INFORMATION ON PROCESSING BY THE IMPERIAL CAPITAL SPÓŁKA Z O.O. PERSONAL DATA IN CONNECTION WITH THE PREPARATION, CONCLUSION AND PERFORMANCE OF BOOKING, PRELIMINARY AND DEVELOPMENT AGREEMENTS.
If you want to obtain information about all the rules of personal data processing by us, please read our privacy policy, which is available on the website www.imperialcapital.pl
From May 25, 2018, Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and the repeal of Directive 95/46 apply in Poland. / WE (hereinafter "GDPR"). Therefore, we present the following information required by the GDPR and regarding the processing of personal data.
In this information, we use the following phrases:
Imperial - Imperial Capital Sp. z o.o. based in Krakow;
Company from the Imperial Group - a company related personally or by capital to Imperial, which is understood as the companies listed in detail in the privacy policy available on the website www.imperialcapital.pl
We, the Administrator - Imperial Capital limited liability company
Client – an individual whose personal data is processed by the Administrator for at least one purpose listed in this information.
Who is a personal data administrator of a client?
The Administrator, or the entity that decides how the personal data of a client will be used, is Imperial Capital with its headquarters on Wadowicka Street 7 in Cracow, entered into the National Court Register kept by the District Court in Cracow, 11th Commercial Department – National Court Register under the KRS number 534246.
How to contact us?
Address the correspondence to Wadowicka Street 7, 30-347 Cracow or send an e-mail to biuro@imperialcapital.pl
Where do we receive Client’s personal data from?
We received information directly from the Client due to their decision to sign and implement a development agreement, reservation or preliminary agreement, or from Imperial company whom we delegated the process of data collecting for signing and implementing development agreements.
What is the purpose, basis and time of processing the Client’s personal data by the Administrator?
Client’s personal data is used for the following purposes:
- preparation, conclusion and implementation of reservation, preliminary and development agreements with the Client (legal basis: Article 6 paragraph 1 (b) of the GDPR) - for the period of the preparation and duration of the contract, as well as possible claims after its termination (pursuing claims and defense against them);
- performing our legal obligations (legal basis: Article 6 paragraph 1 c of the GDPR), e.g.
• issuing and storing invoices and accounting documents,
• ensuring network and IT system security,
• keeping trust accounts,
• audits of financial statements
- for the period of legal obligations, e.g. issuing an invoice, storing an invoice, and the duration of the audit.
- performing a legitimate interest pursued by us or by third parties (legal basis: Article 6 paragraph 1 f of the GDPR). However, we will not process the Client's personal data in a situation when it turns out that the Client's interests or his fundamental rights and freedoms will override our interests and the interests of a third party. These purposes include:
• providing data to entities and persons for the proper preparation and implementation of the agreement with the Client, e.g. notary, property manager – for the period of activities performing and archiving them in accordance with the law,
• transferring of data within the group of companies – the Imperial Group (legal basis: Article 6 paragraph 1 f of the GDPR in connection with Article 48 of the GDPR; the updated list of companies is available at www.imperialcapital.pl in the privacy policy – for the period of their processing by the Administrator,
• determining, investigating or defending in matters of claims or the rights of the Administrator – until the termination of possible claims and rights,
• performing of the assignment of receivables – for the period needed to implement the agreement and pursue claims,
• sharing data with Banks and entities in which or through which financing of the purchase of real estate from the Imperial Group may be provided - for the duration and duration of the agreement, ensuring the security of data, network and IT system, which does not result from obligations imposed by law, but from additional rules adopted by us – for the period of implementation and operation of the rules,
• conducting statistical analysis – for the period required for activities to be performed,
• providing answers to questions addressed to us during a phone conversion, and contacting the Client again if needed for preparation, conclusion and implementation of the development agreement – for the period of agreement preparation and implementation, and also possible claims after its termination (pursuing claims, as well as defending against them);
• conducting audits for our needs – for the period required for activities to be performed
• direct marketing until the objection is raised, and no longer than the period of the expiration of the possible claims;
What types of the Client’s personal data do we process?
For the purposes named above, we gather the identification information of a client which is required for the preparation, conclusion and implementation of the agreement such as name and surname, parents’ names, home address, correspondence address, PESEL number, series and number of an identity document, marital status, e-mail address and telephone number.
Who is the receiver of the client’s personal data?
- Imperial
- companies from the Imperial Group when there are law determined purposes for sharing personal information for internal administration needs of the Imperial Group;
- entities to which we delegate services connected with persona data processing (processor), those will be for instance entities providing and administrating IT systems, and also entities in which or through which financing of the client’s agreement with us can be provided;
- our partners (entities that use the received personal data for their own purposes) e.g. a bank keeping a trust account;
- other data receivers – e.g. banks, tax advisers, law firms, notaries, postal and courier companies, etc.
Must a Client provide their personal data to us?
No, but it is necessary if they want to sign an agreement with us.
Will the Client’s data go beyond the European Economic Area (EEA)?
Currently, we do not plan to transfer the Client’s data outside the EEA. But it may turn out that during the duration of the agreement, we will decide to transfer data outside the EEA – only to the extent permitted by law. Up-to-date information on whether and how we transfer the Client’s data outside the EEA is available at www.imperialcapital.pl in the privacy policy.
What rights does a Client have?
Clients have the following right due to processing their personal data by us. They can be used as well as more details can be received by contacting us.
The Client’s rights are:
- the right to request access to their personal data from us and the right to rectify or delete it ("the right to be forgotten");
- the right to object to the processing of personal data for direct marketing purposes, which causes the cessation of the client’s personal data used for direct marketing;
- the right to object for reasons related to the specific situation of the client, if we process the client's personal data on the basis of a legitimate interest. However, we will continue to process personal data to the necessary extent, if there is a legitimate reason on our side;
- the right to transfer data processed in the process of the agreement implementation or on the basis of the client’s consent and the right to limit data processing;
Who is the supervisory authority and can the Client submit a complaint?
If the Client believes that the processing of their personal data by us violates the law, they may submit a complaint with the supervisory body that deals with personal data protection. In Poland, it is the President of the Personal Data Protection Office.
