessary to enter into and perform the contract and to settle the services provided, identification and contact data, information concerning legal title to the property, the manner of representation or authority to act on behalf of another person, as well as data concerning the course of contact and the arrangements made.

The data may originate from the conclusion or performance of a contract, a property listing or a property search request, as well as from clients, business partners, attorneys, representatives or other persons involved in the matter.

In connection with the execution of a transaction, data may be shared with entities involved in its preparation or handling, including developers, other real estate agencies, brokers, property owners or managers, business partners and other partners of Partners International in Poland or abroad — solely to the extent necessary to achieve the specified purpose.

Where a partner receives data as a separate controller for the purposes of its own process, Partners International provides information about that recipient or category of recipients in accordance with the requirements of the GDPR. Where the transfer of data to a specified developer or partner for its own purposes requires the person’s consent, information about such transfer and the consent are presented when the data are collected.

4.5. Customer relationship and case history management

Partners International may keep a history of contacts, arrangements, properties presented and information provided by the client for the purpose of:

1) ensuring continuity of service;

2) enabling the matter to be handled by the appropriate agent or team;

3) reducing the risk of conflicting or repeated information being provided;

4) documenting the course of cooperation;

5) improving the quality of service.

For this purpose, the Controller may process data concerning the course of contact with Partners International, including the history of correspondence, conversations, arrangements, offers presented and preferences communicated to the agent, information concerning the source from which the data were obtained and information about consents given, their scope and the date on which they were given, as well as about the withdrawal of consent or the lodging of an objection.

The data may originate from a newsletter subscription or notification request, an online form, an e-mail message, a telephone conversation or meeting.

The basis for the processing is Art. 6(1)(f) GDPR. The Controller’s legitimate interest is the efficient management of the customer relationship and ensuring the proper organisation of the services provided.

4.6. Notifications of properties and offers matching specified criteria

Where a user requests a service notifying them of new properties or offers matching criteria specified by them, the data are processed for the purpose of providing that service.

The scope of the data processed may include contact details, information concerning the property sought, the specified criteria and preferences, as well as information concerning consents given, their scope and the date on which they were given, and the withdrawal of consent or the lodging of an objection.

The basis for the processing is Art. 6(1)(b) GDPR.

Communications going beyond the scope of the requested service and constituting commercial information or direct marketing may be sent via terminal equipment only in accordance with the rules laid down in the Polish Electronic Communications Law.

4.7. Newsletter and commercial information

The data of persons subscribing to the newsletter or requesting other information may be processed for the purpose of sending:

1) information concerning properties and the property market;

2) selected or similar offers from the Partners International portfolio;

3) information about new developments;

4) editorial and industry content;

5) information concerning the services of Partners International,

6) information about a change in the price of a followed offer.

The data may originate from a newsletter subscription or notification request, an online form, an e-mail message, a telephone conversation or meeting. The Controller may process contact details, including e-mail address and telephone number, and information concerning consents given, their scope and the date on which they were given, as well as the withdrawal of consent or the lodging of an objection.

Where the processing of data for this purpose is based on consent, the basis for the processing is Art. 6(1)(a) GDPR. Consent is entirely voluntary and is not a condition for using our brokerage services.

The use of an electronic address, telephone number or other telecommunications terminal equipment to send commercial information, including direct marketing, takes place in accordance with Art. 398 of the Electronic Communications Law. Consent may be withdrawn at any time. The withdrawal of consent does not affect the lawfulness of actions taken before its withdrawal.

4.8. Marketing of our own services

Partners International may process personal data for the purpose of marketing its own services on the basis of Art. 6(1)(f) GDPR.

The Controller’s legitimate interest is the promotion of its own services, the analysis of the effectiveness of the actions taken and the adaptation of the manner of communication to the nature of the relationship with the client.

The basis under Art. 6(1)(f) GDPR alone does not replace the consent required under Art. 398 of the Electronic Communications Law where an electronic address, telephone number or other telecommunications terminal equipment is used for marketing purposes. In the case of direct marketing carried out by means of electronic communication (e-mail, telephone, SMS), the basis for the processing is the user’s voluntary consent, expressed by ticking the relevant box in the form. The user has full control over the communication channels to which they consent and may freely modify or withdraw such consent.

A person may at any time object to the processing of their data for direct marketing purposes.

Data may be obtained directly from the data subject, from an online form, an e-mail message, a telephone conversation or meeting, from social media or instant messaging services, and from publicly available sources – to the extent justified by the purpose of the processing and the existing legal basis.

The scope of the data processed may include identification and contact data, data concerning the course of contact with Partners International, including the history of correspondence, conversations, arrangements and preferences communicated to the agent, as well as information concerning consents given and objections lodged.

4.9. Compliance with legal obligations

Partners International may process data in order to comply with obligations arising from legal provisions, including documentation, accounting and tax obligations and obligations relating to the provision of information to competent authorities.

The basis for the processing is Art. 6(1)(c) GDPR.

Data may be obtained directly from the data subject in connection with the conclusion or performance of a contract, from clients, business partners, attorneys, representatives or other persons involved in the matter, as well as from publicly available registers and other publicly available sources.

