PRIVACY POLICY
Last updated: November 17, 2024
The privacy of users of the Gecko Real Estate Group website located at/ is of great importance to us. Therefore, we publish a document explaining the principles and methods of collecting, processing and using information about users of these websites.
§ 1
DEFINITIONS
Administrator: Magdalena Ringel operating as a sole proprietorship under the name Negrin Magdalena Ringel with headquarters in Warsaw (registered office address: ul. Jarosława Dąbrowskiego 85/20, 02-503 Warsaw), registered in the Central Register and Information on Economic Activity (CEIDG), maintained by the Minister of Development and Technology, NIP: 836 175 65 28, REGON: 141029773
Personal data: all information about an identified or identifiable natural person through one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person, including device IP addresses, email addresses, location data, online identifiers and information collected through cookies or other similar technologies.
Policy: this "Privacy Policy", applicable to the Gecko Real Estate Group Service.
GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
Service: the Gecko Real Estate Group website published by the Administrator, to which this Privacy Policy applies, available in the internet domains listed below:
User: any natural person visiting the Service or using one or more services or functionalities available in the Service.
Trusted Partners: entities with which the Administrator cooperates in creating the Service, including advertisers, intermediaries, entities operating in the online market, research companies, including entities acting as joint controllers.
Joint Controller: an entity cooperating with the Administrator, with which the Administrator jointly determines the purposes and methods of processing Personal Data.
Profiling: automated processing of Personal Data, which consists of using Personal Data to evaluate certain personal factors of a natural person.
§ 2
FOR WHAT PURPOSE AND ON WHAT LEGAL
BASIS WE PROCESS YOUR DATA
In connection with using our Service, we collect and process your Personal Data. Below you will find detailed principles and purposes of processing your Personal Data:
a)
to provide access to content collected in the Service – in this case, the legal basis for processing is the necessity for the proper performance of a contract to which the Service User is a party (Art. 6(1)(b) GDPR);
b)
for analytical and statistical purposes – in this case, the legal basis for processing is our legitimate interest (Art. 6(1)(f) GDPR), consisting of conducting analyses of Users' activity and their preferences, in order to improve the functionalities used and services provided;
c)
to establish, pursue or defend against claims – the legal basis for processing is our legitimate interest (Art. 6(1)(f) GDPR) consisting of protecting our rights;
d)
for marketing purposes of ours and other entities – the principles of processing Personal Data for marketing purposes are described below in the MARKETING section.
Your activity in the Service, including your Personal Data, is recorded in system logs (a special computer program used to store a chronological record containing information about events and actions related to the information system used to provide services) and through analytical scripts. We use this Data primarily for purposes related to providing our services, for technical and administrative purposes, to ensure the security of the information system and its management, as well as for analytical and statistical purposes. In the above scope, the legal basis for processing Personal Data is our legitimate interest (Art. 6(1)(f) GDPR) consisting of ensuring the security and efficient operation of our services.
HANDLING INQUIRIES SUBMITTED BY CLIENTS
Using the form requires providing Personal Data marked as mandatory. Failure to provide them results in the inability to process the inquiry. Providing other Data is optional.
Personal Data provided in the form are processed:
a)
to identify the sender and handle the matter described in the form – the legal basis for processing is the necessity of processing to perform a contract (Art. 6(1)(b) GDPR), and for Data provided optionally – the legal basis for processing is consent (Art. 6(1)(a) GDPR);
b)
for analytical and statistical purposes – the legal basis for processing is our legitimate interest (Art. 6(1)(f) GDPR), consisting of conducting statistics of matters reported by Users through the Service, including to improve its functionality.
The Administrator will process the above personal data until an effective objection is raised or the purpose of processing is achieved (depending on which of the mentioned events occurs first).
MARKETING
We process your Personal Data to carry out marketing activities, which may include:
a)
displaying marketing content to you independent of your preferences (including standard advertising);
b)
displaying marketing content corresponding to your interests (behavioral advertising);
c)
sending email notifications about interesting offers or content, which in some cases contain commercial information (newsletter service);
d)
conducting other types of activities related to direct marketing of goods and services (sending commercial information by electronic means).
To carry out marketing activities, in some cases we use Profiling. This means that through automated processing of Data, we evaluate your selected behaviors or create predictions of your future behaviors.
Reklama standardowa
Standard advertising is advertising independent of User preferences. In the case of such advertising, Personal Data are processed for marketing purposes in connection with the realization of our legitimate interest (i.e., on the basis of Art. 6(1)(f) GDPR) consisting of the realization of contracts with our contractors.
Reklama behawioralna
Behavioral advertising is advertising that is tailored to User preferences. Displaying behavioral advertising to you is based, among other things, on Profiling, i.e., the use of your Personal Data collected through cookies and other similar technologies. Profiling for marketing purposes by us takes place provided that you give consent (i.e., it takes place on the basis of Art. 6(1)(a) GDPR). This consent is voluntary. Consent may also be expressed through an act of unambiguous action confirming the expression of consent indicated in the message displayed in the window in the consent collection process. You can withdraw your consent at any time, but withdrawal of consent does not affect the legality of Profiling for marketing purposes before its withdrawal.
