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Contents
Preliminary informatione Asbud as Data Controller Asbud as data processor Obtaining information about the processing of personal data Data acquisition and purpose of processing Is the provision of data mandatory? Data importers Rights to data processing and voluntary nature of data provision Transfer of data to third countries Processing of personal data by automated means Cookie Policy Purpose for which cookies are used What are cookies used for What cookies are used by Asbud How do I change my browser’s cookie settings? What files? Using Google Ads Using Asbot Using CallPage Using Revhunter
Preliminary information
Respecting the right to privacy of the data subjects, Asbud Management sp. z o.o. ensures compliance of personal data processing with the applicable laws.
Asbud as Data Controller
The data controller, i.e., the entity which decides about the purposes and means of the processing of personal data is Asbud Management sp. z o.o. with its registered office in Warsaw, ul. Hrubieszowska 6B lok. B10 (hereinafter: the Data Controller, the DC or Asbud).
Asbud is a development company, specializing in the implementation of residential and office projects, which has been successfully operating on the Polish real estate market for 24 years. The company’s portfolio consists of over 4,000 units and approximately 50,000 m2 of commercial space
Asbud as data processor
Asbud, in certain situations, may also act as a data processor acting for and on behalf of a special-vehicle company of the Group, that sells or leases real estate.
Obtaining information about the processing of personal data
In case of any questions regarding the processing of personal data, the Data Controller invites you to contact it by post (address indicated above) or by e-mail: sekretariat@asbud.com
Data acquisition and purpose of processing
The data controller always processes data legally and securely. This may include data such as:
- data of customers or their employees and associates,
- data of prospective customers,
- data of contractors/suppliers or their employees and associates,
- data of own employees or collaborators.
| Purpose of processing | Legal basis and data retention period |
|---|---|
| Conducting marketing activities, including sales activities to potential customers using electronic or voice communications | Article 6(1)(f) of the GDPR (Polish: “RODO”), while these activities, due to other applicable regulations, in particular the Telecommunications Law and the Act on Provision of Electronic Services, are carried out only on the basis of possessed consents to the communication channel. Until you object or withdraw your consent, i.e., show us in any way that you do not want to be contacted and to receive information about actions taken. |
| Activities aimed at concluding and performing a contract with a customer, including post-sale activities | Article 6(1)(b) of the GDPR concerning customers who are natural persons, and in the case of persons cooperating with the Data Controller on behalf of a customer or being a representative of a customer who is a legal person – on the basis of Article 6(1)(f) of the GDPR. Customer data for this purpose will be processed for the time period specified in the contract or necessary for the Data Controller to perform its duties requiring data processing. |
| Activities aimed at concluding and performing a contract with the Data Controller’s customer, including post-sale activities | Article 6(1)(b) of the GDPR concerning customers who are natural persons, and in the case of persons cooperating with a contractor or being a representative of a contractor who is a legal person on the basis of Article 6(1)(f) of the GDPR. The data for this purpose will be processed for the time period specified in the contract or necessary for the Data Controller to perform its duties requiring data processing. |
| Determining, investigating and defending against claims | Article 6(1)(f) of the GDPR, which indicates the data controller’s legitimate interest. Data for this purpose will be processed until the statute of limitations for any legal claims. Depending on the claim, this deadline may vary. In the case of initiated legal proceedings, the data will be processed until the legal proceedings are legally concluded and then possible enforcement proceedings. |
| Handling complaints, requests and claims. | Article 6(1)(b), (c) and (f) of the GDPR For the duration of the contract or until the warranty expires or the claim is settled. |
| Realization of legal obligations imposed on the Data Controller concerning accounting and bookkeeping records, including archiving documents | Article 6(1)(c) of the GDPR For the periods indicated by law, including the Accounting Act. As a rule, accounting documents are kept for 5 years after the end of the year in which the event to which the accounting document relates occurred. |
