PRIVACY POLICY and COOKIES POLICY of ED Invest S.A.

 

§ 1 DEFINITIONS

Administrator – ED INVEST S.A. with its registered office in Warsaw (03-840), Grochowska Street 306/308, entered in the register of entrepreneurs kept by the District Court for the Capital City of Warsaw, XIV Commercial Department of the National Court Register, KRS No.: 0000321820, REGON: 01282003000000, NIP: 525-19-68-486, with share capital of PLN 619,334.35 fully paid up, e-mail biuro@edinvest.pl.

Personal data – information about an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, by one or more specific factors that determine physical, physiological, genetic, mental, economic, cultural or social identity, including device IP, location data, Internet identifier and information collected through cookies and other similar technology.

RODO – Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC.

Policy – this Privacy and Cookies Policy.

User – any individual visiting the Service or using one or more services or functionalities described in this Policy, as well as any individual whose personal data is processed by the Administrator, e.g. being an Administrator’s client, performing duties for an Administrator’s contractor, visiting the Administrator’s premises or directing an e-mail inquiry to the Administrator.

Service – the Internet service operated by the Administrator at https://www.edinvest.pl/, https://edinvest.pl/, https://www.ri.edinvest.pl/ and https://ri.edinvest.pl/

§ 2 INTRODUCTION

The Privacy Policy applies to data processing by the Administrator, including in connection with the operation of the Service and to data via the Service, by telephone, e-mail or in person at the Administrator’s premises.

In connection with the Administrator’s business activities and the User’s use of the Website, the Administrator collects data to the extent necessary to provide the individual services offered, as well as information about the User’s activity on the Website. Detailed principles and purposes of processing Personal Data are described below.

 

§ 3 PERSONAL DATA ADMINISTRATOR

The Administrator of the personal data is ED INVEST S.A. with its registered office in Warsaw (03-840), Grochowska Street 306/308, which can be contacted by writing to the mailing address indicated above or by e-mail: biuro@edinvest.pl (hereinafter referred to as the Administrator).

 

§ 4 LEGAL BASIS, PURPOSE AND PERIOD OF PROCESSING PERSONAL DATA, VOLUNTARINESS OF PROVIDING DATA

The Administrator processes Users’ personal data for the following purposes, based on the legal basis indicated below:

Respond to an inquiry related to our business

If you contact us by email, call us or use contact forms to arrange a presentation, meeting, get more information about our offer, we process your personal data on the basis of the administrator’s legitimate interest from Article 6(1)(f) of the RODO, which we consider to be answering an inquiry, maintaining a conversation, providing information. We store the data processed for contact purposes for the time necessary to complete the contact/answer questions/send the requested material, and then until the end of the calendar year following the year in which the matter was resolved or the contact was terminated. We keep correspondence for such a period of time for the purposes of evidence, securing or defending against claims, which is our legitimate interest referred to in Article 6(1)(f) of the RODO.

Provision of data is voluntary, nevertheless, failure to do so will result in our inability to fulfill the purposes of responding to your inquiry, etc.

Conclusion and performance of a contract in connection with our business/processing of personal data of contractors/customers, representatives of contractors/customers

If you are our client or customer and enter into a contract with us, we process the personal data necessary for this purpose in order to conclude and perform this contract, i.e. on the basis of Article 6(1)(b) of the RODO. In addition, we process contract-related personal data for tax and accounting purposes, in which case the legal basis is Article 6(1)(c) of the RODO in conjunction with the Accounting Act of September 29, 1994, the Tax Ordinance Act of August 29, 1997, and the Value Added Tax Act of March 11, 2004.

If you are a representative or contact person acting on behalf of our client or customer, we process your personal data for the purpose of business contact, which is our legitimate interest (Article 6(1)(f) RODO). Business contact for us is all correspondence (electronic, paper), as well as telephone contact regarding the concluded cooperation and the performed service, in particular: making arrangements, arranging business meetings, answering questions, directing information from our side.

Personal data obtained for accounting and tax purposes will be processed for 5 years calculated from the end of the fiscal year in which the accounting document was issued. Data processed for contact purposes will be kept for the time necessary for the fulfillment of the contact, and then until the end of the calendar year following the year in which the contract was terminated, unless circumstances arise that make it necessary for us to process the data longer, such as a dispute between the parties to the contract. The data necessary for the execution of the contract/consideration of a complaint are processed for the time necessary for its execution, and then until the statute of limitations for mutual claims that may arise from the conclusion of the contract.