Newsletter
We provide newsletter service to persons who have provided their email address for this purpose. Providing the data indicated when subscribing to the newsletter (email address) is voluntary but necessary to send the newsletter.
Personal Data are processed:
a)
to provide the newsletter sending service – the legal basis for processing is the necessity of processing to perform a contract (Art. 6(1)(b) GDPR);
b)
in the case of directing marketing content to the User within the newsletter – the legal basis for processing, including Profiling, is our legitimate interest (Art. 6(1)(f) GDPR) consisting of promoting our services and products as well as services and products of our partners;
c)
for analytical and statistical purposes – the legal basis for processing is our legitimate interest (Art. 6(1)(f) GDPR) consisting of conducting analyses of Users' activity in the Service, in order to improve the functionalities used;
d)
to establish, pursue or defend against claims – the legal basis for processing is our legitimate interest (Art. 6(1)(f) GDPR) consisting of protecting our rights.
Direct Marketing
Direct marketing conducted via email requires your consent, provided for in the regulations governing such marketing activities (Art. 172 of the Act of July 16, 2004, Telecommunications Law, Art. 10(2) of the Act of July 18, 2002 on the provision of services by electronic means). If you give such consent, the legal basis for processing personal data for the purpose of conducting direct marketing is our legitimate interest consisting of conducting direct marketing, to which you have given consent (Art. 6(1)(f) GDPR) and promoting products and services of our own or our partners, resulting from the above consent. You can withdraw your consent at any time. However, withdrawal of consent does not affect the legality of processing your Data for direct marketing purposes before its withdrawal. To withdraw consent, use the functionalities provided by us or contact us according to the Data provided in the Service.
SOCIAL MEDIA
We process Personal Data of Users visiting our profiles maintained on social media (Facebook, YouTube, Instagram, TikTok). This Data is processed solely in connection with maintaining the profile, including to inform Users about our activity and promote various types of events, services and products. The legal basis for processing Personal Data for this purpose is our legitimate interest (Art. 6(1)(f) GDPR), consisting of promoting our own brand. Social media plugins are used in the Services. Plugins allow the User, among other things, to share content published in the Service on a selected social media platform. Using plugins causes a given social media service to receive information about the User's use of the Service and may assign it to the User's profile created on that social media platform. To the extent that we use Facebook tools (e.g., by placing a plugin on the page such as "Like" or "Share"), joint administration of Users' Personal Data occurs between us and Facebook Ireland Limited. More information about Facebook and agreements between joint controllers (including the scope of their responsibilities) can be found at:
https://www.facebook.com/legal/terms/
§ 3
WEB-PUSH NOTIFICATIONS
User's Personal Data (generated on the basis of cookies or similar technologies) may, with their consent, be processed for the purpose of sending web-push notifications. Web-push notifications are short messages that appear on the User's device, containing information about content available in the Service or marketing messages.
The basis for processing Data for the purpose of sending web-push notifications is consent given by the User (Art. 6(1)(a) GDPR).
To decide on web push notifications – to give or refuse consent – you should select the appropriate button available in the displayed window asking about the desire to receive notifications. When sending web push notifications, in some cases we may use Profiling. This means that through automated processing of Data, we evaluate selected User behaviors or create predictions of their future behaviors.
Consent given can be withdrawn at any time. However, withdrawal of consent does not affect the legality of processing Data before its withdrawal. To withdraw consent, you should disable web-push notifications using the settings of the browser used. If you need help, please contact us according to the data provided in the Service. Changing settings regarding web push notifications made within a given browser will be saved only for that browser. To decide on notifications within other browsers, you should make appropriate settings within each browser.
§ 4
PERIOD OF PROCESSING PERSONAL DATA
The period of processing Data depends on the type of service provided and the purpose of processing. As a rule, Data are processed for the duration of the service or order fulfillment, until withdrawal of expressed consent or submission of an effective objection or effective request for deletion of Data.
The period of processing Data may be extended if processing is necessary to establish, pursue or defend against claims, and after this period, only if and to the extent required by law.
§ 5
YOUR RIGHTS
You have the right to: access the content of your Data and request their rectification, deletion, restriction of processing, the right to transfer Data to another controller and the right to object to processing of Data, as well as the right to lodge a complaint with the supervisory authority dealing with personal data protection, i.e., the President of the Personal Data Protection Office.
To the extent that your Data are processed on the basis of consent, it can be withdrawn at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal. To change privacy settings, give consent or withdraw it, use the widget visible on the Service website or contact the Administrator via email at office@gecko-re.com.
Right to object
You have the right to object to the processing of your Data at any time:
a)
for direct marketing purposes;
b)
for reasons related to your particular situation in cases where the legal basis for processing your Data is our legitimate interest (e.g., our marketing, statistical, analytical purposes), i.e., when your Data are processed on the basis of Art. 6(1)(f) GDPR;
To submit an objection, contact us via email at office@gecko-re.com
§ 6
DATA RECIPIENTS
The recipients of personal data will be the following external entities cooperating with the Administrator:
a)
hosting company;
b)
newsletter service provider;
c)
companies providing tools for analyzing activity in the Store and directing direct marketing to persons using it (including Google Analytics);
d)
company handling the website in terms of content administration and User support.
e)
company providing accounting services;
f)
company providing legal services.
