Privacy policy

Privacy policy

Privacy Policy

  1. This privacy policy (“Privacy policy” or “Policy”) has been adopted by PEC Ziemowita spółka z ograniczoną odpowiedzialnością seated in Warsaw (address: ul. Złota 59, 00-120 Warsaw, entered into the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register under KRS no. 0000541981, NIP (Tax Identification Number): 5272728793, REGON (National Business Registry): 360748870 (“PEC Ziemowita”) in connection with the entry into force of the 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 (“GDPR”).
  2. The Policy governs the processing of personal data by PEC Ziemowita in connection with the operation of Warsaw East Distribution Centre, ul. Księcia Ziemowita 59, 03-885 Warsaw (“Warsaw East Distribution Centre”).
  3. The Policy also constitutes terms and conditions for the use of the websites operated by PEC Ziemowita (“Website”).

 

I Website terms and conditions

1.1. Terms of use of the Website

  1. The use of the Website requires the following technical conditions to be fulfilled:
    a) Internet access,
    b) Operating system: Windows XP, 7, 8, Mac OS X and OS X, Android,
    c) Browser: Google Chrome (version 28 or higher), Mozilla Firefox (version 23 or higher),  Internet Explorer 11 (or higher), Opera, Safari (version 5.1 or higher), iOS Safari (version 4.0 or higher), Android Browser 2.3,
    d) Additional features: JavaScript and Cookies; you may need to install software to view certain elements and information: Flash Player, Acrobat Reader 2.
  2. Use of the Website constitutes acceptance of this Privacy policy.

 

1.2. Cookies

  1. PEC Ziemowita collects information about users of the Website using cookies. Cookies are not used to identify or establish the identity of individual users.
  2. Cookies are established when “entering” and “exiting” the Website.
  3. The entity placing cookies on the user’s terminal device, within the meaning of art. 173 para. 1 of the Act of 16 July 2004 – Telecommunications Act, is PEC Ziemowita.
  4. The placement of cookies is carried out in accordance with the relevant provisions of law, in particular the Telecommunications Act and the Act on provision of electronic services.

 

1.3. Complaints

  1. Users may report complaints concerning the operation of the Website by contacting Warsaw East Distribution Centre at the following address: Warsaw East Distribution Centre, ul. Księcia Ziemowita 59, 03-885 Warsaw.
  2. The complaint should include a description of the problem giving rise to the complaint, user’s demands and contact details (e-mail address) enabling contact with the user.
  3. PEC Ziemowita shall recognise complaints within 14 days of receipt, providing a response to the e-mail address indicated by the user.

 

II Personal data processing

2.1. Information on data administration and the categories of persons whose data are processed by PEC Ziemowita

  1. PEC Ziemowita processes the personal data of individuals referred to in this section in accordance with applicable data protection legislation and is the data controller within the meaning of such legislation.
  2. The co-controller of the personal data collected by PEC Ziemowita is CBRE Investment Management Poland spółka z ograniczoną odpowiedzialnością seated in Warsaw (ul. Złota 59, 00-120 Warszawa, entered into the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register under KRS no. 0000123835, NIP (Tax Identification Number): 526-250-47-21, REGON (National Business Registry): 017188128.
  3. PEC Ziemowita, in connection with the operation of the Warsaw East Distribution Centre, may process personal data of the following categories of persons:
    a) Consumers,
    b) Tenants who are natural persons,
    c) Contractors who are natural persons,
    d) Employees of tenants and contractors,
    e) Employees of subcontractors of tenants and contractors.
  4. In the case of consumers, PEC Ziemowita processes in particular the personal data of:
    a) Participants of competitions and marketing campaigns, including events,
    b) Individuals contacting PEC Ziemowita through the information desk,
    c) Individuals making claims against PEC Ziemowita,
    d) Users of social media, including participants of competitions organised by these media,
    e) Individuals visiting Warsaw East Distribution Centre,
    f) Individuals using the car park.
  5. PEC Ziemowita provides detailed information, required by law, on the processing of personal data to the individuals indicated in paragraphs 3b and 3.c) and 4.a) – 4.c) above directly upon the acquisition of data, i.e. in the case of:
    a) Tenants who are natural persons – simultaneously with tenancy agreement signing,
    b) Contractors who are natural persons – simultaneously with agreement signing,
    c) Participants of competitions and marketing campaigns – simultaneously with sending the confirmation of participation application,
    d) Individuals contacting PEC Ziemowita via information desk – simultaneously with accepting the application at the information desk,
    e) Individuals making claims against PEC Ziemowita – simultaneously with replying to the application.
  6. In addition, PEC Ziemowita provides detailed information, as required by law, regarding the processing of personal data of social media users to these users by publishing on the Warsaw East Distribution Centre’s profile on these media.
  7. The detailed information required by law regarding the processing of personal data of individuals other than those indicated in para. 5 and 6 above, is set out in 2 paragraph of this Policy.