Provision of the aforementioned personal data is necessary for the conclusion and execution of the contract. Failure to provide data will result in our inability to either execute the contract or contact you. Provision of data processed for tax and accounting purposes is mandatory, otherwise we will not be able to fulfill our legal obligations.

Correspondence through a form from the website, by email and traditional mail, and telephone contact

We process data for the purposes of conducting ongoing contact, holding discussions, responding to sent inquiries, providing information – on the basis of Article 6(1)(f) RODO – which should be understood as the realization of the Administrator’s legitimate interest.

We store the data processed for contact purposes for the time necessary for the realization of the contact/response to inquiries/sending the ordered material, and then until the end of the calendar year following the year in which the matter was resolved or the contact was terminated. We keep correspondence for such a period of time for the purposes of evidence, securing or defending against claims, which is our legitimate interest referred to in Article 6(1)(f) of the RODO.

Providing personal data for the aforementioned purposes is fully voluntary. Failure to provide data will prevent us from ongoing contact and answering your question. 

Collection of data within the framework of business contacts

In connection with its business activities, the Administrator collects personal data, e.g. during business meetings or through the exchange of business cards, via LinkedIn, GoldenLine, etc. – for purposes related to initiating and maintaining business contacts. Such personal data is processed in order to realize the legitimate interest of the Administrator and its contractor from Article 6(1)(f) of the RODO, consisting of networking in connection with business activities. We process the data for the duration of the Administrator’s legitimate interest, unless you object to the processing of the data beforehand.

Providing personal data for the above purposes is fully voluntary. Failure to provide data will prevent us from ongoing contact.

Handling of complaints

We process personal data processed in connection with a complaint on the basis of Article 6(1)(f) of the RODO, which is the realization of our legitimate interest to duly consider and handle claims. If special category personal data is provided in the claim then we will process this data on the basis of Article 9(2)(f) of the RODO. We will process this data until the claim is processed and the time necessary after the claim process is completed for evidentiary purposes.

Providing the data is necessary for the complaint process. Failure to provide the data will prevent us from processing the complaint.

Sending commercial/marketing information

In the case of consent to receive marketing/trade information from the Administrator via e-mail and/or telephone, personal data is processed for the purpose of providing the aforementioned information.  The legal basis for processing personal data is consent under Article 6(1)(a) of the RODO in connection with Article 10 of the Act on Providing Services by Electronic Means and Article 172 et seq. of the Telecommunications Act with respect to certain forms of contact, and the legitimate interest of the Administrator under Article 6(1)(f) of the RODO in connection with conducting direct marketing. If personal data are processed for the purposes of direct marketing, the data subject has the right to object at any time to the processing of personal data concerning him or her for such marketing, to the extent that the processing is related to such direct marketing. We process data processed on the basis of consent until the consent is withdrawn. Consent may be withdrawn at any time by writing to the email address indicated in § 3 above. Withdrawal of consent does not affect the lawfulness of the processing performed on the basis of consent before its withdrawal. We process data related to the aforementioned purpose until you object to the processing or withdraw your consent as mentioned above.

Provision of data is voluntary, failure to provide data will prevent us from sending marketing messages, which will lead to lack of knowledge of our latest offers, promotional, marketing actions. 

Sending a newsletter

With regard to newsletter subscribers, we process data on the basis of Article 6(1)(a) of the RODO (consent of the data subject) in conjunction with Article 10 of the Act on Provision of Electronic Services for the purpose of sending commercial information related to the Administrator’s activities by electronic means. We process the data until the consent is withdrawn. Withdrawal of consent does not affect the lawfulness of processing that was performed on the basis of consent before its withdrawal

Provision of data is fully voluntary. Failure to provide data will prevent us from sending newsletters and you from learning more about our business activities.

Social media profiles

The Administrator maintains its social media profiles (Facebook, Instagram, LinkedIn, X) and in this respect is a joint controller of personal data with the entities managing these portals (respectively: Meta Platforms Inc., Meta Platforms Inc., LinkedIn Corporation, X Corp.). The data is processed exclusively in connection with the operation of the profile, including for the purpose of informing users about the Administrator’s activities and promoting various events, products, as well as for the purpose of communicating with the user through the available social media functionalities (comment, message, chat, invitation, response). The legal basis for the Administrator’s processing of personal data for this purpose is its legitimate interest (Article 6(1)(f) RODO), which is to promote its own brand.

The data will be processed until an objection is raised.

Provision of data is voluntary, but refusal to provide it prevents you from following our profiles, adding reactions, commenting or sending messages.

