PRIVACY AND COOKIES POLICY OF RONSON DEVELOPMENT MANAGEMENT SP. Z O.O. AND RONSON GROUP COMPANIES

PRIVACY AND COOKIES POLICY
RONSON DEVELOPMENT MANAGEMENT SP. Z O.O.
AND RONSON GROUP COMPANIES

1. What does this policy describe?

This privacy policy (the “Policy“) contains information about the processing of personal data by Ronson Development Management sp. z o.o. and other companies of the Ronson Group, i.e. companies that are related by equity to Ronson Development SE of Warsaw:

We want it to be clear to you whether this Policy also covers the processing of your personal data. The Policy applies if:

We process your personal data in accordance with the European Union General Data Protection Regulation (2016/679) (“GDPR“) and other applicable data protection laws that supplement and/or implement the GDPR.

2. Who is the controller of your personal data

The controller of your data is Ronson Development Management sp. z o.o. with its registered office in Warsaw, 57 Komisji Edukacji Narodowej Avenue, 02-797 Warsaw, and if you are the Buyer of the Properties or its Representative, the Controller of your data is also the Ronson Group company with which you enter into the development agreement or the Properties Sales Agreement (collectively, the “Controller“, “Ronson“, “we“).

In matters related to the processing of personal data, you can contact us by mail or e-mail – marketing@ronson.pl

In order to increase the level of protection of personal data, we have appointed a Data Protection Officer. This function is performed by Pawel Latkowski. You can contact our IOD at the following email address: iod@ronson.pl

3. What information do we collect about you?

If you are a Candidate, we collect information contained in your application documents, provided to us during interviews, email exchanges and meetings. These include, in particular, your name, contact information, information about your education, work experience, qualifications, language skills and interests.

If you are a Potential Buyer of the Properties, we collect information provided to us through forms on the Website and recorded during your use of the Website, as well as information provided to us through other forms of contact. These include, in particular, your first name, last name, contact information: e-mail address or telephone number, and IP address.

If you are a User of the Website, we collect information about your use of the Website, derived, among other things, from cookies stored on your device. These include, in particular, your IP address and other data contained in cookies.

If you use the eBOK, we collect the information you provide in the contact form – otherwise, the information available in the eBOK is related to the contract between you and Ronson.

If you are the Buyer of the Properties or the Representative of the Buyer of the Properties, we collect information provided to us in the documents you send us, in the course of conversations (including through the hotline), e-mail exchanges and meetings, including in particular information necessary for the conclusion and execution of the contract. This may include, in particular, your name, surname, residential address, PESEL, ID card number, bank account number.

If you are a Contractor or Contractor’s Representative, we collect information provided to us through contact forms, conversations, email exchanges, meetings. This may include, in particular, your name, surname, registered office address, tax ID number, REGON number, contact details, position, data concerning the entity you represent, data needed for us to conclude a contract with this entity, if necessary for this purpose. Your data may also be provided to us by the entity you represent both before and in the course of cooperation with us.

4. For what purpose and on what basis we process your data

If you are a Candidate, we process your personal data:

  1. with your consent (Article 6(1)(a) of the GDPR) for recruitment purposes;
  2. for the purpose of entering into and performing an employment or cooperation contract (Article 6(1)(b) of the GDPR);
  3. in order to fulfill Ronson’s legal obligations as an employer and the corresponding entitlements of an applicant for employment under the law, including labor laws or tax regulations (Article 6(1)(c) of the GDPR);
  4. in order to realize the legitimate interests of the Data Controller, i.e. for the purposes of internal administration, ensuring security, as well as handling possible claims (Article 6(1)(f) GDPR).

If you are a Potential Buyer of the Properties, we process your personal data:

  1. with your consent (Article 6(1)(a) of the GDPR), for the purposes of direct marketing of our products and services, including the products and services of Ronson Group entities, in accordance with the content of your consent;
  2. for the legitimate interest of the Controller and other Ronson Group entities (Article 6(1)(f) of the GDPR), e.g. when creating compilations, analyses, statistics, reports, marketing research, planning the development of offerings or products, for security purposes.

If you are a User of the Website, we process your personal data:

  1. with your consent (Article 6(1)(a) of the GDPR), for marketing, analytical or statistical purposes in accordance with your consent via the cookie banner;
  2. for the legitimate interest of the Controller and other Ronson Group entities (Article 6(1)(f) of the GDPR), e.g. when creating compilations, analyses, statistics, reports, marketing research, planning the development of offerings or products, for security purposes

If you are the Buyer of the Properties or the Representative of the Buyer of the Properties, we process your personal data:

  1. For the purpose of entering into and performing a contract (Article 6(1)(b) of the GDPR);
  2. in order to perform the Controller’s legal obligations (Article 6(1)(c) of the GDPR);
  3. for the legitimate interest of the Controller and other Ronson Group entities (Article 6(1)(f) GDPR), i.e. in connection with the conclusion and performance of a contract, for the purposes of claims, for administrative, statistical, reporting purposes, for purposes related to customer service and improving its quality, as well as direct marketing of products and services of the Controller and Ronson Group companies.

