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Privacy Policy

This document (“Policy”) is intended to explain how Brain Embassy (“We”) processes your personal information when you visit our website at www.brainembassy.com (the “Website”).

We process your personal information for specific purposes, but always with concern for your privacy. This Policy is intended to help you understand what data is collected, for what purposes it is used, and how you can exercise your rights under Regulation 2016/679 (“GDPR”).

You may contact us at [email protected] or in accordance with the provisions of paragraph 8 of this Policy regarding data processing in connection with your visit to the Website.

1. DATA CONTROLLERS

The controllers of your personal data are:

  1. Adgar Investment and Development with its registered office at Efal 35 Petach Tikva; Tax Identification Number: 520035171;(hereinafter referred to as “BE Israel”);
  2. Real Estate Solutions spółka z ograniczonÄ… odpowiedzialnoĹ›ciÄ… sp.k. 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. Brain Embassy Belgium with its registered office at Molenbergstraat 10, 2000 Antwerpen; Tax Identification Number: BE0731.710.590; (hereinafter referred to as “BE Belgium”)

(BE Poland, BE Israel and BE Belgium together as “BE”).

BE Poland, BE Israel and BE Belgium are joint controllers of your personal data gathered with the use of cookies and similar technology and processed to analyze the way you use our Website. BE Poland, BE Israel and BE Belgium have agreed that:

  1. BE Poland will inform the categories of personal data subjects indicated above about the processing of their personal data by the joint controllers (this Policy is an expression of the implementation of this agreement)
  2. BE Poland shall be responsible for the implementation of the rights of the data subjects referred to in paragraph 6 below
  3. any questions regarding the processing of personal data by the joint controllers, data subjects may address to BE Poland by correspondence or e-mail at [email protected]

If you have filled out our contact form:

  1. concerning Brain Embassy location in Israel – the data controller is BE Israel
  2. concerning Brain Embassy location in Belgium – the data controller is BE Belgium
  3. concerning Brain Embassy location in Poland – the data controller is BE Poland

2. WHAT DATA WE COLLECT AND PROCESS

If you are a user of the Website, BE collects your personal data contained among others in cookies, including in particular your IP address.

If you are a user of the Website who submitted contact form 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 Brain Embassy.

3. WHY AND ON WHAT BASIS WE PROCESS YOUR DATA

If you are a user of the Website, BE processes your personal data on the basis of legitimate interests (Article 6(1)(f) GDPR), including in particular:

  1. to use analytics and profiling tools to tailor the Website to your needs (personalization), to tailor the content displayed (including advertisements) to your interests and the way you use the online services and technologies we provide;
  2. to assist in the diagnosis of technical problems;
  3. to operate online services and technologies;
  4. to identify users online;
  5. to identify devices for abuse prevention purposes;
  6. to collect demographic information about users of the Website;
  7. to determine usage patterns of the Website;
  8. to conduct advertising campaigns
  9. to ensure network and system security.

If you are a user of the Website who has made an inquiry about one of Brain Embassy’s locations, BE Poland, BE Israel or BE Belgium processes personal data:

  1. on the basis of your consent (as long as it is a valid and effective basis for processing) for marketing purposes, including in particular to communicate with you about products and services related to the location in which you have expressed an interest (Article 6(1)(a) of the GDPR).
  2. on the basis of a legitimate interests of the controller (Article 6(1)(f) of the GDPR) of handling your inquiry, ensuring security and defending against claims, direct marketing, as well as for internal administrative purposes of its own and other Group entities such as performing analysis and reporting.

4. WHO WE SHARE YOUR DATA WITH

If necessary to fulfil the purposes indicated in paragraph 3. of this Policy, BE Poland, BE Israel or BE Belgium may transfer them:

  1. to entities entitled to receive them under the law (e.g. law enforcement agencies, supervisory authorities, etc.)
  2. entities that process personal data on our behalf, e.g. companies that provide consulting, IT or marketing services to us;
  3. other entities that are part of the Adgar group of companies to which BE belongs;
  4. our trusted business partners.

In the course of processing your personal data, there may be a transfer to a third country within the meaning of the GDPR, in particular to the State of Israel. In any transfer of your data outside the EEA, we will ensure the highest level of security. In addition, we would like to inform you that in accordance with the European Commission Decision No. 2011/61/EU of January 31, 2011 issued pursuant to Directive 95/46/EC of the European Parliament and of the Council, on the adequate protection of personal data, the State of Israel, with regard to automated processing of personal data, provides an adequate level of protection. The text of the decision is available at: https://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32011D0061.

5. HOW LONG WE STORE THE DATA

Your data is stored 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).

In any case your data will not be processed for a longer period if you withdraw your consent and BE has no other legal basis for processing.

6. WHAT RIGHTS TO YOU HAVE

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:

  1. 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;
  2. you can demand access to your personal data and obtain its copy;
  3. 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;
  4. you can demand correction of your personal data if it is incorrect or incomplete;
  5. 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 objection against your data being processed for direct marketing purposes;
  6. 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;
  7. 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, pursue 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:

  1. BE Belgium – [email protected];
  2. BE Israel – [email protected];
  3. BE Polska – [email protected]

BE Poland has appointed a Data Protection Officer with whom you can contact at [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 Poland – President of the Personal Data Protection Office.

BE Belgium – Autorité de protection des données Gegevensbeschermingsautoriteit (Belgian Data Protection Authority);

BE Israel – Israeli Law, Information and Technology Authority (ILITA);