| Human resource management – employees and collaborators | For employees: Article 6(1)(a), (b), (c) and (f) of the GDPR and Article 9(2)(b) of the GDPR For collaborators: article 6(1)(b) and (f) of the GDPR.In accordance with current regulations requiring the archiving of employment law documents, i.e., personnel files of employees hired after 1 January 2019 are kept for 10 years. In the case of employees hired after 31 December 1998, and before 1 January 2019, the documentation related to the employment relationship and the employee’s personal files will be kept for 50 years from the date of termination or expiration of the employment relationship, but with respect to those of the above-mentioned employees for whom the employer submits an information report referred to in Article 4(6a) of the Social Security Act of 13 October 1998, the period for keeping the documentation and files is reduced to 10 years from the end of the calendar year in which this report was submitted. In the case of civil law contracts, data shall be processed for the purpose in question for the duration of the contract. |
| Recruitment | For job applicants: Article 6(1)(a) and (c) of the GDPR For candidates for collaborators: Article 6(1)(a) and (b) of the GDPR Data for this purpose will be processed until the end of the recruitment process, and in case of consent for future recruitment processes – up to one year. |
| Data processing as part of Asbud Group’s profile on Facebook and LinkedIn | Article 6(1)(f) of the GDPR The data will be processed until you object to the processing and in accordance with the regulations of the respective portals. |
| Exchanging correspondence | In principle, Article 6(1)(f) of the GDPR The legal basis and duration of data storage depends on the subject of the correspondence. |
| Keeping statistics | Article 6(1)(f) of the GDPR For the duration of any other processing indicated in this table. |
| Video surveillance to enhance employee safety and protect property and maintain confidentiality of information. | Article 6(1)(f) of the GDPR Video recordings are processed for a period not exceeding 3 months from the date of the recording, unless the recording constitutes evidence in proceedings – then until the proceedings are legally terminated. |
| Processing of cookies in order, among other things, to adapt the content of websites to the user’s needs | Article 6(1)(f) of the GDPR Data will be processed for the periods indicated in the Cookie Policy or until you object to the processing. Objection can only be made by changing the settings of the end user’s browser. |
Is the provision of data mandatory?
Providing data is voluntary, however, it is necessary to execute the contract. In cases arising by law, the provision of data is mandatory.
Data importers
Personal data in connection with the profile of Asbud’s activities in certain situations may be transferred to other data importers, i.e.:
- providers or entities that provide data communications services,
- Internal Revenue Service (Tax Office),
- the police or the prosecutor’s office,
- banks,
- entities providing postal or courier services,
- entities providing legal, audit services,
- entities of the Asbud Group,
- marketing agencies,
- in the case of data of employees or collaborators, such data may be disclosed to customers and contractors,
- in the case of job applicants, also to online recruitment portals
- to entities providing IT systems, including technical support in the handling of IT systems for automating marketing activities, including profiling.
Rights to data processing and voluntary nature of data provision
The person whose data is processed by the data controller has the right to request access to the data, rectification, i.e., erasure or restriction of processing and to object to processing, as well as the right to data portability. In the case of processing based on consent, consent can always be withdrawn. More information on data subjects’ rights is available in Articles 12-23 of the General Data Protection Regulation (i.e., GDPR), the text of which can be found at: https://eur-lex.europa.eu
In addition, you have the right to lodge a complaint to the supervisory authority, i.e., the President of the Office for Personal Data Protection, more information is available at: https://uodo.gov.pl/pl/p/skargi
Transfer of data to third countries
As a rule, personal data will not be transferred outside the European Economic Area (hereinafter: the “EEA”). However, given the services provided by our subcontractors in support for ICT services and IT infrastructure, Asbud may outsource certain activities or IT tasks to recognized subcontractors operating outside the EEA, which may result in your data being transferred outside the EEA. According to the European Commission’s decision, recipient countries outside the EEA provide an adequate level of protection for personal data in accordance with EEA standards.