Defense of claims

When such a need arises, we may process personal data for the purposes of investigating, establishing claims or defending against claims – on the basis of Article 6(1)(f) of the RODO – which should be understood as the realization of the Administrator’s legitimate interest in asserting one’s property or non-property rights, or protecting against claims directed against the Administrator – until the expiration of the statute of limitations for possible claims, and in the case of the initiation of proceedings, until their legal conclusion.

Provision of data is necessary, failure to provide data will prevent us from fulfilling our legitimate interest.

Cookie

We process personal data obtained as a result of the operation of a cookie on the basis of the administrator’s legitimate interest under Article 6(1)(f) of the RODO, which we consider to be the need to receive our website, the desire to properly display the site to the user, or to control the number of people who visit the site. We process data on the basis of the legitimate interests of the controller in connection with which you have the right to object to the processing of your personal data, about which more in § 7 of the Privacy Policy (here also more information on other rights) and/or contact our Data Protection Officer at the e-mail address indicated in § 3 of the Privacy Policy. We process data for the duration of the administrator’s legitimate interest, but no longer than until you object to the processing. Provision of data is fully voluntary, failure to provide data will not result in negative consequences.

At the beginning of your visit to our website, you are asked for your consent to install cookies on your device under Article 173 of the Telecommunications Law, other than those necessary for the operation of the website. Consent can be withdrawn at any time without affecting the processing of data that occurred before its withdrawal. In order to exercise your rights, please contact our Data Protection Officer at the e-mail address indicated in § 3 of the Privacy Policy. Provision of data is fully voluntary, failure to provide data will not result in negative consequences.

Fulfillment of legal obligations, including obligations from RODO

We have an obligation to fulfill the obligations indicated in the RODO, i.e., among others, the creation of records and registers related to the RODO. We process your personal data in this case on the basis of Article 6(1)(c) of the RODO in connection with a legal obligation incumbent upon us, and Article 6(1)(f) of the RODO, i.e. on the basis of the controller’s legitimate interest.

§ 5 SOURCES OF DATA

We collect data directly from you if you call us or correspond with us by email or traditional mail, or leave it in another form (e.g., a business card handed to you, a completed form, an online store purchase). We may also obtain your data from companies with which we cooperate and which indicate you as a representative or appropriate contact person. The data we receive in such a case is your business contact information, or that contained in the power of attorney or copy of the National Court Register, if you are a representative person.

§ 6 RECIPIENTS OF DATA

We will transfer your personal data to entities that process data under a contract with us and only in accordance with our instructions, i.e.

courier and postal service companies,

operators of payment systems,

accounting firm for accounting purposes and settlement of the concluded cooperation agreement,

law firm, if necessary for the defense of our claims,

companies providing hosting services to us, providing or maintaining IT systems, companies providing data protection services.

In addition, we will transfer personal data to relevant state and/or public institutions if necessary to comply with legal obligations.

Personal data may also be shared with entities that are part of our capital group, if the matter in question relates to activities carried out by the designated company, which is a legitimate interest of ED Invest S.A.. These entities, once shared, become administrators of your personal data and process it on the same basis as ED Invest S.A.. The ED Invest group of companies includes:

Project View Sp. z o.o. (KRS number 306785, 306/308 Grochowska St., 03-840 Warsaw),

Radzikowskiego APV Sp. z o.o. (KRS number 845979, 306/308 Grochowska St., 03-840 Warsaw),

SOEDI 1 Sp. z o.o. (KRS number 1011220, 306/308 Grochowska St., 03-840 Warsaw),

SOEDI 2 Sp. z o.o. (KRS number 0001030203, Grochowska Street 306/308, 03-840 Warsaw),

SOEDI 3 Sp. z o. o., (KRS number 0001062304, ul. Grochowska 306/308, 03-840 Warsaw),

SOEDI 4 Sp. z o. o., (KRS number 0001098018, ul. Grochowska 306/308, 03-840 Warsaw),

SOEDI 5 Sp. z o. o., (KRS number 0001098732, ul. Grochowska 306/308, 03-840 Warsaw).

The recipients of cookies may be external entities that provide them.

Data recipients may also be entities authorized under the law. We use Microsoft services (e.g. e-mail), but the data is processed by servers located in the EEA and, as a rule, we do not transfer data outside the EEA.

§ 7 TRUSTED PARTNERS

If you agree, your personal information may be shared with our Trusted Partners – entities with whom we work to market and sell our products.

The current list of these entities is:

ECC REAL ESTATE SP. Z O.O. POLAND, 37/2.43 Domaniewska St., 02-672 Warsaw,

Private House Brokers Angel Wawel, ul. Sukiennicza 8/U8, 31-069 Kraków.