 

2.2. Scope, purposes and processing of personal data of certain categories of persons

  1. Visitors to the Warsaw East Distribution Centre

PEC Ziemowita processes personal data, i.e. the image of individuals visiting the Warsaw East Distribution Centre in order to ensure security and order on the premises of the Warsaw East Distribution Centre, in connection with the CCTV video surveillance system. This data may also be used in connection with violations of law committed by visitors to the Warsaw East Distribution Centre.

In such a situation, personal data of visitors to the Warsaw East Distribution Centre is processed in order to pursue the legitimate interests of PEC Ziemowita, i.e. to ensure security and order on the premises of the Warsaw East Distribution Centre and to assert claims.

In consideration of the above purposes, PEC Ziemowita may share personal data of visitors to the Warsaw East Distribution Centre with suppliers of technical or organisational services as well as legal and advisory services used by PEC Ziemowita in connection with the operation of the Warsaw East Distribution Centre, i.e. in particular the facility manager, security company and CCTV system provider, law and tax offices, courier and postal companies. Personal data may also be disclosed to public authorities, including the police and other inspections and guards.

PEC Ziemowita does not transfer the above personal data to third countries (outside the EEA).

The processing of personal data of visitors to the Warsaw East Distribution Centre does not involve automated decision-making or profiling.

Personal data recorded on CCTV footage is stored for 2 months. In the case of proceedings in connection with violations of law committed by visitors to the Warsaw East Distribution Centre, personal data may be stored for longer – for the duration of such proceedings and until the expiry of the limitation period for claims.

  1. Car park users

PEC Ziemowita processes personal data of individuals using the car park for the following purposes:

  1. Claims in the event of damage,
  2. Statistical purposes.

In both cases, the basis for processing of the personal data of users is the pursuit of the legitimate interests of PEC Ziemowita.

Data on car park users obtained by PEC Ziemowita for statistical purposes is collected using an automatic number plate recognition system. Collection of this data shall not give rise to any legal, financial or other relevant consequences for individuals using the car park.

In consideration of the above purposes, PEC Ziemowita may share personal data of the car park users with suppliers of technical or organisational services as well as legal and advisory services used by PEC Ziemowita in connection with the operation of the Warsaw East Distribution Centre, i.e. in particular the facility manager, security company, law and tax offices, courier and postal companies. Personal data may also be disclosed to public authorities, including the police and other inspections and guards.

PEC Ziemowita does not transfer the above personal data to third countries (outside the EEA).

The processing of personal data of the car park users does not involve automated decision-making or profiling.

Data on registration plates is stored for 6 months. In the case of proceedings in connection with violations of law committed by the car park users, the personal data of these individuals may be stored for longer – for the duration of such proceedings and until the expiry of the limitation period for claims.

  1. Employees of tenants and contractors of PEC Ziemowita

PEC Ziemowita processes personal data of employees of its tenants and contractors for the following purposes:

a) Performance of concluded agreements,
b) Ensuring order and security (refers to the advancement of work, issuing access cards),
c) Pursuing claims or defending rights.

In these situations, the basis for processing of the personal data of tenant employees and contractors is pursuing the legitimate interests of PEC Ziemowita.

PEC Ziemowita obtains personal data of the individuals indicated above from tenants and contractors, in connection with the performance of contracts. The personal data provided may include personal information (name, last name), contact data (telephone number, e-mail address) and data concerning the professional position held.

In consideration of the above purposes, PEC Ziemowita may share personal data of employees of tenants and contractors with suppliers of technical or organisational services as well as legal and advisory services used by PEC Ziemowita in connection with the operation of the Warsaw East Distribution Centre, i.e. in particular the facility manager, security company, law and tax offices, courier and postal companies.

Personal data of employees of tenants and contractors of PEC Ziemowita may be transferred outside the EEA. In this situation, the data is shared within the United States in connection with the use of IT services. Individuals whose data has been transferred to third countries have the right to obtain a copy of the data transferred, and PEC Ziemowita uses appropriate safeguards to protect the data.

The processing of personal data of employees of tenants and contractors of PEC Ziemowita does not involve automated decision-making or profiling.

Personal data of employees of tenants and contractors is processed for the duration of the contracts binding PEC Ziemowita and for 7 years after their expiry. The data contained in the notification forms is stored for the same period. In the event of legal proceedings in connection with the pursue of claims or defence of rights, personal data is stored for the duration of such proceedings and until the expiry of the limitation period for claims.

  1. Employees of subcontractors of tenants and contractors of PEC Ziemowita

PEC Ziemowita processes personal data of subcontractors (who are natural persons) of tenants and contractors and employees of subcontractors of tenants and contractors for the following purposes:

a) Ensuring order and security (refers to the advancement of work, issuing access cards),
b) Pursuing claims or defending rights.

