Privacy policy

Personal data protection

The ROBYG Capital Group makes every effort in order to ensure the confidentiality of the personal data and accountability of the processing thereof as well as their availability to the authorized persons. ROBYG attaches great importance to the protection of personal data and privacy of its clients and persons whose personal data are processed in the course of business processes. We take utmost care so that any and all personal date are processed according to the purposes for which they have been collected and in accordance with the scope of the given permissions (consents), should such consents be necessary for the processing of data, in accordance with the applicable legal regulations. Personal data are processed in line with the requirements of Polish law and, in particular, in accordance with 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 (GDPR), the Personal Data Protection Act of 10 May 2018, the Electronic Services Provision Act of 18 July 2002.

Please review this Privacy Policy (“Privacy Policy”) to learn how we collect, use and protect the personal data that are provided to us.

Collection and use of personal data

1.1. Who is the controller of my personal data?

The relevant controller is the entity that implements the specific purposes of data processing. Depending on the purposes for which your personal data are processed in your relationship with ROBYG, the relevant controller will be particular companies from the ROBYG Capital Group.

Upon date collection, we always communicate which entity within our Capital Group is the controller of your data in a particular case as well as the specific information about the data processing, e.g. in agreements we execute with you, job advertisements, or quotation forms.

For example:

  • if you are interested in the offers concerning the ROBYG Capital Group Companies and you would like to receive such offers in electronic form (by e-mail, SMS, live interview by videoconference) or by phone, in particular in matters concerning investing in ROBYG, the data controller shall be ROBYG Marketing i Sprzedaż Sp. z o.o.
  • if you enter into a reservation agreement or any other subsequent agreement concerning the purchase of an apartment, a storage unit or a garage with one of the special purpose vehicles from the ROBYG Capital Group (hereinafter jointly referred to as the “ROBYG Capital Group Companies”) or you are a representative or a contact person acting on behalf of such client, the data controller shall be the special purpose vehicle with which the agreement has been executed.
  • if you enter into, or seek to enter into, agreements with us concerning the lease or sale of real estate or you are a representative or a contact person acting on behalf of such business partner, the data controller shall be the company with which the business relationship is established or with which the agreement is ultimately executed.
  • if you enter into, or seek to enter into, a cooperation agreement whereunder services are to be provided to us (e.g. architectural services, IT services, contracting services, construction services) or you are a representative or a contact person acting on behalf of such business partner, the data controller shall be the company with which the business relationship is established or an agreement is ultimately signed or with which the agreement is ultimately executed.
  • if you use our service allowing you to stay in our co-working space, the data controller shall be Working Balance Sp. z o.o.
  • if you submit the data for recruitment purposes, the data controller shall be the ROBYG Capital Group Company that is the prospective employer
  • if you submit the data for the purposes of commencing employment or cooperation, the data controller shall be the ROBYG Capital Group Company that is the employer

Note: if you are a member of a Housing Community, the data controller for members of such Housing Community shall be such Housing Community, and not the ROBYG Capital Group Company.

 

1.2. How can I contact the data controller?

All ROBYG Capital Group Companies have their registered offices at: Al. Rzeczypospolitej 1, 02-972 Warszawa

You may contact us as set out below:

 

1.3. Has the controller appointed a Data Protection Officer?

Yes, a Data Protection Officer has been appointed at ROBYG Capital Group, being:

Katarzyna Ułasiuk, contact: iod@robyg.com.pl

Correspondence address: Data Protection Officer, al. Rzeczypospolitej 1, 02-972 Warszawa with a note „Inspektor Ochrony Danych”

 

1.4. For what purposes and on what basis are my personal data processed?

The processing of personal data processed for specific purposes is based on relevant legal provisions. Upon date collection, you will always be notified of the actual purposes for which the data collected in a specific case are processed and of the relevant legal basis, e.g. in agreements we execute with you, job advertisements, or quotation forms.

