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 Adgar Investment and Development with its registered office at Efal 35 Petach Tikva; Tax Identification Number: 520035171;(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 Brain Embassy Belgium with its registered office at Molenbergstraat 10, 2000 Antwerpen; Tax Identification Number: BE0731.710.590;  (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:

    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.

COOKIES POLICY

This policy applies to the cookies used by Real Estate Solutions sp. z o.o. with its registered office in Warsaw, Poland (“BE“) on the website available at https://brainembassy.com/ (the “Home Page“) and the landing page on the domain brainembassy.com (the “Landing Page“; Home Page and Landing Page hereafter also collectively referred to as the Website).

1. Cookies

Cookies are computer files stored in the memory of the end device (computer, laptop, tablet, phone) transmitted by the Website during its use. These cookies enable the identification of the end device to ensure the correct display of the Website, tailored to the individual preferences of the visitor to the Website.

The data is collected automatically and predominantly includes:

    • statistical data,
    • IP address;
    • other device identification numbers;
    • session data;
    • data relating to activity on the Website.

2. Cookies used by BE

BE uses different types of cookies on the Site, which remain in the memory of the end device until they are manually deleted by the browser user or until the expiry date specified in the functional parameters of the cookies.

Furthermore, considering the purpose of the service’s use of cookies, we can divide them into:

  1. essential): contribute to the usability of the Website by enabling basic functions such as site navigation and access to secure areas of the Website; the Website cannot function properly without these cookies;
  2. Functional: enable the Website to remember information that changes the appearance or functioning of the Website, such as your preferred language or region. Functional cookies help with certain functions, such as sharing Website content on social media platforms, collecting feedback and other third party functions;
  3. Statistical/analytical: these types of cookies are used to understand how visitors interact with the Website. These cookies help to provide information on visitor metrics, traffic sources, etc.;
  4. Marketing: used to analyse user behaviour on websites; their purpose is to display advertisements that are relevant and interesting for individual users and thus more valuable for publishers and advertisers.

You will find a detailed list of the cookies used on the Home Page and Landing Page at the end of this Cookies Policy.

3. Purpose of BE’s use of cookies

The main purpose of cookies is to ensure the continued use of the Website and to adapt the content of the Website to the visitor’s preferences. BE also uses cookies for its own purposes such as collecting statistics to improve the functionality of the Website, the services provided by BE. Cookies are also used for marketing and advertising purposes.

4. Legal basis for processing cookies and the duration of their storage

BE processes essential cookies (necessary and essential for the proper functioning of the Website, including maintaining the session after logging in) on the basis of the administrator’s legitimate interest (Article 6(1)(f) GDPR in conjunction with Article 173(3)(2) Telecommunications Law).

BE processes functional cookies which allow it to remember the settings of the Website selected by the user so that the use of the website is more efficient, these cookies are processed on the basis of the voluntary consent of the visitor to the Website (Article 6(1)(f) GDPR in conjunction with Article 173(1) Telecommunications Law).

BE processes statistical cookies (which enable the creation of statistics to better understand users’ preferences and, through their analysis, improve and develop the functionality of the Website) based on the voluntary consent of the visitor to the Website (Article 6(1)(f) GDPR in conjunction with Article 173(1) of the Telecommunications Law).

BE processes marketing cookies for advertising purposes based on the voluntary consent of the visitor to the Website (Art. 6(1)(f) GDPR in conjunction with Art. 173(1) Telecommunications Law).

BE processes each time the data contained in the files in compliance with the provisions of the GDPR and the Telecommunications Law.

The retention (storage period of cookies) is indicated for each cookie in the table at the end of this policy.

5. Cookie managment

Before accessing the Website, any person can give his/her consent to the storing of preferential, statistical and marketing cookies via a cookie banner (pop-up), whereby the person can choose which cookies he/she gives his/her consent to.

The necessary cookies are saved automatically, as their absence may adversely affect the display of the Website or its functionalities.

At any time, a visitor to the Website may delete cookies using the functions available in his or her web browser.