§ 8 RIGHTS OF DATA SUBJECTS

In connection with the processing of personal data, the User has the following rights:

The right to access their personal data (Article 15 RODO), including obtaining a copy of the data (Article 15(3) RODO),

The right to rectify (correct) or complete incomplete personal data (Article 16 RODO),

The right to request erasure of personal data in cases provided by law (Article 17 RODO),

The right to request restriction of the processing of personal data (Article 18 RODO),

The right to receive your data in a structured commonly used format and to have it transferred when processing is based on consent or a concluded contract, and when processing is carried out by automated means (Article 20 RODO),

The right to receive your data in a structured commonly used format and to have it transferred when processing is based on consent or a concluded contract, and when processing is carried out by automated means (Article 20 RODO),

The right to object to the processing of your data on the grounds of your particular situation – in cases where we process your data on the basis of our legitimate interests, including profiling of data. The data subject has the right to object at any time for reasons related to his or her particular situation. The controller shall no longer be allowed to process the personal data, unless the controller demonstrates the existence of compelling legitimate grounds for the processing overriding the interests, rights and freedoms of the data subject, or grounds for establishing, asserting or defending claims. If personal data are processed for the purposes of direct marketing, the data subject has the right to object at any time to the processing of personal data concerning him or her for such marketing, including profiling, to the extent that the processing is related to such direct marketing. The controller will delete the data immediately.

in cases where the processing of data is based on the consent granted, you have the right to revoke the consents granted at any time, but without affecting the legality of the processing performed on the basis of such consents before their revocation. Consent may be withdrawn at any time by email to the address indicated in 4.

In cases where the processing of personal data is deemed to violate the provisions of the RODO, the User has the right to lodge a complaint to the supervisory authority, i.e. the President of the Office for Personal Data Protection, based in Warsaw.

The above rights may be exercised by sending an appropriate request by e-mail or by letter to the Administrator’s registered office address given in § 3 of the Policy

§ 9 TRANSFER OF DATA OUTSIDE THE EOG, PROFILING, AUTOMATED DECISION-MAKING

As a general rule, the Company does not transfer data outside the European Economic Area (hereinafter EEA). However, when using the Company’s Microsoft Office software and subcontractors, there may be times when the Company agrees to transfer personal data outside the EEA only when necessary and with an appropriate degree of protection, primarily by:

cooperating with processors of personal data in countries for which a relevant decision of the European Commission has been issued;

Use of standard contractual clauses issued by the European Commission;

application of binding corporate rules approved by the competent supervisory authority;

§ 10 COOKIES

Cookies are small files sent by a web server to a User’s browser and stored on the User’s computer. Cookies help the Administrator analyze web traffic and recognize which part of the website was visited. Cookies do not in any way allow the Administrator to access the User’s computer or information, except for information about how the website was used and personal information that Users provide automatically due to browser settings.

Typically, web browsing software (web browser) by default allows the storage of cookies necessary for the operation of the website on your end device.

Using your browser settings, you can change your settings in this regard at any time (e.g. delete cookies or block their use in the future). Below you will find information on which cookies are considered essential and others, which we will ask you to agree to install on your computer. Appropriate configuration of your browser settings also allows you to refuse acceptance of cookies. However, this may mean that you will not be able to use all features of the Site.

Types of cookies:

Necessary cookies: This type of cookie is essential to the operation of the Website and cannot be disabled on our systems. Necessary cookies are typically used in response to actions you take, such as setting privacy options, logging in or filling out forms. You can change your browser settings to block them, but the website will then not function properly.

Analytical cookies: These types of cookies allow us to measure the number of visits and collect information about traffic sources so we can improve the performance of our site. They also help us learn which pages are most popular or how visitors navigate our site. If you block these types of cookies we will not be able to collect information about site usage and will not be able to monitor site performance.

Functional cookies: This type of cookies helps us improve the effectiveness of our marketing activities and customize them to your needs and preferences, e.g. by remembering any choices you make on the pages.

Advertising cookies: In order to promote certain services, articles or events, we may use advertisements that display on other websites. This type of cookie is used to make advertising messages more relevant and tailored to your preferences. Cookies also prevent the same ads from appearing again.

Session cookies: These are temporary information stored in your browser’s memory until your browser session ends, that is, until you close it. These cookies are mandatory for certain applications or functionalities to work properly.

Permanent cookies: They make it easier to use frequently visited sites (e.g., they ensure optimal navigation, content layout, etc.). This information remains in your browser’s memory for a longer period of time. The duration depends on the choice you can make in your browser settings. This type of cookie allows information to be transmitted to the server each time a page is visited.

