DEVELIA S.A. PRIVACY POLICY

This Privacy Policy applies to the rules of using the website https://develia.pl (hereinafter: Website) and the processing of personal data in connection with business operations of Develia S.A.

I DATA CONTROLLER

The Data Controller is Develia S. A. with its registered office in Wrocław at ul. gen. Romualda Traugutta 45, 50-416 Wrocław Wrocław, KRS: 0000253077, NIP: 8992562750, REGON: 020246398, share capital: PLN 447,558,311 (hereinafter: Controller). You can contact the Controller as follows:

Develia S.A.
ul. gen. Romualda Traugutta 45, 50-416 Wrocław
website: https://develia.pl,
e-mail: biuro@develia.pl
phone: (+48) 71 79 88 010.

II DATA PROTECTION OFFICER

The Controller has appointed a team of Abistar s.c. Data Protection Officers. You can contact the Data Protection Officer at the following e-mail address: ochronadatnych@develia.pl or at the Controller’s address attn. “Data Protection Officer”.

III LEGAL BASIS AND PURPOSES OF PERSONAL DATA PROCESSING

Your personal data will be processed for the following purposes:

Using the Website

Personal data of all Website Users (including an IP address and information collected via cookies from the User’s end device) are processed in order to:

provide services by electronic means in the scope of providing Website Users with content published on the Website – in connection with the performance of the contract pursuant to Art. 6 Sec. 1(b) of the GDPR;
use necessary cookies – in connection with the performance of the contract pursuant to Art. 6 Sec. 1(b) of the GDPR;
use cookies for analytical and statistical purposes based on the User’s consent – in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1(f) of the GDPR, consisting in conducting analyses of Users’ activity, as well as their preferences in order to improve the functionalities and efficiency of the Website.

When making the Website available, the Controller uses solutions and analytical tools developed by external entities. The Controller uses tools such as:

Google Analytics

Detailed information on the scope and principles of data collection in connection with this service can be found in the privacy policy of a given partner.

Contact with the Website User

You can contact the Controller using a contact form available on the Website, chat, phone call order form or by sending an e-mail. If an inquiry is sent to the Controller, personal data will be processed only for the purpose of:

communication and resolution of the matter to which the correspondence relates – in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1(f) of the GDPR consisting in sending correspondence as part of customer service or in connection with the Controller’s business operations;
defense against possible claims – in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1(f) of the GDPR in the scope of pursuing or defending against claims.

Subscribing to the legal newsletter by the Website User involves the processing of his/her personal data, which are processed in order to:

provide the newsletter service – in connection with the performance of the contract pursuant to Art. 6 Sec. 1(b) of the GDPR;
send marketing content to the User as part of the newsletter – based on the User’s consent (Article 6 Sec. 1(a) of the GDPR);
conduct analytical and statistical activities related to sending the newsletter – in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1(f) of the GDPR consisting in conducting analyses of Users’ activity on the Website in order to improve the functionalities used and to assess the attractiveness of the content provided in the newsletter.

Controller’s Marketing

The Controller processes Users’ Personal Data in order to carry out marketing activities of the Controller’s own or third-party products and services. In this regard, personal data will be processed only for the purpose of:

displaying marketing content to the User on the Internet – in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1(f) of the GDPR consisting in conducting marketing and remarketing campaigns on the Internet;
displaying marketing content to the User corresponding to his/her interests in connection with profiling based on cookies (behavioral advertising) – based on the User’s consent (Article 6 Sec. 1(a) of the GDPR) to collect cookies, as well as in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1(f) of the GDPR consisting in conducting marketing and remarketing campaigns on the Internet and to customize the displayed content according to individual preferences and interests of the User;
sending commercial information by electronic means (to an e-mail address) and conducting telemarketing activities (MMS/SMS or telephone conversation) – based on the User’s consent (Article 6 Sec. 1(a) of the GDPR);
sending notifications as part of the newsletter about interesting offers or content, which in some cases contain commercial information – based on the User’s consent (Article 6 Sec. 1(a) of the GDPR);
maintaining accounts in social media – in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1(f) of the GDPR consisting in maintaining an account, promoting the Controller’s brand, products and services, building and maintaining a community related to the Controller and for the purpose of communication;
conducting analytical and statistical activities, as well as activities related to direct marketing of goods and services – in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1(f) of the GDPR consisting in conducting analyses of the effectiveness of marketing campaigns conducted by the Controller on the Website and assessing the attractiveness of the content provided;
sending marketing materials via traditional mail – in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1(f) of the GDPR consisting in conducting marketing and remarketing campaigns without examining recipients’ preferences.

In connection with marketing activities, the Controller uses solutions and analytical tools developed by external entities. The Controller uses tools such as:

Google Ads
Display
Facebook ADS

Detailed information in this regard can be found in the data privacy settings and in the privacy policy of a given partner.

Performance of the contract

You can contact the Controller to discuss its housing offer via a contact form available on the Website, chat, phone call order form, by sending an e-mail or via forms provided by listing portals cooperating with the Controller. In this case, personal data are processed for the purpose of:

enabling the presentation of a particular investment selected by the User or in order to take steps to conclude a contract – pursuant to Art. 6 Sec. 1(b) of the GDPR;
verification of the User’s interest in concluding a contract – in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1(f) of the GDPR consisting in verifying the Customer’s decision or verifying the validity of customer databases;
User satisfaction surveys – in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1 (f) of the GDPR consisting in verifying the Users/Customer’s reaction after contacting the Controller’s employees or after using its services;
defense against possible claims – in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1(f) of the GDPR in the scope of pursuing or defending against claims.