The scope of the data processed is in each case determined by the obligation applicable to the particular process or transaction and may include data necessary to maintain documentation, for accounting and tax settlements and for the provision of information to competent authorities

4.10. Establishment, exercise and defence of legal claims

Partners International may store and process data for the purpose of:

1) establishing the existence of a claim;

2) pursuing claims due;

3) defending against claims;

4) preserving evidence concerning the course of cooperation or communication.

The basis for the processing is Art. 6(1)(f) GDPR. The Controller’s legitimate interest is the protection of its rights and the ability to demonstrate the course and content of the relationship with the data subject.

The data may originate from the conclusion or performance of a contract, correspondence conducted, a telephone conversation or meeting, an online form, as well as from attorneys, representatives or other persons involved in the matter.

For this purpose, the Controller may process data concerning the course of contact with Partners International, including the history of correspondence, conversations and arrangements, data necessary to enter into and perform the contract and to settle the services provided, as well as evidence concerning the course of cooperation or communication

4.11. Security of the website and systems

Technical data may be processed for the purpose of:

1) ensuring the security of the website and systems;

2) detecting errors, abuse or attempts at unauthorised access;

3) conducting analyses of technical incidents;

4) ensuring the continuity of services.

The basis for the processing of personal data is Art. 6(1)(f) GDPR. The Controller’s legitimate interest is the protection of the website, information and systems used in the business of Partners International.

The source of the data is the website, the technologies used and the user’s settings.

The scope of the data processed may include technical data and information concerning the use of the website, to the extent resulting from the technologies used and the user’s settings, as well as information concerning errors, abuse, attempts at unauthorised access and technical incidents.

4.12. Social media

Where a person contacts Partners International via a profile maintained on a social networking site, their data may be processed for the purpose of handling the message, comment or other interaction.

The basis for the processing by Partners International is Art. 6(1)(f) GDPR and, in the case of steps taken at the person’s request with a view to entering into a contract – Art. 6(1)(b) GDPR.

The operator of the given social networking site may independently process personal data in accordance with its own rules and privacy policy.

The source of the data may be correspondence conducted via social media or instant messaging services and the profile maintained on the social networking site.

The Controller may process identification and contact data, data concerning the message, comment or other interaction, as well as data concerning the course of contact with Partners International. The operator of the given social networking site may independently process personal data in accordance with its own rules and privacy policy

4.13. Analytics and service quality improvement

Partners International may use data to prepare internal analyses concerning the manner in which clients are served, the organisation of processes and the quality of the services provided.

Wherever possible, analyses are carried out on aggregated data or using data to an extent that limits the possibility of identifying specific individuals.

The basis for the processing of personal data, where such data are used, is Art. 6(1)(f) GDPR.

The data may originate from the history of contacts, arrangements, properties presented and information provided by the client, as well as from a telephone conversation or meeting, an e-mail message, an online form and the conclusion or performance of a contract.

The scope of the data processed may include information concerning the manner in which clients are served, the organisation of processes and the quality of the services provided, as well as data concerning the course of contact with Partners International. Wherever possible, analyses are carried out on aggregated data or on data to an extent that limits the possibility of identifying specific individuals

5. RECIPIENTS OF DATA

Personal data may be shared with or entrusted to entities whose involvement is necessary to carry out a particular process. The categories of recipients of data may include:

1) entities providing hosting, website maintenance and IT infrastructure;

2) providers of cloud services, CRM systems, tools for sending electronic communications and tools used for customer service, as well as tools using artificial intelligence;

3) providers of e-mail, communication and newsletter distribution services;

4) entities providing accounting, legal, audit or advisory services;

5) entities supporting Partners International in carrying out marketing activities, where they process data in this respect in accordance with the Controller’s instructions;

6) developers, other real estate agencies, brokers and partners involved in handling a specific matter;

7) owners, landlords or other parties to a potential transaction, where the transfer of certain data is necessary for its conduct;

8) notaries or other professional advisers involved in the transaction process, where their involvement results from the nature of the matter or the expectations of a party;

9) foreign partners involved in handling an enquiry concerning a property abroad;

10) public authorities and other entities entitled to receive data under legal provisions.

Depending on the nature of the cooperation, a recipient may act as a processor processing data on behalf of Partners International or as a separate controller.

If you give separate consent, we may make a one-off transfer of your data to a selected business partner, who will process them as an independent controller for the purpose of contacting you, providing information about its services and preparing an individual offer. Such partners may include in particular: Moovin Interiors, Deer Design and Wyższa Kultura Budownictwa.

6. TRANSFERS OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

Partners International verifies whether the use of the services of particular providers or cooperation with a foreign partner involves the transfer of personal data outside the European Economic Area. Where such a transfer takes place as part of a particular process, the Controller ensures that it takes place solely on the basis of and using a mechanism permitted under Chapter V GDPR, in particular a European Commission decision finding an adequate level of protection, appropriate safeguards provided for in Art. 46 GDPR or a derogation provided for in Art. 49 GDPR. Art. 46 GDPR concerns transfers subject to appropriate safeguards, whereas Art. 49 GDPR sets out derogations for specific situations.

