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Privacy Regulations

Privacy Regulations

Privacy policy - rules for the processing and protection of personal data in Capital Apartments For the purpose of the implementation of the requirements 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), hereinafter referred to as "RODO", we inform you about the rules of processing your personal data and about your rights related with it. The following rules apply from May 25, 2018.

1. The Controller of your personal data The controller of your personal data is Capital Apartments, Pokorna 2 Street lok. U15A 00-199 Warsaw, Poland, REGON: 017324235 NIP (Tax No.): 526-218-87-05 (hereinafter referred to as "Capital Apartments"), an entity providing short-term accommodation (rental) services for apartments in Warsaw and other cities via external booking portals and in a direct booking system.

2. Contact details Capital Apartments has set one contact point for all personal data issues. If you would like to contact us, please write us an e-mail to: info@capitalapart.pl or send a letter to: Capital Apartments, Pokorna 2 Street U15A 00-199 with the note: "Personal data".

3. Where do we obtain your personal data from? Most of the data we receive directly from you via the contact form at https://www.capitalapart.pl, e-mail, during a telephone conversation or while using other means of distance communication with you, or during a personal visit to our office, that is when you contact us with a wish to use our services; We may also collect your data from our partners engaged in the sale of accommodation services, as well through external services (third parties, such as Facebook), at your request or with your consent granted to these entities.

4. What is the scope of data processed? We process following personal data: a. name and surname; b. address; c. the name of your business (when you want to receive a VAT invoice); d. the address of your business (if you want to receive a VAT invoice); e. NIP, that is Tax No. (when you want to receive a VAT invoice); f. e-mail address; g. telephone number (if you provided us for contact); h. your bank and bank account number from which you made payments, credit card, debit or other payment details; i. additional information about yourself that you could have included in e-mail correspondence or that you could have provided during the telephone conversation with our staff (although we do not record calls); j. your consent (if, for example, you gave us permission to process your data for marketing purposes); k. date of birth; l. citizenship and other data present on the identity document issued by the relevant authorities;.

5. What is the purpose and legal basis for processing of your personal data? We process your personal data for the purpose of providing you our services, that is short-term lease of our apartments. Due to the above, we process your personal data for various purposes indicated below: performance of the contract to which you are a party or taking action at your request prior to the conclusion of the contract (Article 6 (1) (b) of RODO); mandatory provisions of law also requires us to process your personal data for accounting and tax purposes (Article 6 (1) (c) of RODO); if you give us separate consent, we will process your data for our marketing purposes with reference to the legitimate interest of the controller (Article 6 (1) (f) of RODO).As a part of our marketing, we want to be able to present you tailor-made offers and promotions. For this purpose, we can perform profiling activities, which in no case affect your rights or freedoms, nor affect you in any other way; your personal data is also processed to collect debts, conduct court, arbitration and mediation proceedings, archiving and give us possibility to account for the correct fulfilling of the obligations imposed by law, including the processing of your data, which is the legitimate interest of the controller (Article 6 (1) (f) of RODO).

6. How long do we process your personal data? The period for which we process your personal data depends on the purpose of processing. Consequently: regarding the performance of the contract with you or taking action on your request prior to the conclusion of the contract - your personal data will be processed by us for the time necessary to perform it, and then until the end of the limitation period for your or our claims related to it (this period depends on the type of claim in accordance with the Civil Code or other legal acts regulating the liability principle, also other than civil); regarding accounting purposes - we will process your data for a period of 5 years, counting from the beginning of the year following the accounting year covered by the accounting documents (Article 74 paragraph 2 and 3 of the Accounting Act). As far as tax purposes are concerned, data will be processed for a period of 5 years, counting from the end of the calendar year in which the payment deadline for a given tax has expired (Article 70 § 1 of the Tax Ordinance); marketing purposes - we will process your data until you object to such processing, in any case for no longer than 10 years from the date of your last booking in our facilities; debt collection, conducting court, arbitration and mediation proceedings, archiving purposes and the possibility of us to account for the correct fulfilling of the obligations imposed by law, including processing your data - your personal data will be processed until the end of the limitation period (this period will depend on the type of claim in accordance with the Civil Code or other legal acts regulating the principle of non-civil liability) or the period in which we may be exposed to a different type of liability related to the relationship we have established with you.

7. Who is the recipient of your personal data? We only share your data when it is necessary. We do not sell your data, we do not make your data commercially available to third parties. We can pass your personal data on to our contractors: service providers supplying Capital Apartments with technical and organizational solutions that enable us to provide services and manage our organization (eg companies delivering and maintaining database software, through which we can conduct our service and relevant sales records, suppliers of business management systems, entities providing hosting services, etc.); marketing agencies (advertising agencies, entities supporting e-mailing services) that help us understand what our clients are interested in, create interesting offers, promotions and help us in ongoing communication with customers, including you; companies collecting opinions about our products or services - they help us if you want to share your opinion about us or impressions about the use of our services; intermediaries in the execution of payments, in the case of payment transactions; providers of legal, accounting and advisory services. For each of these purposes, we only provide data that is necessary to achieve it.