As a general rule, we use data for the following purposes and on the following legal grounds:

a) recruitment – consent of the candidate for employment

b) employment, i.e. the performance of an agreement and the implementation of applicable provisions in this respect (concerning labor law, insurance, taxes, archiving of employee documentation):

  • the need to perform an agreement or the need to process personal data prior to entering into an agreement, at your request, and
  • the applicable provisions of law in the scope of labor law, insurance, taxes, archiving of employee documentation
  • legitimate interests, deemed as enabling contacts within and outside the ROBYG Capital Group in official matters with a competent person (where necessary for the proper performance of entrusted tasks)

c) cooperation based on non-employment agreement (e.g. contract for specific work, contract of mandate):

  • the need to perform an agreement or the need to process personal data prior to entering into an agreement, at your request, and
  • the applicable provisions of law in the scope of insurance, taxes, archiving of documentation
  • legitimate interests, deemed as enabling contacts within and outside the ROBYG Capital Group in official matters with a competent person (where necessary for the proper performance of entrusted tasks)

d) submission of offers concerning ROBYG Capital Group Companies – the consent for receiving such offers in electronic form or by phone (we collect separate consents for each of these forms)

e) conducting a remote video interview with us and recording it for the purposes of archiving (evidence) – the client’s consent to the processing of his or her image is given prior to the commencement of the interview by way of an action (clicking the button in accordance with the information provided beforehand), and additionally with regard to other data provided in the course of the interview – the legitimate interest in recording the conversation for the purposes of evidence

f) the performance of executed agreements concerning the purchase of real estate, lease, use of co-working space, delivery of products/services for our benefit:

  • the need to perform an agreement or the need to process personal data prior to entering into an agreement, at your request, and
  • the applicable provisions of law in the scope of taxes, archiving of documentation, construction law (in the case of real estate), and
  • legitimate interests of ROBYG, deemed as pursuing, defending or establishing claims, recovery of outstanding debts, ongoing contact in the matters concerning the agreement, clarifying potential disputes, maintaining business relations, proper identification of contact persons or representatives of our clients, contractors, their employees or associates

g) ongoing contact with representatives, contact persons appointed for the purpose of contact or persons who contact us on their own volition – the legitimate interests of ROBYG, deemed as accepting an inquiry for execution and responding thereto as well as maintaining ongoing contact

h) video monitoring of the construction site or the workplace – legitimate interests of ROBYG, deemed as protection of persons and property located on the construction site or at the workplace, prevention of abuse or irregularities on the construction site / at the workplace

In addition to the above, information on our clients’ preferences, e.g. types of apartments or investments they are interested in, selected locations (cities, districts), area in m2, without using names, surnames, e-mail addresses, addresses of residence or other personal data, is compiled in an aggregate form. Data used in such compilations originate either from our websites (after being provided with a quotation form) or are provided when an agreement (reservation, sale) is executed. Such aggregated information is used for the following purposes:

  • compiling statistics constituting the basis for analyzing how users make use of the websites;
  • creating look alike profiles, i.e. targeting marketing materials at a similar group of clients by using information and knowledge about them, with the use of a relevant search filters to find their “twins”, i.e. such client who are most similar to them in terms of purchase interests or preferences (based on aggregated data concerning other clients).

 

1.5. Source of data (where does ROBYG get my personal data from?)

Typically, the data are provided by you, the data subject themselves. ROBYG does not acquire salable databases from other entities.

If you use the forms provided by real estate websites, we receive data from such real estate websites to the extent specified in the terms of use of a given website. Our objective in using these data is to respond to your inquiry or, – in the case a separate consent is granted, to present offers about ROBYG investments in electronic form.

If you are an employee, associate or representative of our business partner (e.g. a fit-out services or construction supplier, a party to a lease agreement) or a representative of our client and you are cooperating with us on their behalf, we may receive your contact details from, as the case may be, that business partner or client in connection with their appointment of representatives or persons to maintain contact on their behalf.

The personal data you provide to us are provided on a voluntary basis, however, in certain situations their provision may be a statutory or contractual requirement, and consequently the failure to provide them will prevent the performance of a legal provision or the execution and proper performance of an agreement.

 

1.6. Data recipients

Within the ROBYG Capital Group, we exercise the utmost care not to disclose personal data to unauthorized persons, in particular, we make sure that the information does not fall into unauthorized hands. We ensure that the persons engaged in customer service and in the processing of other categories of personal data are trained in the field of personal data protection.

The ROBYG Capital Group Companies do not sell, transfer or lend the personal data collected for processing purposes to other persons or institutions than authorized employees or associates of the ROBYG Capital Group Companies, unless:

  • this occurs at the request of authorities authorized pursuant to relevant provisions of law (e.g. inspection authorities, bailiffs, the Police)
  • this is required to comply with a legal obligation (e.g. disclosure of data to ZUS (Social Insurance Institution), tax offices, on a notice board at a construction site)
  • this is required for the proper performance of an agreement (e.g. disclosure of data to the bank in connection with settlement-related transfers, disclosure of data to a notary office in the course of a real estate purchase in the form of a notarial deed)
  • this occurs as a result of performance of a legitimate interest of the ROBYG Group Companies (e.g. disclosure of data to attorneys or in court in the event of defending or pursuing claims in court)
  • this occurs on the basis of concluded personal data processing agreements pursuant to which we authorize our service providers to access personal data to the extent necessary to perform the service the were commissioned do perform (e.g. support services related to the maintenance of IT infrastructure or systems, website maintenance, removal of defects that identified on real properties).

