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Privacy Policy Frost International Real Estate – Magdalena Mróz
This document contains rules on the processing of personal data and the use of cookies and other tracking technologies in connection with the operation of the https://frostinternationalrealestate.com/ website.
The administrator of the website is Magdalena Mróz conducting business activity under the name Frost International Real Estate – Magdalena Mróz; entered in the register of entrepreneurs CEIDG at 27 John Paul Avenue, 00-867 Warsaw, Poland, NIP 9542463273, REGON 243244410; e-mail: office@frostinternationalrealestate.com
This privacy policy has been structured in the form of questions and answers. The choice of this form was dictated by the concern for clarity and legibility of the information presented to you. Below, you will find a table of contents of this policy corresponding to the questions we answer in turn.
Please be informed, that the processing of your personal data takes place on the basis of the provisions of 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 (General Data Protection Regulation) (hereinafter: RODO).
If you have any concerns about the privacy policy, you can contact us at any time by sending an email to: office@frostinternationalrealestate.com.
# 1: Who is the controller of your personal data?
# 2: Who can you contact regarding the processing of your personal data?
# 3: What information do we have about you?
# 4: Where do we have your personal data from?
# 5: Is your data secure?
# 6: For what purposes do we process your personal data?
# 7: How long will we keep your personal data?
# 8: Who are the recipients of your personal data?
# 9: Do we transfer your data to third countries or international organisations?
# 10: Do we use profiling? Do we make automated decisions based on your personal data?
# 11: What rights do you have in relation to the processing of your personal data?
# 12: Do we use cookies and what are they?
# 13: On what basis do we use cookies?
# 14: Can you disable cookies?
# 15: For what purposes do we use our own cookies?
# 16: What third-party cookies are used?
# 17: Do we track your behaviour on our website?
# 18: Do we target advertising to you?
# 19: How can you manage your privacy?
# 20: What are server logs?
# 21: Is there anything else you should know?
The administrator of your personal data is Magdalena Mróz conducting business activity under the name Frost International Real Estate – Magdalena Mróz; entered in the register of entrepreneurs CEIDG at 27 John Paul Avenue, 00-867 Warsaw, Poland, NIP 9542463273, REGON 243244410; e-mail: office@frostinternationalrealestate.com.
As part of the implementation of data protection in our organisation, we have decided not to appoint a Data Protection Officer due to the fact that it is not mandatory in our situation. For matters relating to data protection and privacy more broadly, you can contact us at: office@frostinternationalrealestate.com.
Depending on the purpose, we may process the following information about you:
We have described the scope of the processing precisely for each processing purpose. Information in this regard can be found later in this policy.
In most cases, it is you who provide us with your personal data. This happens when:
We take care of the security of your personal data. We have analysed the risks involved in the various processes of processing your data and have implemented appropriate security and personal data protection measures. We continuously monitor the state of our technical infrastructure, train our staff, look at the procedures in place and make the necessary improvements. If you have any questions about your personal data, we are at your disposal at the following e-mail address: office@frostinternationalrealestate.com.
Below is a list of purposes, followed by a more detailed explanation. We have also assigned the respective legal bases for processing to the various purposes.
Service orders – details
When you place an order for our services, you must provide the data necessary to sign the contract. Depending on the details of the service, the data catalogue may be different. For example, if you are requesting a VAT invoice for a company, we need to know your VAT ID number and business address. Provision of the data is voluntary, but necessary to place the order.
Data collected in connection with the service, is processed for the performance of the contract concluded by placing an order (Art. 6(1)(b) RODO), the issuing of an invoice (Art. 6(1)(c) RODO in conjunction with the provisions governing the issuing of invoices), the inclusion of the invoice in the accounting documentation and the fulfilment of other tax and accounting obligations (Art. 6(1)(c) RODO in conjunction with the provisions governing tax and accounting obligations) and for archiving purposes for the possible need to defend, establish or assert claims.
Your order data will be processed for the time necessary to process your order and thereafter until the expiry of the limitation period for contractual claims. In addition, after the expiry of this period, data may still be processed by us for archival purposes for the possible need to defend, establish or assert claims. We are obliged to keep accounting records, which may contain your personal data, for the period required by law.
If you make a complaint or withdraw from the contract, you provide personal data in the body of the complaint or statement of withdrawal, which includes your name, address, telephone number, e-mail address, bank account number. The provision of data is voluntary, but necessary in order to make a complaint or withdraw from the contract.