In addition, personal data may also be transferred to public or private entities if such an obligation results from generally applicable legal provisions, a final court judgment or a final administrative decision.
§ 7
JOINT ADMINISTRATION
Below is a list of entities that are joint controllers of Personal Data with the Administrator in selected areas:
1. MailerLite Limited
2. Facebook Ireland Limited
§ 8
TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
It is possible that we will transfer your Data outside the European Economic Area (EEA) – in particular to social media administrators. Such transfer will occur only when an appropriate level of protection of your Data is ensured, which will be confirmed in particular by:
a)
cooperation with entities processing personal data in countries for which an appropriate decision of the European Commission has been issued
b)
application of standard contractual clauses issued by the European Commission;
c)
application of binding corporate rules approved by the competent supervisory authority.
Upon your request, we will provide you with a copy of your Data that will be transferred outside the EEA.
§ 9
PERSONAL DATA SECURITY
We continuously conduct risk analysis to ensure that Personal Data are processed by us in a secure manner, ensuring above all that only authorized persons have access to Data and only to the extent necessary due to the tasks they perform. We ensure that all operations on Personal Data are recorded and performed only by authorized employees and collaborators.
We take all necessary measures to ensure that our subcontractors and other cooperating entities also guarantee the application of appropriate security measures in every case when they process Personal Data on our behalf.
§ 10
RIGHTS
In connection with the processing of personal data, you have the following rights:
1.
the right to information about what personal data concerning you are processed by the Administrator and to receive a copy of such data (the so-called right of access). Issuing the first copy of data is free, for subsequent copies the Administrator may charge a fee;
2.
if the processed data become outdated or incomplete (or otherwise incorrect), you have the right to request their rectification;
3.
in certain situations you can request the Administrator to delete your personal data, e.g., when:
a)
the data will no longer be needed by the Administrator for the purposes for which it was informed;
b)
you have effectively withdrawn consent to process data – provided the Administrator does not have the right to process data on another legal basis;
c)
processing is unlawful;
d)
the need to delete data results from a legal obligation incumbent on the Administrator;
4.
in the case where personal data are processed by the Administrator on the basis of consent given for processing or to perform a Contract entered into with him, you have the right to transfer your data to another controller;
5.
in the case where personal data are processed by the Administrator on the basis of consent given by you for processing, you have the right to withdraw this consent at any time (withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal);
6.
if you consider that the processed personal data are incorrect, their processing is unlawful, or the Administrator no longer needs specific data, you may request that for a specified, necessary period (e.g., to verify the correctness of data or pursue claims) the Administrator does not perform any operations on the data, but only stores them;
7.
you have the right to object to the processing of personal data, the basis of which is the legally justified interest of the Administrator. In the event of an effective objection, the Administrator will cease processing personal data for the above purpose;
8.
you have the right to lodge a complaint with the President of the Personal Data Protection Office when you consider that the processing of personal data violates the provisions of GDPR.
§ 11
COOKIES
1.
The Administrator informs that the Service uses "cookies" installed on your terminal device. These are small text files that can be read by the Administrator's system, as well as by systems belonging to other entities whose services the Administrator uses (e.g., Facebook, Google).
2.
The Administrator uses cookies for the following purposes:
a)
ensuring proper operation of the Service – thanks to cookies, it is possible for the Service to operate smoothly, use its functions and conveniently navigate between individual pages;
b)
increasing the comfort of browsing the Service – thanks to cookies it is possible to detect errors on some pages and constantly improve them;
c)
creating statistics – cookies are used to analyze how users use the Service. This makes it possible to constantly improve the Service and adapt its operation to user preferences;
d)
conducting marketing activities – thanks to cookies, the Administrator can direct advertisements to users tailored to their preferences.
3.
The Administrator may place both permanent and temporary (session) files on your device. Session files are usually deleted when the browser is closed, while closing the browser does not cause permanent files to be deleted.
4.
Information about cookies used by the Administrator is displayed in the panel located at the bottom of the Service website. Depending on your decision, you can enable or disable cookies of individual categories (except for necessary cookies) and change these settings at any time.
5.
Data collected through cookies does not allow the Administrator to identify you.
6.
Detailed information about the types of cookies used by the Administrator can be found in the panel displayed on the Service website. You can access the panel at any time using the widget visible on the Service website.
7.
Through most commonly used browsers, you can check whether cookies have been installed on your end device, as well as delete installed cookies and block their installation in the future by the Service. However, disabling or limiting cookie support may cause quite serious difficulties in using the Service, e.g. in the form of a longer loading time of the Service page, limitations in using some functionalities or complete inability to use the Service.
§ 12
CONTACT DATA
1.
In matters not regulated by the Policy, the generally applicable provisions on personal data protection apply.
2.
In all matters related to the processing of personal data, you can contact the Administrator by email at: office@gecko-re.com.