PRIVACY POLICY

The aim of this document (hereinafter referred to as the “Policy”) is to explain how we, Brain Embassy (hereinafter referred to as “We/Us”), process your personal data while you visit our website at www.brainembassy.com (hereinafter referred to as the “Website”). We process your personal data for specific purposes, though always caring for your privacy. This Policy is supposed to help you understand how we collect data, for what purposes and how you can exercise your rights pursuant to the Regulation 2016/679 (hereinafter referred to as “GDPR”). In the matters concerning data processing in relation to visiting the Website, you can contact us at [email protected] or according to the provisions of Paragraph 8 of this Policy.

1. PERSONAL DATA ADMINISTRATOR

   If you are:

   1. a user of the Website or a user of the Website who submitted a request concerning Brain Embassy locations in Israel, the administrator of your personal data is [_ ] (hereinafter referred to as “BE Israel”);
   2. a user of the Website who submitted a request concerning Brain Embassy locations in Poland, the administrator of your personal data is Real Estate Solutions sp. z o.o. with its registered office in Warsaw, at Aleje Jerozolimskie 181B, 02-222 Warszawa, entered into the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Division of the National Court Register under the KRS number: 266695, Tax Identification Number: 5213410440, REGON statistical number: 140712835, with the initial capital of PLN 50,000.00 (“hereinafter referred to as “BE Poland”);
   3. a user of the Website who submitted a request concerning Brain Embassy locations in Belgium, the administrator of your personal data is [_ ] (hereinafter referred to as “BE Belgium”).

2. WHAT INFORMATION WE COLLECT

   If you are a user of the Website, BE Israel collects your personal data contained among others in cookie files, including in particular your IP address. If you are a user of the Website who submitted this request concerning one of the Brain Embassy locations, BE Israel, BE Belgium or BE Poland collects the personal data provided by you in the contact form or in further communication, including in particular your name, surname, phone number, email address or your interest in a Brain Embassy product.

3. WHY AND ON WHAT BASIS WE PROCESS YOUR DATA

   If you are a user of the Website, BE Israel processes your personal data pursuant to legitimate interests (Article 6, Paragraph 1, Point f of GDPR), including in particular for the following purposes:

   • Making use of analytical and profiling tools in order to adjust the Website to your needs (customisation), adjusting the displayed content (including advertisements) to your interests and the way you use online services and the technologies that we provide;
   • Support in diagnosing technical problems;
   • Handling online services and technologies;
   • Identifying users of online services;
   • Identifying devices in order to prevent fraud;
   • Collecting demographic data about the users of the Website;
   • Determining how the Website is used;
   • Ensuring the security of networks and systems. If you are a user of the Website who submitted a request concerning one of the Brain Embassy locations, BE Poland, BE Israel or BE Belgium processes your personal data:
   • based on your consent (on condition it is a valid and effective basis of data processing) for marketing purposes, including in particular in order to communicate with you about the products and services related to the location for which you expressed your interest (Article 6, Paragraph 1, Point a of GDPR).
   • when it is necessary to perform the duties imposed by legal provisions (Article 6, Section 1, Point c of GDPR).
   • In order to realise the legitimate interests of the administrator (Article 6, Paragraph 1, Point f of GDPR) consisting in handling the request, ensuring security and defending against claims, as well as for internal administrative purposes of their own or other entities from the Group, such as performing analyses and reporting

4. WHO WE SHARE YOUR DATA WITH

   If it is necessary for the realisation of the objectives defined in Paragraph 3 of this Policy, BE Poland, BE Israel or BE Belgium may share it with:

   • the entities entitled to receive it pursuant to legal regulations (e.g., law enforcement agencies, supervision authorities, etc.)
   • the entities processing personal data to our order, e.g., for the companies providing us with consulting, IT or marketing services;
   • other entities which are part of the Adgar capital group that we are part of;
   • our trusted business partners. When processing your personal data, it is possible that it is shared with a third country within the meaning of GDPR, in particular to Israel. For each case of making your data available outside the EEA, we will ensure the highest level of security. Additionally, we would like to inform that based on the decision of the European Commission no. 2011/61/EU from 31 January 2011 issued upon Directive 95/46/EC of the European Parliament and of the Council on appropriate protection of personal data, in relation to automated personal data processing Israel ensures appropriate level of personal data protection. The text of this decision is available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011D0061.

5. HOW LONG WE STORE THE DATA

   Each administrator of your data stores the information about you for a period necessary to realise the objectives presented in Paragraph 3 of this Policy (unless a longer period is required by the applicable law). We will store and use the information about you to the extent necessary to meet the legal requirements (e.g., if we are obliged to keep the information about you for tax purposes), resolve disputes, perform an agreement, a settlement or for the purpose defined in this Policy.

6. WHAT YOU ARE ENTITLED TO

   Taking advantage of the rights you have in terms of personal data processing, you can submit the following demands to the administrator of your data:

   • If processing of your personal data follows based on your consent, you can withdraw this consent at any time; however, please remember that withdrawing the consent does not affect the legality of the processing conducted based on this consent before it was withdrawn;
   • You can demand access to your personal data and obtain its copy;
   • You can use your right to transfer your personal data, that is, demand that your data is presented to you in a structured, universally used machine-readable format, and you can also demand that the data is sent directly to another administrator if the processing is automated upon your prior consent;
   • You can demand correction of your personal data if it is incorrect or incomplete;
   • In a particular situation you can raise an objection against your personal data being processed if the processing is based on a legitimate interest; you can also raise an objective against your data being processed for direct marketing purposes;
   • In the cases defined by law, e.g., if your data is obsolete, unnecessary, processed against the law, or if you have withdrawn your consent to processing (if the consent was the basis of such processing) or you have effectively raised an objective against your personal data processing – you can demand deletion of your personal data;
   • You can also demand restriction of data processing for the time of your objection or request concerning the accuracy of your personal data, the legality of your data processing or the legitimate interest being considered, as well as if you need the data in order to determine, vindicate or defend claims.

7. DO YOU HAVE TO GIVE US YOUR DATA

   It is fully optional for you to give us your data; however, without it we will not be able to realise the objectives stipulated above, and in particular we will be unable to answer your request or provide you with information concerning the Brain Embassy location you are interested in.

8. CONTACT

   For questions concerning data processing or in order to exercise the rights stipulated in Paragraph 6 of the Policy, please contact the administrator of your personal data at:

   • BE Belgium – [???];
   • BE Israel – [???];
   • BE Poland – [email protected].

   For each case in which you decide that the processing of your personal data infringes the provisions of GDPR, you are also entitled to bring a complaint to the appropriate supervision authority of the administrator of your personal data. These are the following authorities for the following BE locations:

   • BE Belgium – Autorité de protection des données Gegevensbeschermingsautoriteit (Belgian Data Protection Authority);
   • BE Israel – Israeli Law, Information and Technology Authority (ILITA);
   • BE Poland – President of the Personal Data Protection Office.