In these situations, the basis for processing of the personal data of the individuals indicated above is the realization of the legitimate interests of PEC Ziemowita.

PEC Ziemowita obtains personal data of the above-mentioned individuals from tenants and contractors, in connection with the notification of works carried out in the premises or on the premises of Warsaw East Distribution Centre. The personal data provided may include personal information (name, last name), contact data (telephone number, e-mail address) and data concerning the professional position held.

In consideration of the above purposes, PEC Ziemowita may share personal data of the individuals indicated above with suppliers of technical or organisational services as well as legal and advisory services used by PEC Ziemowita in connection with the operation of the Warsaw East Distribution Centre, i.e. in particular the facility manager, security company, law and tax offices, courier and postal companies.

Personal data of the individuals concerned may be transferred outside the EEA. In this situation, the data is shared within the United States in connection with the use of IT services. Individuals whose data has been transferred to third countries have the right to obtain a copy of the data transferred, and PEC Ziemowita uses appropriate safeguards to protect the data.

The processing of personal data of the individuals in question does not involve automated decision-making or profiling.

The personal data of the individuals in question is processed for 7 years after the completion of work carried out on the premises or within the Warsaw East Distribution Centre. In the event of legal proceedings in connection with the pursue of claims or defence of rights, personal data is stored for the duration of such proceedings and until the expiry of the limitation period for claims.

2.3. Responding to requests of data subjects

  1. In connection with the operation of the Warsaw East Distribution Centre, PEC Ziemowita ensures that all data subjects (as indicated in point 1) are able to exercise their rights in accordance with applicable legislation. These individuals have the right:
    a) to access their personal data,
    b) to request immediate rectification of personal data,
    c) to request immediate deletion of personal data,
    d) to request restriction of processing of personal data,
    e) to transfer personal data,
    f) to object to the processing of their personal data, including profiling.
  2. For details on how to exercise these rights, please refer to section 4 of this Policy.
  3. In addition, in the case of processing of personal data on the basis of consent, PEC Ziemowita provides data subjects with the opportunity to withdraw their consent at any time. Withdrawal of the consents given shall not affect the lawfulness of processing carried out on the basis of the consent given before the withdrawal.
  4. Persons whose data is processed by PEC Ziemowita may exercise their rights set out in para. 1 and 3 above by contacting PEC Ziemowita at: Warsaw East Distribution Centre, ul. Księcia Ziemowita 59, 03-885 Warsaw.
  5. PEC Ziemowita shall, without undue delay – and in any event within one month of receipt of the request – provide the data subject with information on the actions taken in relation to his/her exercise of the rights referred to in para. 1 and 3 above.
  6. If PEC Ziemowita fails to take action in response to the data subject’s request, PEC Ziemowita shall, without delay – at the latest within one month after receipt of the request – inform the data subject of the reasons for not taking action and of the possibility of lodging a complaint to the supervisory authority and of seeking judicial remedy.
  7. At the same time, any individual who believes that his/her data is being processed unlawfully by PEC Ziemowita has the right to lodge a complaint with a supervisory authority: Prezes Urzędu Ochrony Danych Osobowych (President of the Personal Data Protection Office), ul. Stawki 2, 00-193 Warsaw.

 

2.4. Rights of persons whose data is processed by PEC Ziemowita

  1. Right to access

Data subjects may request information on whether their personal data is processed and, if so, to access it.

PEC Ziemowita, upon a data subject’s request for access to his/her data, shall inform that individual of the scope, manner and purpose of the processing, and shall grant the individual access to the data relating to him/her. Access to data can be provided by issuing a copy of the data, the first copy of which is provided free of charge. If further copies of the data are requested, PEC Ziemowita is entitled to charge a fee equivalent to the administrative costs.

  1. Right to rectification

Where personal data is out of date or incorrect, the data subject may request that it be rectified. If the data was shared with other entities, PEC Ziemowita shall inform these entities of the rectification of the data. Furthermore, PEC Ziemowita completes and updates the data at the request of the data subject. PEC Ziemowita may refuse to complete the data if it is not necessary for the purposes of the processing.

  1. Right to deletion (“right to be forgotten”)

At the request of the data subject, PEC Ziemowita deletes the collected data. This is possible if:

a) the data is no longer necessary for the purposes for which it was collected or otherwise processed,
b) the data subject has withdrawn the consent on which the processing is based and there is no other legal basis for the processing,
c) the data subject objects to the processing and there are no overriding legitimate grounds for the processing,
d) the personal data was processed unlawfully,
e) the personal data must be deleted in order to comply with a legal obligation imposed on PEC Ziemowita,
f) the personal data was collected in connection with offering of information society services directly to a child.