Google Analytics: In order to continuously improve our Site, we use the Google Analytics web data analysis tool of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies that are stored on your computer to analyze your use of the Site. The information generated by the cookies about your use of the Website is usually sent to a Google server in Europe (or a member state of the European Economic Area) to anonymize your IP address, making it impossible to directly link the address to you. Only after the IP address has been anonymized is this abbreviated IP address transferred to a Google server in the US and stored there. The full IP address can be sent directly to a Google server in the USA and only abbreviated there in exceptional cases. This Website uses Google Analytics with an extension for the anonymous collection of IP addresses (so-called IP masking). Google will use for our benefit the information collected to evaluate your use of the Site, to create reports on Site activity and to provide other services related to the use of the Site. The IP address transmitted by your browser as part of Google Analytics is not combined with other Google data.

Google Ads: We promote our website in search engine results. For this purpose, we use the Google Ads tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Ads uses cookies that are stored on your computer to analyze your use of the Site. The information generated by the cookies about your use of the Website is usually sent to a Google server in Europe (or a member state of the European Economic Area) in order to anonymize your IP address, making it impossible to link the address directly to you. Only after the IP address has been anonymized is this abbreviated IP address transferred to a Google server in the US and stored there. The full IP address can be sent directly to a Google server in the USA and only abbreviated there in exceptional cases.

Pixel Meta: Due to our legitimate interests in the analysis, optimization and efficient operation of our services and website, we use a tracking functionality called “Pixel Meta” (formerly: Facebook Pixel), which is provided by Facebook operated by Meta Platforms, Inc. based in the USA USA or, for users who are EU residents, Meta Platforms Ireland Limited based in Ireland. This solution allows Meta to identify visitors to our web content as a target audience for displaying advertisements. Accordingly, we use Meta’s Pixel feature to display our published Facebook advertisements only to Facebook users who have demonstrated an interest in our services or who have certain common ratios (such as interests in certain topics or products determined by the websites visited) that we provide to Facebook (called custom audiences). The Pixel Meta function also helps us understand the effectiveness of Facebook ads for statistical and market research purposes, showing whether users were redirected to our services after clicking on a Facebook ad (known as conversion, allowing us to determine on which devices a user performs an action), to create so-called similar audiences or statistical twins (i.e., broadcasting ads to target groups similar to existing customers), and to obtain comprehensive statistics on site usage. During a user’s visit to our site, the Pixel Meta function establishes a direct connection to Facebook servers. In this way, the Facebook server is notified that you have visited our site, and Facebook assigns this information to your personal Facebook user account.

You can object to our collection of data using Google Analytics, Google Ads and Pixel Meta tools, in particular by selecting the appropriate settings in your browser that restrict the collection of cookies. You can opt out of the use of cookies by selecting the appropriate settings in your browser. However, it is worth bearing in mind that if you do so, you may not be able to take full advantage of all the features offered by our Site. You can also prevent Google from collecting the data generated by the cookies and related to your use of the Site (including your IP address) and from processing this data by Google by downloading and installing the appropriate browser plug-in available here: http://tools.google.com/dlpage/gaoptout?hl=pl. Rejecting cookies is a setting that prevents the collection of data when you visit this Site in the future. For more information on data protection on Google Analytics, click here: http://www.google.com/analytics/terms/pl.html, on Google Ads: https://safety.google/intl/pl_au/privacy/ads-and-data/, and on Facebook and Facebook’s data protection policy at https://www.facebook.com/about/privacy/update. Detailed information on Pixel Meta features is available in the Facebook help section at https://www.facebook.com/business/help/651294705016616.

§ 11 PERSONAL DATA SECURITY

The Administrator shall ensure the security of personal data against unlawful disclosure to unauthorized persons, acquisition of data by unauthorized persons, destruction, loss, damage or alteration, and processing of personal data in a manner inconsistent with the provisions of the RODO.

The Data Controller shall take technical and organizational measures to secure the entrusted personal data that meet the requirements of the RODO, in particular the measures listed in Article 24 and Article 32 of the RODO, ensuring the confidentiality, integrity and availability of the processing services of the personal data provided.

§ 12 AUTOMATED DECISION-MAKING AND PROFILING

Your data may be processed by the Administrator by automated means, including profiling. However, decisions regarding an individual person related to this processing will not be automated.

§ 13 FINAL PROVISIONS

To the extent not covered by this Policy, EU and national data protection laws shall apply. Date of last update of the Policy: 05 July 2024.

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