If you use eBOK, we process your personal data:

  1. for the purpose of creating an Account and granting access to eBOK and providing services via eBOK, i.e. for the purpose of concluding and performing an agreement for the provision of electronic services (Article 6(1)(b) GDPR);
  2. for the legitimate interest of the Controller and other Ronson Group entities (Article 6(1)(f) GDPR), i.e. contact in connection with the services provided, ensuring the proper operation of the eBOK, ensuring the proper level of services provided, ensuring the security of the eBOK or marketing Ronson products.

If you are a Contractor or Contractor’s Representative we process your personal data:

  1. For the purpose of entering into and performing a contract (Article 6(1)(b) of the GDPR);
  2. in order to perform the Controller’s legal obligations (Article 6(1)(c) of the GDPR);
  3. for the legitimate interest of the Controller and other Ronson Group entities (Article 6(1)(f) GDPR), i.e. in connection with the conclusion and performance of a contract, for claims purposes, for administrative, statistical, reporting purposes.

5. To whom we share your data

When it is necessary for the purposes for which we process your data, we may transfer it:

  1. To entities authorized to receive them under the law (e.g., law enforcement agencies, supervisory authorities, etc.);
  2. entities that process personal data on our behalf, i.e. companies that provide us with certain services, the performance of which involves the processing of personal data. e.g. subcontractors, entities operating our IT systems or providing us with ICT tools, entities providing us with accounting, consulting, advisory, marketing or recruitment services;
  3. to other entities within the Ronson Group to which we belong, i.e. entities with capital ties to Ronson Development SE of Warsaw.

6. How long we keep your data

We retain your information for the period of time necessary to fulfill the purposes outlined in this privacy policy and in accordance with our data retention policies (unless a longer period is required by applicable law). Our data retention policies are based on the provisions of applicable law. We will retain and use your information to the extent necessary to comply with legal requirements (e.g., if we are required to retain your information for tax purposes), resolve disputes, perform a contract or settlement, or for the purpose set forth in this privacy policy.

If you are a Candidate, we will keep your data until the end of the recruitment process and, if you have consented to its processing in future recruitment processes, for the longest time until you revoke your consent.

If you are a Potential Buyer of the Properties or a User of the Website, we will retain your data for as long as it is useful for marketing purposes, the longest until you withdraw your consent or object to the processing.

If you are the Buyer of the Properties or the Representative of the Buyer of the Properties, we keep your data for as long as we are required to do so by law and for the period specified by the statute of limitations for claims, and in the case of call recordings – for a period of 3 months.

If you use eBOK, we keep your data for as long as you have an eBOK account.

If you are a Contractor or Contractor’s Representative, we keep your data for as long as we are required to do so by law and for the period specified by the statute of limitations for claims.

7. What rights you have

When exercising your rights regarding the processing of your personal data, you may direct the following requests to us:

  1. if we process your personal data on the basis of your consent, you may withdraw that consent at any time; however, please note that withdrawal of consent does not affect the lawfulness of the processing we performed on the basis of your consent prior to its withdrawal;
  2. You may request access to and obtain a copy of your personal information;
  3. you may exercise your right to portability of your personal data, i.e., you may request that we obtain your data in a structured, commonly used machine-readable format, and you may also request that we send the data directly to another controller if we process it by automated means based on your prior consent;
  4. You may request that your personal information be corrected if it is incorrect or incomplete;
  5. based on your particular situation, you may object to the processing of your personal data if we process it citing our legitimate legal interest; you may also object to the processing of your data for direct marketing purposes;
  6. In the cases stipulated by law – e.g., if your data is outdated, redundant, processed unlawfully, and if you have withdrawn your consent to its processing (when consent was the basis for such processing) or successfully raised an objection to the processing of your personal data – you may request the erasure of your personal data;
  7. You may also request a restriction of data processing for the duration of our processing of your objection or request regarding the correctness of your personal data, the lawfulness of the processing of your data or our legitimate interest, or if the data is needed by you to establish, assert or defend claims.

To exercise the above rights, contact us by mail or email at marketing@ronson.pl. You may also contact our Data Protection Officer at the following email address: iod@ronson.pl.

Whenever you consider that our processing of your personal data violates the provisions of the GDPR, you also have the right to lodge a complaint with the President of the Office for Personal Data Protection (PUODO).

8. Do you have to give us your data

If you are a Candidate, the data you provide is completely voluntary, however, without it, we will not be able to consider your candidacy in ongoing recruitments.

If you are a Potential Buyer of the Properties, the data you provide is completely voluntary, however, without this data it will not be possible to use the marketing contact form, provide you with an offer and conduct other marketing activities.

