WHITE STAR REAL ESTATE SP. Z O.O.

White Star Real Estate group of companies (as defined below) (hereinafter referred to as the "White Star") is committed to the privacy and confidentiality of information provided by its users. This Privacy Policy describes White Star policies and practices with regard to Personal Data collected by White Star through this website and web applications which link to this Privacy Policy as well as Personal Data we received from you in the course of our business, including when you contact or request information via email or you engage our services or as a result of your relationship with one or more our staff and clients. What kind of information we collect and how we process them.

Please note that by submitting Personal Data manually or in electronic form to us, by using our website, web applications or by sending emails you give your consent that all Personal Data submitted to us may be processed by us in the manner and for the purposes described in this Privacy Policy.

The term “Personal Data” refers to any information that identifies, or could reasonably be used to identify, a living individual. .

1. Who is responsible for the data processing and who can I contact in this regard

The White Star group comprises a number of companies acting as controllers or processors of Personal Data, including, but not limited to White Star Real Estate sp. z o.o. based in Warsaw (Poland), White Star Real Estate s.r.o. based in Praha (Czech Republic), White Star Real Estate Limited Liability Company based in Budapest (Hungary), White Star Real Estate SRL based in Bucharest (Romania), OOO White Star Real Estate based in Moscow (Russia), White Star Real Estate LLC (Delaware, United States); their subsidiaries and members together with their respective affiliates.

Each White Star group company that processes your Personal Data is responsible for looking after it in accordance with this Privacy Policy, our internal standards and procedures, and the requirements of data protection law including General Data Protection Regulation no. 2016/679 (hereinafter: „GDPR”).

For more precise information about the specific company or companies in the White Star group that have access to and are responsible for your Personal Data (including the identity of the relevant White Star group company that are the data controller(s) or processor(s) for your Personal Data), please contact us using email rodo@whitestar-realestate.com or the details provided below:

In Poland:

White Star Real Estate sp. z o.o.

Address: ul. Zajęcza 2B

00-351 Warsaw, Poland,

telephone at:(48 22) 564 50 00;

Fax :+48(22) 564 50 85

NIP: 525-15-97-564

REGON: 12455435

District Court for the Capital City of Warsaw, 12th Economic Department of the National Court Register, KRS no.: 0000043357

Share capital: PLN 10 628 800

In Czech Republic & Slovakia:

White Star Real Estate s.r.o.

Address: V Parku 2343/24,

148 00 Praha 4 Chodov, Czech Republic,

Tel :+420 246 085 800

Fax :+420 246 085 891

In Hungary:

White Star Real Estate Limited Liability Company

Address: Csörsz utca 49-51.,

Budapest H-1124,Hungary,

Tel :+36 1 382 5100,

Fax :+36 1 382 5101

In Romania:

White Star Real Estate SRL

Address: 121C Gheorghe Titeica Street,

5th Floor 2nd District,

Bucharest RO-020295, Romania,

Tel :+40 21 7809010,

Fax :+40 21 7809013

2. What sources and data do we use

We process your Personal Data that we have legally received from you during our business relationship, through this websites and web applications which link to this Privacy Policy, when you contact or request information via email or you engage our services or as a result of your relationship with o our staff and clients, the Personal Data we may receive from you may include inter alia:

a) Basic information such as your name, surname, your employer, your title or position;

b) Contact information such as e-mail address, fax, mobile and telephone number(s);

c) Identification and background information to enable us to check and verify your identity, such as your date of birth or passport details;

d) Financial information such as bank account details, financial reports;

e) Technical information (including IP address of your computer) such as information from your visit to our website or applications or in relation to materials and communications we sent to you, traffic data, location data, weblogs and other communication data;

f) Any other information relating to you which you may provide to us.

In some circumstances, we collect information about you from our partners or from publicly available websites to help us expand and better understand our audience and enhance the relevance of our content. For example, in some cases we obtain the contact details of potential contributors to our events and publications from public websites.

We may also process Personal Data from publicly available sources (e.g. commercial registers, register of entrepreneurs) which we lawfully obtained.

We may also receive information about you from Google Analytics, a web analytics service provided by Google, Inc. ("Google") whose servers are in the United States of America. Google Analytics uses cookies to help us analyze how users use our websites.

If you provide Personal Data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that Personal Data to us and that, without our taking any further septs, we may collect, use and disclose that Personal Data as described in this Privacy Policy.

3. Information that we obtain through cookies and similar tools

We make use of cookies to track your use of our website. Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. This information is used to track visitor use of the website and to compile statistical reports activity.

We may offer cookies to you and you should ensure that your web browser is set up to not accept cookies if you do not wish to receive them. Cookies help you to get the most out of our websites, and please note that if you disable cookies, some services or website functionality may not be available. For example, you may have difficulties viewing articles published on our websites. We use the following cookies:

Analytical cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Marketing cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences. These cookies also record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website, the advertising displayed on it and communications sent more relevant to your interests.

