INFORMATION ABOUT PERSONAL DATA PROCESSING BY BRAIN EMBASSY IN POLAND
1. What our Policy describes
The Policy contains information about data processing by Brain Embassy, and in particular:
a) it defines the types of personal data that we collect;
b) it explains how and why we collect and use your personal data;
c) it explains when and why we will share personal data with other entities; and
d) it explains the right and possibility to choose that you have as regards your personal data.
We want it to be clear for you if the Policy refers to the processing of your personal data as well The Policy applies if:
e) you are a Candidate, that is, you are applying for being employed at Brain Embassy;
f) you are a Member, that is, you rent space at Brain Embassy in Poland;
g) you are a Representative of a Member, that is, you represent a Member, you are a Member’s employee or coworker, and a user of the space at Brain Embassy in Poland;
h) you are a Contractor or Partner, that is, you supply us with any products or services, or you cooperate with us by realising joint projects;
i) you are a Representative of a Contractor or Partner, that is, you represent an entity supplying us with products or services, or cooperating with us by realising joint projects;
j) you are a Recipient of Marketing content, that is, you receive information about the latest offers and additional services of Brain Embassy or third parties with which Brain Embassy cooperates, as a person potentially interested in our products or services or a person representing an entity potentially interested therein.
Your personal data is processed according to the General Data Protection Regulation of the European Union (2016/679) (hereinafter referred to as “GDPR”) and other applicable regulations on personal data protection which complement and/or implement GDPR.
2. WHO IS THE ADMINISTRATOR OF YOUR PERSONAL DATA
The Administrator of your personal data is Real Estate Solutions sp. z o.o. sp. k. with its registered office in Warsaw, at Aleje Jerozolimskie 181B, 02-222 Warszawa.
For any cases related to personal data processing please contact us via mail or e-mail at [email protected]
3. WHAT INFORMATION AND FROM WHAT SOURCES WE COLLECT
If you are a Candidate, we collect the information you provide to us in recruitment forms and documents.
If you are a Member, we collect the information you provide to us in documents, during our talks, in email exchange, at meetings, including in particular the information necessary to conclude and realise the tenancy agreement. This could be in particular your name, surname, mailing address, email address, phone number, company name, company address, PESEL identification number, Tax Identification Number, REGON statistical number, or bank account number. Your data can also come from public sources.
If you are a Representative of a Member, we collect the information you provide to us in documents, during talks, in email exchange, or at meetings. This could be in particular the name, surname, contact details, position, and the data of the entity you represent. Your data can also be provided to us by the entity you represent both before and during their cooperation with us.
If you are a Contractor or a Partner, we collect the information you provide to us in documents, during our talks, in email exchange, at meetings, including in particular the information necessary to conclude and realise an agreement. This could be in particular the name, surname, email address, phone number, company name, company address, PESEL identification number, Tax Identification Number, REGON statistical number, or bank account number. Your data can also come from public sources.
If you are a Representative of a Contractor or Partner, we collect the information you provide to us in documents, during talks, in email exchange, or at meetings. This could be in particular name, surname, contact details, position, and the data of the entity you represent. Your data can also be provided to us by the entity you represent both before and during their cooperation with us.
If you are a Recipient of Marketing content, we collect the information provided by you or your employer, including in the contact form and questionnaires, or from public sources.
4. WHY AND ON WHAT BASIS WE PROCESS YOUR DATA
If you are a Candidate, we process your data:
a) in order to take actions at your request, prior to concluding an agreement (Article 6, Paragraph 1, Point b of GDPR)
b) in order to realise the obligations of the employer and their respective rights under the provisions of the Labour Code (Article 6, Paragraph 1, Point c of GDPR);
c) in order to realise legitimate interests of Brain Embassy, that is, to ensure the security, for reporting reasons, for determination and vindication of claims, and for internal administrative purposes (Article 6, Paragraph 1, Point f of GDPR);
d) based on your consent to data processing in a certain recruitment process or future recruitment processes, in relation to where the obligation to provide it does not stem from legal provisions (Article 6, Paragraph 1, Point a of GDPR);
If you are a Member, a Contractor or a Partner, we process your data::
e) in order to conclude or perform an agreement (Article 6, Paragraph 1, Point b of GDPR);
f) in order to perform legal obligations (Article 6, Paragraph 1, Point c of GDPR), particularly in relation to tax liabilities and storage of financial documentation;
g) in order to realise our legitimate interests (Article 6, Paragraph 1, Point f of GDPR) in relation to ensuring security in buildings, maintaining business relationships, the ongoing contact, conducting marketing activities, as well as vindicating claims and defending against claims.
If you are a Representative of a Member, a Contractor or a Partner, we process your data:
h) in order to realise our legitimate interests (Article 6, Paragraph 1, Point f of GDPR) in relation to ensuring security in buildings, concluding and realising an agreement with the entity you represent, maintaining business relationships and ongoing contact, conducting marketing activities, as well as vindicating claims and defending against claims.
If you are a Recipient of Marketing content, we process your data:
i) for marketing purposes upon your consent (Article 6, Paragraph 1, Point a of GDPR);
j) in order to realise our legitimate interest (Article 6, Paragraph 1, Point f of GDPR), consisting in administering the Website, answering the questions asked and handling the incoming messages.