If you are a User of the Website, it is completely voluntary for you to provide data, however, without such data, it will not be possible to use certain functionalities of the Website.

If you are the Buyer of the Properties or the Representative of the Buyer of the Properties, the data you provide is necessary for the conclusion of the contract and business relationship. If you are the Website Buyer‘s Representative, you did not provide us with your data personally, it was provided to us by the entity you represent, or it comes from publicly available sources.

If you use the eBOK, your data comes from your contracts with Ronson and interactions with Ronson, and is otherwise provided by you when you contact Ronson.

If you are a Contractor or Contractor’s Representative, the data you provide is necessary to enter into a contract and maintain business relations. If, being a Contractor’s Representative, you have not provided us with your data personally, it has been provided to us by the entity you represent, or it comes from publicly available sources.

COOKIE POLICY

1. Cookies and other monitoring technologies: Definition

A “cookie” is a text file that a Web Website sends to a visitor’s computer or other Internet-connected device to identify the visitor’s browser, or to store information or settings in the Web browser. A cookie usually contains the name of the domain from which it was sent, the “lifetime” of the cookie, and a randomly generated unique identifier.

We may use other technologies, including web beacons and JavaScript, which in some cases work in conjunction with cookies and other means with our Website to identify your device. These other technologies allow us to activate certain features on our Website. We may also use certain technologies to determine whether an email we have sent you has been opened or whether a link in it has been clicked on by you.

2. How we use cookies

When you use our network services, we and others (such as advertising networks) may obtain information about you about your use of the network, your use of the network over time, and your use of sites operated by third parties.

We use cookies for various purposes. For example, we monitor the total number of visitors to our Website – on an anonymous and aggregated basis. We may also use cookies to be able to remember you if you visit the Website again and to personalize the Website according to your preferences. In this situation, certain information about you, which may constitute personal information, may be associated with the cookie.

Monitoring technologies may be permanent (i.e., files remain on your computer or device until you delete them) or session-based (i.e., files remain only until you close your browser).

In particular, our website uses the following types of cookies:

3. Setting and deleting cookies

In your browser settings, you can block the receipt of cookies or set your browser so that every time you receive a cookie you will be notified.

Note, however, that blocking cookies completely may prevent you from using all the features of our Website.

Below are links to resources showing how you can specify the conditions for storing or accessing cookies using the settings of the most popular web browsers

Alternatively, you can also visit http://jakwylaczyccookie.pl/jak-wylaczyc-pliki-cookies/, which provides comprehensive information on how to disable cookies on your browser or device, as well as more general information on cookies. You can find information on how to delete cookies from your cell phone in your phone’s manual. You can also opt out of receiving cookies.

Please note that restricting your ability to receive cookies may affect the functionality of the Website and its appearance.

Due to the multitude of technological solutions, it is not possible to post precise guidelines on how to determine the conditions for storing or accessing cookies through the settings of all available telecommunications terminal devices and software installed on that device. Nevertheless, in most cases, you should go to “Tools” or “Settings” and there find the section responsible for configuring cookie settings or for managing your privacy while browsing the Internet. Detailed information is usually provided by the manufacturer of the device or browser in question in the user manual or on its website.

4. Server logs

Information about certain behaviors of Users is subject to logging in the server layer. This data is used solely for the purpose of administering the Website and to ensure the most efficient operation of the hosting services provided.

The resources viewed are identified by URLs. In addition, the record may be subject to:

  1. time of arrival of inquiry,
  2. time to send a response,
  3. The name of the client station – identification implemented by the http protocol,
  4. information about errors that occurred in the execution of http transactions,
  5. URL of the page previously visited by the user (referer link) – in case the Website was accessed via a link,
  6. User’s browser information,
  7. IP address information.

This data is not associated with specific individuals browsing the Website and is used only for server administration purposes.

Cookies

Manage cookies

We use cookies to ensure the proper functioning of the website. We can also use cookies for analytical purposes, in particular to match advertising content to your preferences. The use of analytical and functional cookies requires consent. If you want to accept all cookies, click “Accept all”. If you do not consent to our use of cookies other than essential cookies, click “Reject all”. If you want to customize your consents, click “Manage cookies”. Remember that you can withdraw any of the expressed consents at any time by changing the selected settings. More information can be found in Privacy Policy.

The use of cookies for the purposes indicated above is related to the processing of your personal data. For more information about our use of cookies and the processing of your personal data, including your rights, please see our Privacy Policy.

These cookies are essential for the operation of the website and cannot be disabled in our systems. They are usually only set in response to actions you make that constitute a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or warn you about these cookies, but some parts of the website will not then work. These cookies do not store any personally identifiable information.

These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is anonymous. If you do not allow these cookies, we will not know when you visited our site and will not be able to monitor its performance.

These cookies may be used by our Trusted Partners to track Users across websites. The purpose is to display advertisements tailored to the preferences of individual Users.