Ladies and Gentlemen,

In connection with the new regulations on the protection of individuals with regard to the processing of personal data, we would like to fulfil our obligation to inform you about how we process your data. We explain the most important points below. If you have any questions, please do not hesitate to contact us.

Information on the processing of personal data:

Your data shall be processed on the basis of Article 6(1)(f) “GDPR”, i.e. on the basis of the necessity of the processing for the purposes of legitimate interests pursued by the Data Controller or by a third party.

Where did we get your data from?

We have obtained your data:

1. directly from you,
2. from an entity which has concluded an agreement with Real Management SA to provide services to you,
3. from a partner / third party cooperating with Real Management SA, who provided your personal data on the basis of your consent.

Who is the controller of your data?

Real Management SA with its registered office in Warsaw, at ul. Franciszka Klimczaka 1, 02-797 Warsaw, NIP: 951-204-02-20, REGON: 017506255, KRS number: 0000350480,  telephone: +48 22 395 61 00, e-mail: office@realmanagement.pl

Who is the Data Protection Supervisor [DPS]  at Real Management SA?

The institution of the DPS is currently in the process of being formed. Until such time as it is completed and notified, all enquiries concerning the personal data processed should be addressed to the main address as specified  above.

What data are we processing?

Real Management SA processes the following categories of data:

1. contact details;
2. data required for identification for the purpose of concluding a contract, providing a service and issuing an invoice;
3. identification data necessary for on-line correspondence;
4. employee data necessary for processing from the point of view of separate regulations;
5. data needed to select an appropriate marketing offer and services of for you as provided by Real Management SA (if you have agreed to do so beforehand).

What will we use your data for?

We will process your data for one or more of the following purposes:

1. in order to carry out activities carried out at your request before the conclusion of a contract;

2. in order to conclude and perform an  agreement with Real Management SA;
3. in order to perform a contract concluded with Real Management SA on your behalf as a third party (Article 393 of the Civil Code), where another entity is a party to such contract;
4. in order to fulfil a legal obligation imposed on Real Management SA, e.g. to issue an invoice or bill, or to implement an employment relationship;
5. for the marketing purposes of Real Management SA products and services (if you have given your prior consent to do so).

Are you obliged to provide the data?

To the extent that the processing of your data is carried out for the purpose of performing a contract with Real Management SA, the provision of your data is a condition for the conclusion of such contract. The provision of data is voluntary, but is necessary for the conclusion and performance of a contract. If you do not provide your personal data, a given agreement will not be concluded. Providing the data necessary to issue an invoice is a statutory obligation and results from the Act on the tax on goods and services (VAT).

For the rest, the provision of personal data is voluntary, is not a statutory or contractual requirement and does not constitute a condition for concluding a contract.

On what basis will we process your personal data?

The basis for processing personal data is, depending on the activities performed:

1. conclusion and performance of an agreement with Real Management SA,

2. fulfilling the legal obligation imposed on Real Management SA (e.g. issuing an invoice, employment),
3. legally justified interest of Real Management SA (direct marketing of its products and services or performance of an agreement concluded with Real Management SA for you as a third party where another entity is a party to such agreement),
4. your consent.

When and to whom can we convey the data, and to whom will we certainly not convey the data?

If you give your consent, we will share your personal data with entrepreneurs with whom Real Management SA cooperates so that they can use them for marketing purposes. We may disclose your data to the recipients, in the form of companies cooperating with us and performing tasks on our behalf or mandated by us. In this case, an agreement is concluded with these entities to ensure the security of your data. If you want to know who we are currently working with, you can always ask us about this.

What can you do with the personal data you have given us?

You have the right to request, from Real Management SA, to access, correct, delete or limit the processing of your personal data, to object to its processing, and we may, at your request, transfer such data  to another data controller. You may object to the processing of your data for the marketing of Real Management SA’s own products or services.

How to withdraw the consent?

It is possible to give all the consents, some of the consents, or none of them at all.   At any time you can revoke any consent granted to Real Management SA in connection withthe processing of your personal data without any negative consequences. It is enough to send an e-mail, to call or send a message by traditional mail to the contact details specified  above. The willingness to withdraw your consent can be expressed in any manner, the only condition is that it reaches us. The withdrawal of the consent does not affect the lawfulness of the processing of your data before its execution, i.e. until the moment of withdrawal of your consent, the processing of your data by Real Management SA is legal.

Until when will we keep your data?

Your personal data will be stored for as long as it is necessary for the performance of a contract between you and Real Management SA or a contract concluded by another entity on your behalf, and afterwards for a period corresponding to the statute of limitations for claims that Real Management SA may raise and that may be raised against Real Management SA. If your personal data are to be processed in order to fulfil the legal obligation of the data controller, your personal data will be stored for the time necessary to fulfil this obligation. The data processed on the basis of your consent will be processed until you withdraw your consent.

If your personal data are to be processed on the basis of the legitimate interest of the controller, where the basis for such processing is the performance of an agreement concluded with Real Management SA on your behalf, the data will be processed until the legitimate interest underlying such processing has been fulfilled. If your personal data are to be processed on the basis of the legitimate interest of the controller, where the basis for this processing is direct marketing of its products and services, your personal data will be processed until you object to such processing.

Where can you complain about the processing of your personal data by Real Management SA?

At present, such complaints can be addressed to the Inspector General for Personal Data Protection [Polish: Generalny Inspektor Ochrony Danych Osobowych]. However, we would like to point out that the President of the Office for the Protection of Personal Data [Polish: Prezes Urządu Ochrony Danych Osobowych] will soon be the competent supervisory authority in this matter.

How will we not process personal data?

Your personal data are not subject to automated processing (e.g. profiling) which produces legal effects on you or significantly affects you in a similar manner.

Real Management SA, as the Controller of your personal data, makes every effort to ensure all the means of physical, technical and organisational protection of your personal data against accidental or deliberate destruction, accidental loss, alteration, unauthorized disclosure, use, or access in accordance with all applicable regulations.

For this specific purpose, Real Management SA has engaged specialists in the  GDPR and ISO 27001:2015 and will perform relevant adjustments in order to fully comply with the above mentioned sets of standards for personal data processing.