5. WHO WE SHARE YOUR DATA WITH
If it is necessary to realise the purposes for which we process your data, we can share it with:
a) the entities entitled to receive it pursuant to legal regulations;
b) the entities processing personal data at our request, that is, the companies providing us with certain services requiring processing of personal data, for example, the entities handling our IT systems or providing us with access to IT tools, the entities providing us with consulting services, and other (the so-called “processors”);
c) other companies from the Adgar Group or entities associated by capital with Brain Embassy and companies of the Adgar Poland Group, including [_] and [_];
d) the trusted partners of Brain Embassy.
Whenever sharing your data, we will make sure it is legitimate and refers only to the minimum information necessary for realisation of the objective for which the data is shared.
6. INFORMATION ABOUT THE INTENTION TO MAKE YOUR DATA AVAILABLE IN A THIRD COUNTRY
The Adgar Poland Group is associated by capital with Adgar Investments and Development Ltd. with a registered seat in Petach Tikwa in Israel. Due to the above, in some cases (e.g., in reporting) your data may be made available outside of the European Economic Area, 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, as available at: https://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32011D0061.
7. HOW LONG WE STORE YOUR DATA
If you are a Recipient of Marketing content, we store your personal data as long as it is necessary for realisation of marketing purposes, unless you withdraw your consent earlier, raise objection against your personal data being processed, or demand removal of your data – in such a case your personal data will be removed without undue delay.
If you are a Member, a Contractor or a Partner, or a Representative of a Member, a Contractor or a Partner, we store your data for the period of the realisation of the agreement concluded with you or the entity that you represent. After this period we store your data to the extent necessary for the period pursuant to legal requirements (e.g., due to the obligation to store financial documentation for five years), the provisions concerning the period of limitation for claims (three years for the claims related to business activity) or for the period necessary for the realisation of the data processing objectives defined in this document.
If you are a Candidate, we store your data until the recruitment process is finished, and if you give your consent to your personal data being used for future recruitments – your data will be stored until you withdraw your consent, yet no longer than for two years.
8. 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 us:
a) If we process your personal data based on your consent, you can withdraw this consent at any time; withdrawing the consent does not influence the legality of the processing we conducted based on this consent before it was withdrawn;
b) You can demand access to your personal data and obtain its copy;
c) You can use your right to transfer your personal data;
d) You can demand correction of your personal data if it is incorrect or incomplete;
e) Due to your special situation, you can raise an objective against your personal data if we process it pleading our legitimate interest;
f) 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;
g) You can also demand restriction of data processing;
In order to exercise the above rights, please contact us via mail or at the following email address: [email protected]
For each case in which you decide that our processing of personal data infringes the provisions of GDPR, you are entitled to bring a complaint to the President of the Personal Data Protection Office.
9. DO YOU HAVE TO GIVE US YOUR DATA AND WHERE WE HAVE IT FROM IF NOT FROM YOU
Giving your data is always optional but remember that refusing to give it to us will make it impossible for us to realise the objectives for which the data is collected, and will in particular make it difficult for us to contact you or conclude an agreement you are a party to.
If you are a Representative of a Member, a Contractor or a Partner and you do not provide us with your data yourself, it comes from the entity that you represent or was collected by us from public sources (e.g., the website of this entity).
Cookie files and other monitoring technologies: Definition
- Cookies aimed at analysis and efficiency evaluation. Cookies can be used in order to evaluate efficiency of our website, including as part of the analyses aimed at increasing the quality of the content offered through the website.
Setting and clearing cookies
In your website settings you can block cookie files or configure the settings so that each time you receive a cookie file, you will be informed about it. However, please remember that totally blocking cookies might make it impossible for you to use all the features of the Website. You will find the links to the resources showing how to define the conditions for storing and gaining access to cookie files in the settings of the most popular web browsers.
Alternatively, you can also use the website https://www.allaboutcookies.org/manage-cookies/clear-cookies-installed.html which contains all the exhaustive information on how to stop cookies in your browser or device, as well as general information on cookies. The information about clearing cookies from your mobile phone can be found in the user manual for your phone. You can also stop receiving cookies.Remember that limiting the possibility to receive cookies can influence the website functionality. Due to the numerous technological solutions, it is not possible to present precise guidelines on how to define the conditions of storing and receiving access to cookies with settings of all available telecommunications end devices or software installed on a given device. Nevertheless, in most cases you need to go to “Tools” or “Settings” and select the section related to configuration of cookie file settings or to managing privacy when browsing the Internet. Detailed information is usually provided by the producer of a given device or browser in the user manual or on their website.
Information on some behaviours of the User are logged in the server layer. This data is used only for server administration and in order to secure the most efficient operations of the hosting services. The resources viewed are identified through URL addresses. Moreover, the following can be logged:
- the time the request was received
- the time the answer was sent
- the name of the client station – identification through HTTP
- information on the errors occurring during the realisation of the HTTP transaction
- the URL address of the website visited before by the user (referrer link) – if the transfer to the website followed through a link
- information about the browser of the User
- information about the IP address
This data is not linked to any persons browsing on the website and is only used for server administration.