For recipients in the territory of countries not covered by the European Commission’s decision, in order to ensure an adequate level of this protection, the data controller shall conclude agreements with recipients of personal data that are based on the standard contractual clauses issued by the European Commission in accordance with Article 46(2)(c) of the GDPR.
A copy of the standard contractual clauses can be obtained from the data controller – its contact details are given above. The method used by the data controller to secure your data complies with the principles provided for in Chapter V of the GDPR. You may request further information about the safeguards in place, obtain a copy of those safeguards, and find out where they are made available.
Processing of personal data by automated means
The Data Controller will not make automated decisions, i.e., without human involvement. The data controller may use the data for automated profiling.
Cookie Policy
Cookies are small files that are saved and stored on your computer or other device (terminal device) when you visit websites on the Internet. The entity placing cookies on the final device and accessing them is Asbud.
Based on cookies, persons may be identified, and therefore the legal basis for the processing of such data is Article 6(1)(f) of the GDPR, i.e., legally justified interest. Objections can only be made by changing the end user’s browser settings to prevent the collection of information using cookies.
Purpose for which cookies are used
Cookies are used to adapt the content of websites to user preferences and to optimize the use of websites. They are also used to create anonymous statistics, which help to understand how the user uses the websites, which allows to improve their structure and content, excluding personal identification of the user.
What are cookies used for
Asbud uses cookies to:
- customize the content of our websites;
- optimize the use of websites and applications;
- collect data about the use of the website to help us understand how visitors use the website and to allow us to improve the structure, navigation and content of the website;
- display information in a way that avoids presenting the same content to the same user over and over again, and to present the content in a way that takes into account the interests of the user;
- reach the user with advertising content emitted through partner systems outside the websites and applications owned by Asbud;
- support users and guarantee their safety when browsing the sites by using mechanisms that prevent abuse of the sites and the possibility of quick contact by means of features such as live chat.
What cookies are used by Asbud
The following file types are used:
- Permanent cookies – stored in the final device for the time specified in the parameters of cookies or until they are deleted;
- session cookies – cookies that allow you to remember the choices you have made. They remain on your terminal device until you leave the website or turn off your software (web browser);
Due to the purpose of cookies and other similar technologies, we use the following types of cookies:
- performance cookies – allowing to collect information about how the websites are used;
- statistical cookies – used to count statistics about websites and applications;
- advertising cookies – to enable the delivery of advertising content more tailored to your interests;
- functional cookies – enabling “remembering” the User’s selected settings and personalizing the interface, e.g., in terms of the selected language.
How do I change my browser’s cookie settings?
Typically, your web browsing software (web browser) will by default allow you to store information in the form of cookies and other similar technologies on your terminal device, the one you are actually using. technologies on your terminal device, the one you are actually using.
By doing so, through your software settings, you consent to the use of cookies to the extent and for the purposes indicated above – which is in accordance with the Telecommunications Law. You can withdraw your consent at any time by changing your settings. Failure to make changes means that the aforementioned information may be posted and stored on your terminal device.
Your software provider will provide you with more information on how to manage cookies in your browser. Below are links to the most popular web browsers: Internet Explorer Edge Chrome Safari Firefox Opera
Mobile devices: Android przeglądarka Chrome Safari
Please be advised that limiting or disabling the use of cookies and other similar technologies may affect the ability to use certain features available on the websites.
What files?