Information concerning a specific transfer and the safeguards applied, as well as the means of obtaining a copy of them, can be obtained by contacting iod@partnersinternational.pl.

7. HOW LONG WE STORE DATA

Personal data are stored for no longer than is necessary for the purposes for which they were obtained, unless an obligation to continue storing them arises from legal provisions or further storage is necessary for the establishment, exercise or defence of legal claims.

Data relating to an enquiry are stored for the period necessary to handle it and to maintain further contact concerning the matter.

Where contact leads to the conclusion of a contract or the commencement of handling a transaction, the data are stored for the duration of the cooperation and thereafter for the period resulting from legal obligations and the period necessary to secure claims.

Data processed on the basis of consent are processed until consent is withdrawn or the purpose of the processing ceases to exist earlier. After consent has been withdrawn, the Controller may retain the data necessary to demonstrate the fact and scope of the consent previously given, to record its withdrawal and to defend against any claims – for a period justified by the accountability principle and the applicable limitation periods for claims.

Data processed for direct marketing purposes on the basis of legitimate interest are processed until an objection is lodged or the purpose of their processing ceases to exist.

Data concerning the withdrawal of consent or an objection may be retained to the extent necessary to ensure that the person concerned is not again included in communications to which they have effectively objected or for which they have withdrawn consent.

Data obtained from other sources, where no relationship or further contact has been established, are stored only for a limited period necessary to assess the possibility of establishing a relationship or achieving the purpose for which they were obtained. Once the purpose ceases to exist, the data are erased or anonymised, or their further processing takes place only where another legal basis exists.

Technical data and system logs are stored for a period justified by the need to ensure security, analyse incidents and ensure the proper functioning of systems.

Detailed retention periods are determined by the Controller for individual processing operations, taking into account the nature of the data, the purpose of the processing, legal obligations and the risk to the rights and freedoms of individuals.

8. RIGHTS OF DATA SUBJECTS

You have the right to:

1) access your personal data,

2) rectification of your personal data,

3) correction of your personal data,

4) restriction of the processing of your personal data,

5) erasure of your personal data,

6) portability of your personal data [applies to data processed on the basis of Art. 6(1)(a) GDPR (on the basis of your consent) and on the basis of Art. 6(1)(b) GDPR (data processed for the performance of a contract between you and the Controller and for taking steps at your request prior to entering into the Contract)]

7) object, at any time, to the processing of personal data by the Controller where:

– the processing is carried out for direct marketing purposes – if you exercise this right, we will immediately stop processing your personal data for that purpose,

– the processing is carried out for the purposes of the legitimate interests pursued by the Controller – if you exercise this right, we will immediately stop processing your personal data unless the Controller is able to demonstrate compelling legitimate grounds for further processing which override the interests, rights or freedoms you have indicated.

In addition, where personal data are processed on the basis of consent, you may withdraw your consent to the processing of personal data. Consent may be withdrawn at any time, without affecting the processing operations carried out before the consent was withdrawn.

In order to exercise the rights referred to above, you may contact the Controller by e-mail at iod@partnersinternational.pl.

The user also has the right to lodge a complaint with the supervisory authority (President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stanisława Moniuszki 1A, 00-014 Warszawa) if they consider that the processing of data by the Controller infringes the applicable law, in particular the provisions of the GDPR.

9. OFFER MATCHING, SEGMENTATION AND AUTOMATED DECISION-MAKING

Partners International may use the information on property preferences provided by a person in order to organise its contact database, match offers and present properties that meet the specified criteria.

This process may take into account in particular such information as location, type of property, floor area, standard, price range or other preferences provided by the person.

We may analyse the criteria you provide, such as location, type of property, floor area, standard and budget, in order to present offers better suited to your interests. Profiling does not automatically determine the provision of a service, the conclusion of a contract or a refusal of service.

10. COOKIES AND SIMILAR TECHNOLOGIES

The Partners International website may use cookies and other similar technologies.

These technologies may be used in particular to:

1) ensure the proper and secure operation of the website;

2) remember selected user settings;

3) carry out analyses of the use of the website;

4) measure the effectiveness of activities conducted via the website;

5) perform marketing functions – where the user has given the required consent.

The storage of information, or the gaining of access to information already stored, in the user’s device takes place in accordance with Art. 399 of the Electronic Communications Law.

Technologies that are not necessary for the transmission of an electronic communication or for the provision of a service explicitly requested by the user are used after the required consent has been obtained.

The user should be able to manage consents for individual categories of technologies via the cookie settings made available on the website.

Detailed information about the technologies used, their providers, purposes and duration is set out in the Cookie Policy.

11. DATA SECURITY

Partners International applies technical and organisational measures appropriate to the nature of the data processed and the risk identified.

Access to personal data is limited to persons who need it in connection with the tasks they perform and who hold appropriate authorisation or another basis for access.

The Controller takes measures aimed at protecting data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

The Controller’s detailed security arrangements and internal procedures are not published where their disclosure could reduce the effectiveness of the safeguards applied.

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