8. How do we process your personal data? We process personal data in accordance with applicable law, in particular in accordance with RODO. We have the following rules in mind when we process your personal information: Adequacy rule. We process only data that is necessary to achieve a given processing goal; we have carried out an analysis of the fulfillment of this rule for each business process; Transparency rule. You should have full knowledge of what is happening with your data. This document, in which we try to provide you with complete information about the rules of processing your personal data by us, is its manifestation; Accuracy rule. We strive to keep your personal data in our systems up-to-date and truthful. If you find that in some area your personal data have not been updated or are incorrect, please contact us at the email address info@capitalapart.pl Integrity and confidentiality rule. We apply the necessary measures to safeguard the confidentiality and integrity of your personal data. We are constantly improving them, along with the changing environment and technological progress. Security includes physical and technological measures restricting access to your data, as well as appropriate measures to prevent loss of your data; Accountability rule. We want to be able to account for each of our actions regarding personal data, so that in the event of your inquiry we can give you full and reliable information about what actions we have been carried out on your data.

9. What rights do you have regarding the processing of your personal data? The provisions of law give you a number of rights that you can use at any time. Unless you abuse these rights (eg unreasonable daily requests for information), exercising them will be free of charge and should be easy to implement. Your rights include: the right to access your personal data. This right means that you can ask us to export from our databases the information we have about you and send it to you in one of the commonly used formats (eg XLSX, DOCX, etc.); the right to correct personal data. If you find out that your personal data we process is incorrect, you may ask us to correct it and we will be obliged to do so. In this case, we have the right to ask you for a document or proof of the change; the right to seek restriction of personal data processing. If, despite the fact that we adhere to the adequacy principle, that is we process only data that is necessary to achieve a given processing goal, you consider that for a specific purpose we process too wide catalogue of your personal data, you have the right to request that we restrict (limit) the scope of processing. If the request does not oppose the requirements imposed on us by applicable law, or it is not necessary for the performance of the contract, we will accept your request; the right to request erasure of personal data. This right, also known as the right to be forgotten, means that you can demand that we remove any information that contains your personal information from our systems and any other records. Remember however, that we will not be able to do so if we are obliged to process your data under provisions of law (for example transaction documents for tax purposes, obligation to ensure the accountability of our activities). In each case, however, we will remove your personal data to the fullest extent possible, and where it is not possible we will ensure their pseudonymisation (which means that the data subjected cannot be identified without a corresponding key). Allowing this, your data we need to keep in line with applicable law, will be available only to a very limited group of people in our organization; the right to personal data portability. In accordance with the General Data Protection Regulation, you can ask us to port the data you provided to us in the course of all our contacts and all cooperation to a separate file, for the purpose of further transfer to another data controller; the right to withdraw consent. If we process your personal data on the basis of your consent, you can revoke this consent at any time. Withdrawal of your consent will not affect the lawfulness of the processing previously performed on the basis of the consent (prior to its withdrawal). However, we would like to inform you that your personal data in the scope of the purpose covered by the revoked consent will cease to be processed for this purpose only. Your personal data subject to consent will be further processed in order to fulfill our obligations under the law, including, in particular, the obligation to account for the correctness of personal data processing, or for the purposes based on our legitimate interest. You can perform the above mentioned rights by contacting us at the e-mail address info@capitalapart.pl or  by post on Capital Apartments, Pokorna 2 / U15A 00-199 with the note "Personal data". In all matters related to personal data, you can always write to us, especially when any action or situation you encounter raise your concerns about its legality or if you feel that your rights or freedoms may be violated. In this case, we will answer your questions and concerns and immediately address the issue. If you believe that in any way we have violated the rules for the processing of your personal data, you have the right to submit a complaint directly to the supervisory authority (from 25 May 2018, it is the President of the Office for Personal Data Protection in Poland). As part of exercising this right, you should provide a full description of the situation and indicate what action you consider as violating your rights or freedoms. The complaint should be submitted directly to the supervisory authority.

10. What is the right to object? We would like to inform you separately that you also have the right to object to the processing of your personal data. You submit the right to object when you do not want us to process your personal data for a specific purpose (for example for marketing purposes). You have the right to object also when the processing of your personal data is based on a legitimate interest of the controller or for statistical purposes, and the opposition is justified by the particular situation in which you have found yourself. In this case, we will continue to process your data for other processes (for other purposes), but not for the purpose for which you objected. You can exercise the right to objection by sending a message to the e-mail address info@capitalapart.pl or by post to the address Capital Apartments, Pokorna 2 Street lok. U15A 00-199, with a note with the note "Personal data".

11. Is it your obligation to provide your data? You do not have a legal obligation to provide us with your personal data. Without obtaining them, however, we will not be able to provide our services to you.

12. Do we transfer your data outside EU? No, the Controller does not intend to transfer your data to a third country or to international organizations.

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