If in doubt, please contact us at [email protected]

6. Cookies used on Global Website

Name Domain Retention Type
CookieConsent cookiebot.com 1 year Necessary
_GRECAPTCHA www.google.com 180 days Necessary
_grecaptcha www.google.com Persistent Necessary
rc::a www.google.com Persistent Necessary
rc::b www.google.com Session Necessary
rc::c www.google.com Session Necessary
CONSENT brainembassy.com 2 years Necessary
wp-wpml_current_language brainembassy.com 1 day Functional
maps/gen_204 maps.googleapis.com Session Functional
_ga www.google-analytics.com 2 years Statistics
_gat www.google-analytics.com 1 day Statistics
_gid www.google-analytics.com 1 day Statistics
collect google-analytics.com Session Statistics
yt-player-headers-readable brainembassy.com Persistent Statistics
ads/ga-audiences google.com Session Marketing
NID drive.google.com 6 months Marketing
rc::f www.google.com Persistent Marketing
LAST_RESULT_ENTRY_KEY www.youtube.com Session Marketing
LogsDatabaseV2:V#||LogsRequestsStore brainembassy.com Persistent Marketing
nextId www.youtube.com Session Marketing
nWC1Uzs7EI brainembassy.com Session Marketing
requests www.youtube.com Session Marketing
ServiceWorkerLogsDatabase#SWHealthLog brainembassy.com Persistent Marketing
TESTCOOKIESENABLED www.youtube.com 1 day Marketing
VISITOR_INFO1_LIVE brainembassy.com 180 days Marketing
YSC brainembassy.com Session Marketing
yt.innertube::nextId brainembassy.com Persistent Marketing
ytidb::LAST_RESULT_ENTRY_KEY brainembassy.com Persistent Marketing
YtIdbMeta#databases brainembassy.com Persistent Marketing

7. Cookies used on Landing Page

Name Domain Retention Type
test_cookie www.googletagmanager.com 1 day Necessary
CookieConsent cookiebot.com 1 year Necessary
CONSENT www.youtube.com 2 years Necessary
_ga www.googletagmanager.com 2 years Statistics
_ga_# www.googletagmanager.com 2 years Statistics
_gat www.google-analytics.com 1 day Statistics
_gid www.google-analytics.com 1 day Statistics
_hjAbsoluteSesyjnyInProgress script.hotjar.com 1 day Statistics
_hjFirstSeen script.hotjar.com 1 day Statistics
_hjIncludedInSesyjnySample_# script.hotjar.com 1 day Statistics
_hjSesyjny_# script.hotjar.com 1 day Statistics
_hjSesyjnyUser_# script.hotjar.com 1 year Statistics
_hjTLDTest script.hotjar.com Session Statistics
_hjRecordingEnabled hotjar.com Session Statistics
_hjRecordingLastActivity hotjar.com Session Statistics
hjActiveViewportIds hotjar.com Persistent Statistics
hjViewportId hotjar.com Session Statistics
_ga www.google-analytics.com 2 years Statistics
_gat www.google-analytics.com 1 day Statistics
_gid www.google-analytics.com 1 day Statistics
yt-player-headers-readable www.youtube.com Persistent Statistics
_fbp connect.facebook.net 3 months Marketing
_gcl_au www.googletagmanager.com 3 months Marketing
ads/ga-audiences www.googletagmanager.com Session Marketing
pagead/1p-user-list/693041885/ www.googletagmanager.com Session Marketing
LAST_RESULT_ENTRY_KEY www.youtube.com Session Marketing
LogsDatabaseV2:V#||LogsRequestsStore www.youtube.com Persistent Marketing
nextId www.youtube.com Session Marketing
remote_sid www.youtube.com Session Marketing
requests www.youtube.com Session Marketing
ServiceWorkerLogsDatabase#SWHealthLog www.youtube.com Persistent Marketing
TESTCOOKIESENABLED www.youtube.com 1 day Marketing
VISITOR_INFO1_LIVE www.youtube.com 180 days Marketing
YSC www.youtube.com Session Marketing
yt.innertube::nextId www.youtube.com Persistent Marketing
YtIdbMeta#databases www.youtube.com Persistent Marketing
yt-remote-cast-available www.youtube.com Session Marketing
yt-remote-cast-installed www.youtube.com Session Marketing
yt-remote-connected-devices www.youtube.com Persistent Marketing
yt-remote-device-id www.youtube.com Persistent Marketing
yt-remote-fast-check-period www.youtube.com Session Marketing
yt-remote-Sesyjny-app www.youtube.com Session Marketing
yt-remote-Sesyjny-name www.youtube.com Session Marketing