Social media

We maintain profile pages on Facebook:

as well as profiles on Instagram

and YouTube:

which may involve the processing of your personal data when you visit our profiles or interact with them (by way of likes, comments, messages). If you visit our social profiles such as on Facebook, we collect data about your activity on our profile, including in the form of likes, messages sent to us, the content of comments and posts made on our profile. Please note that as users of a social media website both we and you are bound by the privacy policy and terms of use that we consented to at this site. Data related to your activity on our social media profiles will be processed by us as part of this profile for the period when a given social media account is active, unless you delete the data yourself. Please remember that, as a user of Facebook or another social media site, you can also manage your account and the content you upload in line with the terms of use of a given social media website.

For how long are personal data stored?

Personal data will only be stored for as long as their ongoing use or archiving serves a purpose. Upon collection, we always communicate the retention periods of data collected in a specific case, e.g. in agreements we execute with you, job advertisements, or quotation forms. 

As a general rule, data retention periods are established based on the following criteria:

  • in case of data processing based on granted consent (e.g. for receiving marketing offers, conducting recruitment processes) – the data shall be stored until the consent is revoked
  • in case of data processing based on a contractual relationship with us – the data shall be stored until the periods when you or we have the right to asset a claim have lapsed
  • in case of data processing for the purpose of satisfying legal requirements – the data shall be stored for the period required by the law.
  • in case of data processing based on our legitimate interests – the data shall be stored for as long as the stated purpose continues and for as long as the archiving is necessary for the purpose of pursuing, defending or establishing claims.

Rights of data subjects

Due to the fact that your personal data are processed, you have the following rights:

  • to request access to your personal data and to be informed about our processing of your personal data
  • to rectify or complete personal data
  • to request erasure of your personal data
  • to request the restriction of processing of your personal data
  • to receive your data in a structured commonly used format. Upon your request, we will send such data directly to another data controller
  • to object on grounds relating to your particular situation where we your personal data are processed based on a legitimate interest. Such objection may be lodged at any time
  • to object to the processing of your personal data for direct marketing purposes. Such objection may be lodged at any time.

Where your personal data are processed based on consent, you have the right to withdraw such consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. 

You also have the right to lodge a complaint with the President of the Personal Data Protection Office if you deem the processing of your personal data to be in violation of GDPR provisions.

General rules of security

The ROBYG Capital Group Companies take the matter of server and computers security in the local network, mobile devices, office security, the use of electronic mail, etc. very seriously. The applied level of data security and the related risks are subject to periodic reviews, assessment and verification. Where necessary, we implement additional control and security mechanisms to increase the level of protection of your data. It is our goal to ensure the highest level of confidentiality of the data you entrusted to us. We guarantee due diligence has been exercised to secure the information, such security to be maintained through periodic verification of the introduced safeguards, periodic training of employees, implementation of internal policies and procedures for the purpose of personal data protection, improvements to the implemented personal data protection system in each and every case when this is possible or, in particular, needed.

Cookies

For the purpose of customizing the services rendered and quicker provision of information, Robyg uses the so-called cookies, being information saved by the server of www.robyg.pl, najagodnie.pl, city-sfera.pl i working-balance.pl on the user’s computer. When a computer connects to the website, the server reads cookies for the main purpose of saving user’s time in searching for information that the user is most likely to be interested in finding. Cookies are also used for saving, for the duration of the session, statistical data about user traffic to be used by Robyg. Users of our website may, at any time, cease providing such information to our website by deleting cookies that our website saved on their terminal equipment. This can be achieved by changing your current browser settings. More information- Internet Explorer More information- Chrome More information- Firefox The user may at any time disable the option of accepting cookies in their browser, but this may result in the use some pages of www.spetrafit.pl becoming impossible. As required by the Telecommunications Law, browser configuration allowing the installation of cookies on your computer shall be deemed as confirmation of consent to the use of cookies. Information on how to manage cookies can be found at All About Cookies website (http://www.allaboutcookies.org/manage-cookies/).

Changes to the Privacy Policy

Many regulations can affect the field of data protection. Should any changes be necessary, such changes shall be included in this Privacy Policy, which will be updated without undue delay.

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ROBYG Hotline 22 888 50 50

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