The purpose of this privacy policy (“Privacy Policy”) is to explain why and how we - Parkur Propco sp. z o.o., Parkur Bemowo sp. z o.o. and Talonello Investment sp. z o.o. process the personal data of a tenant, co-tenant or other person living in or visiting a rented apartment located in Kłobucka 25, Orlińskiego 3, 3a, Markowska 5, 5a and Brzeska 8 (hereinafter referred respectively to as "tenant", "data subject" and “apartments”). Please read this Privacy Policy carefully.
- CONTROLLER Parkur Propco sp. z o.o. with its registered office in Towarowej 28, 00-839 Warszawa entered in the commercial register of the National Court Register under the KRS number 0000878005 and Bemowo Propco sp. z o.o. with its registered office in Towarowej 28, 00-839 Warszawa entered in the commercial register of the National Court Register under the KRS number KRS 0000875874 and Talonello Investments sp. z o.o. with its registered office in Towarowej 28, 00-839 Warszawa, entered in the commercial register of the National Court Register under the KRS number 0000916731 are jointhly the controller of the data (“controller"). Contact details of the controller: Mathias Sachse Skrubbeltrang, [email protected]
- PERSONAL DATA PROCESSED As a rule, personal data concerning the data subject being a tenant or a person applying for a rental is collected from the data subject himself in connection with the application for a rental apartment and the conclusion of the lease agreement, as well as during the rental relationship. Information about the data subject being a tenant or a person applying for a rental can also be collected from other sources, such as publicly available registers. The credit information of the applicant for a rental apartment can be checked from the registers of an external service provider. The controller cooperates with Simpl sp. z o.o. a limited liability company incorporated and existing under the laws of Poland, having its registered office in Kraków, address: ul. Piwna 25 premises no 20, 30-527 Kraków , who enables the tenant to create an certificate confirming its identity and credibility (“Simpl”). The terms and conditions governing the provision of services by Simpl can be found here. The draft certificate to be provided by Simpl to the controller can be found here. We also collect data for the following purposes: managing access rights to protect the property and its residents and to investigate damage situations and property crimes. The following data is collected and processed about tenants: • information such as name, age, gender and personal and tax identity code; • connection information, such as previous mailing address, email address and telephone number; • information on the lease agreement, such as information on the apartment to be rented, the rental period, the amount of the rent and the grounds for increasing it; • customer service information, such as information about the language of communication and the tenant's contacts with customer service; • information related to the use of the tenant's apartment, such as information on fault reports and repairs, as well as information on energy and water consumption (when this is necessary, for example, for property-specific measurements); • the tenant's credit history to the extent permitted and required by law; • information necessary for this purpose, such as information on invoicing and payments transferred to collection; • information related to the management of access rights: basic and identification data (name, apartment number, key identification data) and information on access rights (access rights assigned to the key); • information necessary for the investigation of damages and property crimes, such as lock transaction log data (lock opening timestamp, entry or entry failure log).
- PURPOSE AND LEGAL BASIS FOR PROCESSING PERSONAL DATA We process personal data for the purpose of entering into and managing the lease relationship, cf. GDPR art. 6(1)(b). In this case, personal data is also processed in connection with the maintenance of apartments, the management of fault reports and the provision of housing-related services. In the above cases, the processing of personal data is based on a lease relationship. However, with respect to the data subjects who are not the party of the lease relationship (persons living in or visiting an apartment) the processing is necessary for the purposes of our legitimate interest, cf. GDPR art. 6(1)(f).
- TRANSFER AND DISCLOSURE OF DATA We may transfer and disclose data subjects' personal data to third parties in the following cases: • in accordance with the requirements and limits of the legal or contractual relationship; • trusted external service providers (e.g., Colliers) acting on behalf of and in accordance with the controller's instructions; • to a maintenance company, lock company or other processor of personal data authorized by us, who act on behalf of the controller and in accordance with the instructions. • to other companies within the NREP Group; • to Simpl to enable the tenant the creation of the tenant’s certificate under Simpl’s terms and conditions; • to entities holding security over receivables due to the controller arising under concluded lease agreement, or entities which acquire such receivables, including to the European Bank for Reconstruction and Development. • in connection with a corporate reorganization; and • when we believe in good faith that disclosure is necessary to protect our rights, protect you and others, investigate fraud, or respond to government requests.
- ABOUT OUR PARTNERS The rental, rent billing and hosting of our apartments is handled by our partner - Colliers Property Management Poland Sp. z o.o. a limited liability company incorporated and existing under the laws of Poland, having its registered office in Warsaw, address: ul. Prosta 70, 00-838 Warsaw (hereinafter "Colliers"). Colliers processes personal data on our (controller’s) behalf and in accordance with our instructions, for example with regard to the administration of lease agreements.
- CCTV The controller conducts video monitoring in the common areas of the building where apartments are located in order to ensure security in the building. Monitoring recordings may be made available to the following categories of recipients: (i) public authorities and entities performing public tasks or acting on behalf of public authorities within the scope of their statutory authority; (ii) entities cooperating with the controller in carrying out monitoring (to the extent necessary for its performance) or in managing the building. Recordings from the monitoring shall be kept for a maximum period of 6 months.
- TRANSFER OF DATA OUTSIDE THE EU/EEA We do not transfer your personal data outside the EU or the European Economic Area.
- DATA RETENTION The personal data is stored during the term of the lease agreement and beyond such term until the end of the calendar year when the seventh anniversary of the expiry of the term of the lease elapses. However, if the lease agreement is not signed the personal data shall be stored no longer than until the end of the subsequent calendar year.
- RIGHTS OF THE DATA SUBJECT As a data subject, the following rights are guaranteed to you in the applicable data protection legislation: • You have the right to request from us access to personal data concerning you and the right to request the rectification or erasure of such data within the limits of and in accordance with applicable data protection law; • You have the right to request the restriction of processing or to object to the processing within the limits and in accordance with applicable data protection legislation; • You have the right to data portability, i.e., to receive the personal data concerning you in a structured and commonly used format, and to transfer it to another controller within the limits and in accordance with applicable data protection legislation; and • You have the right to lodge a complaint with your national data protection authority (President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw) or other data protection authority of the European Union or the European Economic Area if you consider that your statutory rights have been violated. You can send the above-mentioned requests to our customer service, whose contact information can be found at the beginning of this privacy policy.
- PROTECTION OF PERSONS We have in place the necessary technical and organizational data security measures to protect personal data from destruction, destruction, misuse and unauthorized access. For example, we restrict access to your data only to personnel who have a need to process that data in order to work on their work.
- LINKS We may propose hypertext links from communications you receive from us, to third-party websites or Internet sources. We do not control such third-party website or Internet sources and cannot be held liable for third parties’ privacy practices and content on their websites. Please read their privacy policies carefully to find out how they collect and process your personal data.
- AUTOMATED DECISION MAKING / PROFILING There is currently no automated decision-making process or profiling which would legally effect you or otherwise significantly affects you.
- TRANSFER IN CASE OF CHANGE OF CONTROL If controller or its entire group is involved in a merger, acquisition, dissolution, or sale of the apartments, we reserve the right to transfer your personal data. You will be notified if your data is transferred to another entity as a result of a merger, acquisition, dissolution, or sale.
- CHANGES TO THE PRIVACY STATEMENT We reserve the right to change and update this privacy statement. If we make changes to the privacy policy, we will inform you about it on our website: www.lett.pl