If the data to be deleted has been transferred to other entities, PEC Ziemowita shall take reasonable steps, including technical measures, to inform those entities of the need to delete and access the data. At the request of the data subject, PEC Ziemowita shall inform him/her of the entities to which his/her data has been transferred.

  1. Right to restriction of processing

PEC Ziemowita shall carry out the restriction of data processing at the request of the data subject in situations where:

a) the data subject contests the accuracy of the personal data – for a period enabling PEC Ziemowita to verify the accuracy of the data,
b) the processing is unlawful, and the data subject objects to the deletion of the personal data by requesting instead that the processing be restricted,
c) PEC Ziemowita no longer needs the personal data for the purposes of the processing, but the data subject needs it in order to establish, assert or defend claims,
d) the data subject has objected to the processing – until it is determined whether the legitimate grounds on the part of PEC Ziemowita override the grounds for the data subject’s objection.

If processing has been restricted, PEC Ziemowita processes the data, with the exception of storage, only with the consent of the data subject, or in order to establish, assert or defend claims, or to protect the rights of another natural or legal person, or for compelling reasons of public interest.

  1. Right to transfer the data

If the data is processed on the basis of consent or for the purpose of concluding a contract, PEC Ziemowita shall, at the request of the data subject, issue the data relating to him/her, processed in IT systems, in a structured, commonly used machine-readable format or transfer it – if possible – to another entity.

  1. The right to object to the processing of personal data, including profiling

If the data subject objects to the processing of his/her data on grounds relating to his/her particular situation, and the data is processed by PEC Ziemowita on the basis of a legitimate interest of PEC Ziemowita, PEC Ziemowita shall respect the objection, unless there are compelling legitimate grounds on the part of PEC Ziemowita for the processing overriding the interests, rights and freedoms of the data subject who objects, or grounds for the establishment, exercise or defence of claims.

If an objection to the processing of data for direct marketing purposes (including profiling) is raised, PEC Ziemowita shall respect the objection without delay and cease the processing of data of the individual who raised the objection.

III Final provisions

  1. The Privacy policy does not apply to other websites and entities whose contact details are provided on the Website. If the Website contains links to other websites, PEC Ziemowita reserves that it is not responsible for the privacy policies of the owners of those domains and websites. The Privacy policy also does not apply to services provided by other parties through or using the Website, if such services are provided by third parties.
  2. This Privacy policy is effective as of 25 May 2018.
  3. PEC Ziemowita shall be entitled to amend this Privacy policy at any time. In such a case, the changes introduced shall be valid from the moment they are published on the Website.

 

Personal data:

The controller of personal data of users of the Warsaw East Distribution Centre profile (“Users”) is PEC Ziemowita spółka z ograniczoną odpowiedzialnością seated in Warsaw (address: ul. Złota 59, 00-120 Warszawa, entered into the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register under KRS no. 0000541981, NIP (Tax Identification Number): 5272728793, REGON (National Business Registry): 360748870 (“PEC Ziemowita Sp. z o. o.”).

Users’ personal data is processed by PEC Ziemowita in connection with the running of this profile, including correspondence with Users and the organisation of competitions via the profile. In addition, PEC Ziemowita may process Users’ personal data in connection with the exercise of its legitimate interests: pursue of claims or defence of rights.

Disclosure of data is voluntary. In the case of the organisation of competitions, failure to provide personal data may prevent the competition from being held and resolved. Detailed rules for conducting the competitions are provided by PEC Ziemowita in the regulations of the respective competition.

Users’ personal data is processed for the duration of the profile or until the posts are deleted by the User or PEC Ziemowita. Data collected for the purposes of organisation of the competition will be processed for the duration of the competition and for 7 years after its completion.

Users’ personal data will or may be transferred to suppliers of technical or organisational services and legal and advisory services used by PEC Ziemowita in connection with the running of this profile, i.e. in particular the manager of the Warsaw East Distribution Centre in Warsaw, marketing companies, law and tax offices, courier and postal companies.

The processing of personal data by PEC Ziemowita does not involve automated decision-making or profiling. PEC Ziemowita does not transfer Users’ data to third countries (outside the EEA).

Profile Users are entitled to access their personal data, rectify it, delete it or limit its processing. In addition, the Users can object to the processing of personal data or request the transfer of personal data.

The Users may exercise their rights set out above by contacting PEC Ziemowita via the Warsaw East Distribution Centre profile and at the address: Warsaw East Distribution Centre, ul. Księcia Ziemowita 59, 03-885 Warsaw.

If PEC Ziemowita processes personal data in violation of applicable legislation, the Users have the right to lodge a complaint with a supervisory authority: Prezes Urzędu Ochrony Danych Osobowych (President of the Personal Data Protection Office), ul. Stawki 2, 00-193 Warsaw.

This information relates solely to the processing of the User data by PEC Ziemowita and does not cover activities undertaken by Facebook.