| Cookie name | Operator | Type | Duration | Cookie type |
|---|---|---|---|---|
| _ga | asbud.com | HTTP | 2 years | statistical |
| _gat | asbud.com | HTTP | 1 day | statistical |
| _gid | asbud.com | HTTP | 1 day | statistical |
| pll_language | asbud.com | HTTP | 1 year | Allowing the tool to work properly on the website |
| _gcl_au | asbud.com | HTTP | 3 months | marketing |
| ulubione | asbud.com | HTTP | 10 years | Allowing the tool to work properly on the website |
| cookie_notice_accepted | asbud.com | HTTP | 1 month | Cookie preferences |
| ads/ga-audiences | google.com | pixel | session | marketing |
| 0747af181e2ff65b5df958a37d90f12de86d213c | api.callpage.io | HTTP | 1 day | Allowing the tool to work properly on the website (callpage) |
| 0ab10aa4af0589c215739cd3c589189514c7f23d | api.callpage.io | HTTP | 1 day | Allowing the tool to work properly on the website (callpage) |
| 2317e635d574146d9ed54e54f64f1834eada7634 | api.callpage.io | HTTP | 1 day | Allowing the tool to work properly on the website (callpage) |
| 2aa727e9f76ccfa392ecda19a9d41bfcc4754ad4 | api.callpage.io | HTTP | 1 day | Allowing the tool to work properly on the website (callpage) |
| callpageCookieTest | asbud.com | HTTP | session | Allowing the tool to work properly on the website |
| cp.lead.phoneNumber | asbud.com | HTTP | session | Allowing the tool to work properly on the website |
| cp_lastTriggerId | asbud.com | HTML | permanent | Allowing the website to function properly |
| cp_metrics | asbud.com | HTML | permanent | Allowing the website to function properly |
| cp_resolvedTriggers | asbud.com | HTML | permanent | Allowing the website to function properly |
| cp_score | asbud.com | HTML | permanent | Allowing the website to function properly |
| cp_session_id | asbud.com | HTML | permanent | Allowing the website to function properly |
| cp_wasWidgetShown | asbud.com | HTML | permanent | Allowing the website to function properly |
| cp_widget_geo_response | asbud.com | HTML | permanent | Allowing the website to function properly |
| cp_widget_session | asbud.com | HTML | permanent | Allowing the website to function properly |
Using Google Ads
Our website uses Google Ads. We use Google tools to draw attention to our attractive offers on external websites through advertising media.
The remarketing feature allows us to present users of our website with ads based on their interests from other websites that are part of Google’s advertising network. For this purpose, the interaction of users on our website is analyzed, e.g., which offers does the user find interesting, so that we can display targeted advertisements to users, e.g., on our website.
Our website also uses Google Conversion Tracking. If you arrived at our site through an advertisement sent by Google, a cookie will be set on your computer. These cookies expire after 30 days and are not used for personal identification. If you visit certain pages on our site and the cookie has not expired, we and Google may recognize that you clicked on an advertisement and were redirected to that page. Each Google Ads customer receives a different cookie The information collected using the redirection cookie is used to generate redirection statistics for Google Ads advertisers who use such functionality. They do not receive information that identifies users.
For more information about the purposes and scope of data collection and processing by Google, click here.
Using Asbot
Chatbot and voicebot are interactive software hidden in an instant messenger or on a website that supports the area of broadly understood communication with the customer. It performs the most repetitive and tedious tasks. It helps to improve sales, answers the most frequently asked questions or supports brand image creation. More information here.
Using CallPage
Our website uses CallPage solutions. CallPage displays popups for visitors to leave contact information, which is used for marketing and sales purposes. More information here.
Using Revhunter
Revhunter is a tool that allows creation of offers and product recommendations that are tailored to your interests and online activities. In order to optimize the content available on our website, to adapt it to your individual needs and to present you with the best available offer, tailored to your preferences and not to display or send advertisements in which you are not interested, we use information stored in cookies on your terminal equipment (such as laptop or cell phone). You can control cookies through your browser settings as described above.
Email remarketing services involve sending of email advertisements to users of the Administrator’s website that are tailored to the user’s actions and behavior on the website. Retargeting service is performed through the Revhunter tool, which belongs to INIS sp. z o.o. with its registered office in Rybnik at ul. Raciborska 35a (NIP: 6423128785).
The entity that sends e-mails to you and at the same time the controller of your personal data is our partner, INIS sp. z o.o., whose identity is indicated in the footer of the e-mail you received. More information here.