By continuing to use this site, you are accepting our use of these cookies that make advertising and communications more relevant to you and your interests, and further help us to improve our website.

Most browsers allow you to manage cookie settings. These settings can usually be found in the ´Settings´, ´Options´ or ´Preferences´ menu of your browser.

4. Why do we process your data (purpose of the processing) and on what legal basis

Whether we receive your Personal Data directly from you or from a third party, we only process your Personal Data where we have a lawful basis for doing so, such as the following:

a) based on your consent (art. 6 (1) a) GDPR)

This is where you have given us explicit permission to process Personal Data for a given purpose. For example, if you complete our “contact form” you have agreed to the processing of your Personal Data for contacting purposes, by giving us your business card you agree to the processing your Personal Data contained therein for business purposes. You have the right to withdraw this consent at any time by contacting us at the address given in point 1 above.

b) for the performance of contractual obligations (article 6 (1) b) GDPR

The processing of Personal Data may be carried out to perform contract with you /or your company or to take steps at your request before entering into a contract. The purpose of the data processing is primarily dependent on the specific contract with you /or your company

c) legitimate interests pursued by the controller (art. 6 (1) f) GDPR

If necessary, we process your Personal Data for the purposes of the legitimate interest pursued by the controller or a third party. For example:

- for archiving (evidence) purposes, in cases where facts are required, e.g. in the event of a potential dispute or claim;

direct marketing. We take due care to balance our interests against your right to privacy. We will also comply with your request to stop sending any such further communications. You have the right to opt out of receiving marketing communications at any time by:

- contacting us by emailing: rodo@whitestar-realestate.com or the addresses given in point 1 above;

- using the “unsubscribe” link in the marketing emails.

d) compliance with a legal obligation to which the controller is subject (art. 6 (1) c) GDPR

we process your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to, including anti-money laundering regulation, health and safety regulations or rules issued by our professional regulator. Other purpose of processing include among others the satisfaction of tax control and reporting obligations as well as the assessment and management of risk.

5. Who receives your data

Within the White Star group, each company, may have access to your Personal Data if this is required to perform our contractual or statutory obligations. Service providers and vicarious agents employed by us may also receive Personal Data for these purposes if they observe confidentiality obligation and our documented instructions under GDPR

With regard to the transfer of Personal Data to recipients outside White Star capital group, we may only disclose information about you if we are legally required to do so. The recipients of Personal Data may be, for example:

public authorities and institutions insofar as a statutory or official obligation exists;

entities providing office services for the Company (including data deleting).

This includes, but is not limited to, email service providers, IT service providers, mailing houses, certain support service providers such as translation and photocopying. We will not release, rent or sell your Personal Data to third parties for their own use. We will take reasonable steps, such as contractual clauses and terms of service, to ensure that any third parties who do receive and handle such Personal Data are bound by the same obligations as us and do not use such information for any other purpose.

6. Is data transferred to a third country or to an international organization

White Star is an international firm and a list of our offices, together with relevant contact information, may be found on our website and in point 1 above. Irrespectively of how we obtain your Personal Data, it may be shared among all White Star entities. Our policy requires all White Star entities to always ensure a level of data protection at least as protective as those mandated by European Union.

The personal information that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area ("EEA"). If this happens we will take steps such as contractual clauses to ensure that your data is safe and treated securely and in accordance with this Privacy Policy.

7. How long will my data be stored

Your Personal Data will be stored in accordance with our Data Retention Policy, which specifies the appropriate retention period for each category of data. We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data by contacting us: rodo@whitestar-realestate.com

However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. What data protection rights do I have

Every data subject has a right of access, a right to rectification, a right to erasure, a right to restriction of processing, a right to object and a right to data portability. The right of access and right to erasure are subject to the restrictions under GDPR. Data subjects also have a right to lodge a complaint with an appropriate supervisory authority if you decide that the processing of Personal Data violates the provisions of the GDPR.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

9. Obligation to provide data

Within the scope of our business relationship your Personal Data as your company authorised representatives, attorney, contact persons are necessary for the execution of a business relationships and performance of the associated contractual obligations. In particular, provisions of money laundering law require that we verify your identity before entering into the business relationship.

Providing Personal Data is voluntary but necessary to contact you in case you filled in our “contact” form.

Our website and website applications are not intended for children under 16 years of age. We do not intentionally collect or use any information from children.

Your Personal Data will not be subject to automatic decision making, including profiling related to automatic decision making.

10. Changes to our privacy policy

We will improve and add new functionality and features to our website application and improve and add to our existing products, services and products. Because of these ongoing changes, changes in the law and the changing nature of technology, our data practices will change from time to time. If and when our data practices change, we will let you know.