Performing the Controller’s legal obligations

Contact with the Controller undertaken by the User may involve the processing of personal data, the performance of legal obligations imposed by the Controller, e.g. in connection with pursuing complaints or the rights of Data Subjects or with settlements in connection with contracts concluded with the Controller. In this case, the processing of personal data is carried out on the basis of Art. 6 Sec. 1 (b) and (c) of the GDPR.

Pursuing claims

Personal data will be processed in order to enable the pursuit of claims in the event of using the Website in a manner inconsistent with the law and the Terms of Service, security rules or decency – in connection with the Controller’s legitimate interest within the meaning of Art. 6 Sec. 1 (f) of the GDPR in the scope of pursuing or defending against claims.

IV PERSONAL DATA STORAGE PERIOD

The period of data processing by the Controller depends on the type of service provided and the purpose of processing.

Personal data processed in order to respond to the User’s request related to the functioning of the Website will be processed for the period necessary to answer an inquiry or handle a complaint.

Any data that will be processed in order to meet any obligation imposed on the Controller by the law will be stored until such obligation is met, unless the law requires further storage of such data.

When the basis for processing is the necessity to conclude and perform a contract, data are processed until its termination.

If the processing is based on consent, data are processed until its withdrawal.

Any data processed in order to implement the Controller’s legitimate interest, in particular statistical and analytical data, will be processed for a period enabling the enforcement of this interest or until the User effectively objects to their processing.

If certain messages may constitute or constitute evidence in proceedings before a court of law or other authority, they will be stored until the end of the limitation period for any claims or until the final termination of the proceedings, if they have been initiated, whichever is later.

Any data no longer necessary for the purposes for which they were collected will also be deleted.

V SHARING DATA WITH OTHER ENTITIES. DATA RECIPIENTS.

In order to protect Users’ personal data against accidental or unlawful disclosure to unauthorized persons, removal by unauthorized persons, destruction, loss, damage or change, as well as against unlawful processing, the Controller uses technical and organizational security measures to protect the data processing.

Any personal data processed by the Controller may only be accessed by authorized employees or associates of the Controller and external entities providing individual services to the Controller related to the operation of the Website, to whom these data have been entrusted and who have been obliged to keep any personal data of Users to whom they have access confidential. These may be primarily entities responsible for the operation of IT systems and hardware, software suppliers, entities providing accounting or legal services, finance advisors, postal operators, couriers, marketing agencies.

Personal data of Website users may be made available to entities authorized to receive them under applicable laws, including competent state authorities.

VI USER’S RIGHTS

Any User who provided his/her personal data has the following rights:

the right of access,
the right to rectification,
the right of modification
the right to restrict data processing,
the right to erasure,
the right to portability of data, processed in an automated manner on the basis of the User’s voluntary consent or processed in an automated manner if their processing is necessary for the performance of a contract to which the Data Subject is a party, or to take action at the request of the Data Subject before concluding the contract .

The User also has the right to object, at any time, to the processing of personal data by the Data Controller when:

such processing is carried out for the purpose of direct marketing – if the User exercises this right,
we will immediately stop processing his/her personal data for this purpose, such processing is carried out in order to implement the Controller’s legitimate interest – if the User exercises this right, we will immediately stop processing his/her personal data, unless we are able to demonstrate that there are valid legitimate grounds for further data processing, overriding those interests, rights or freedoms indicated by the User.

If the User exercises one of the above rights, the Controller will immediately take action to remove inconsistencies in the processing of personal data.

In addition, when the processing of personal data is based on consent, the User is entitled to withdraw his/her consent to the processing of personal data. The consent may be withdrawn at any time, without prejudice to the processing activities carried out prior to such withdrawal.

In order to exercise the above rights, the User may contact the Controller as follows:

Develia S.A.

ul. gen. Romualda Traugutta 45, 50-416 Wrocław

website address: https://develia.pl,

e-mail: biuro@develia.pl

phone: (+48) 71 79 88 010.

The User also has the right to lodge a complaint with the supervisory authority if he/she considers that the processing of data by the Controller violates the applicable laws, in particular the provisions of the GDPR. According to Art. 56 Sec. 1 of the GDPR, in relation to data processing by Prosoma sp. z o.o., the leading supervisory authority competent to take action is:

President of the Personal Data Protection Office

Stawki 2,

00-193 Warsaw

Poland

https://uodo.gov.pl/pl/p/kontakt

VII SECURITY AND PROCESSING OF USER’S DATA

The Controller undertakes to use adequate technical measures to achieve the highest possible level of security in terms of the User’s personal data, trying to prevent unauthorized access to data. The Controller undertakes to protect data against accidental or unlawful disclosure to unauthorized persons, destruction, loss, damage, change and processing inconsistent with the provisions of applicable laws.

The User’s personal data will not be subject to automatic processing or profiling. However, due to the use of programming solutions on the Website, the Controller may automatically process information on the company represented by the User.

The Controller will not transfer Users’ personal data to any third countries or international organizations. However, in connection with the use of programming and Internet services, data may be transferred to a third country independent of the Controller’s will, which results from the regulations of providers of these services.

VIII. FINAL REGULATIONS

This Privacy Policy may change due to technological development and modification of existing standards or changes in the law.