The data provided to us in connection with the submission of a complaint or withdrawal from a contract are used for the purpose of the complaint procedure or withdrawal procedure and subsequently for archiving purposes, which is our legitimate interest (Art. 6(1)(f) RODO).
Data will be processed for the time necessary for the complaint procedure or the withdrawal procedure. Complaint documents will be stored until the expiry of the warranty entitlement period. Statements of withdrawal will be stored together with accounting records for the period required by law.
When you add a comment or opinion about a service, you must provide at least a username that will be assigned to the comment or opinion (the name may contain personal data, such as your first or last name) and an e-mail address. The provision of this data is voluntary, but necessary in order to add a comment or opinion. You may also add your avatar (which may include an image of yourself, such as a photograph) and your website address, but this is not obligatory.
The data provided in connection with the addition of a comment or opinion will be processed for the purpose of publishing the comment or opinion on the website. The basis for the processing is your consent (Article 6(1)(a)) resulting from the submission of the form used to publish your comment or opinion. You can withdraw your consent at any time by requesting that the comment or opinion be deleted.
Your comment or opinion will remain publicly available on the website for the duration of its online availability, unless you request the comment or opinion to be deleted beforehand. You can modify the content of your comment at any time, as well as modify the data assigned to it as about the person who added the comment or opinion.
When you contact us by sending an e-mail or by using the contact form at https://frostinternationalrealestate.com/contact-us/, you provide us with your personal data contained in the body of your correspondence, in particular your e-mail address and your name. The provision of data is voluntary but necessary in order to make contact.
Your data is processed in this case for the purpose of contacting you, and the basis for processing is Article 6(1)(f) RODO, i.e. our legitimate interest. The legal basis for post-contact processing is also our legitimate purpose of archiving your correspondence to ensure that we can prove certain facts in the future (Article 6(1)(f) RODO).
The content of your correspondence may be subject to archiving and we are not in a position to say with certainty when it will be deleted. You have the right to request the history of any correspondence you have had with us (if it has been archived), as well as to request its deletion, unless archiving it is justified by our overriding interests, such as defending against potential claims from you.
If we issue an invoice to you, it forms part of your accounting records, which will be kept for the period of time required by law. Your personal data is then processed for the purpose of fulfilling our tax and accounting obligations (Art. 6(1)(c) RODO in conjunction with the provisions governing tax and accounting obligations).
Handling the dispatch of the newsletter – details
Subscription to the newsletter takes place via a form on our website. During the newsletter subscription procedure, we obtain personal data such as name and e-mail address. The provision of the above data is voluntary, but necessary in order to receive the newsletter. Failure to provide the aforementioned data makes it impossible to receive the newsletter. This data is obtained in order to present commercial offers and marketing information to the e-mail address or telephone number provided in the contact form.
The legal basis for the processing of your personal data in this case is Article 6(1)(a) RODO. Your consent to the processing of your data may be withdrawn at any time by sending an email to office@frostinternationalrealestate.com from under the address to which the consent relates. Personal data obtained in this way are stored and processed for the period of subscription to the newsletter, as well as the period of implementation of the Administrator’s marketing policy.
Running marketing campaigns on Google, Facebook and Instagram platforms – details
Personal data such as name and email address obtained by the Administrator may be used to create and conduct marketing campaigns on the aforementioned social media platforms. This processing takes place on the basis of Article 6(1)(f) of the RODO, i.e. due to the legitimate interest of the Administrator.
With regard to the details of the platform administrators’ processing of the information provided in connection with the campaign, in particular the purpose and scope of data collection and further processing and use of the data by the administrators, as well as the possibility of contacting you and your rights in this regard and the possibility of making settings to ensure your privacy, the aforementioned information can be found in the privacy policies of the individual service providers:
As part of the description of the various purposes for processing personal data above, we have indicated the time limits for storing personal data. These time limits are often related to our archiving of certain data for the purpose of ensuring that we are able to prove certain facts in the future, to reconstruct the course of our cooperation with you, the correspondence exchanged, to defend ourselves, to establish or assert claims. We rely in this respect on our legitimate interest as referred to in Article 6(1)(f) RODO.
Data retention periods are indicated separately in relation to each processing purpose. You will find this information within the details dedicated to each separate purpose of processing.
We make use of services provided by third parties. Some of these services involve the processing of your personal data. The third-party service providers that are involved in the processing of your personal data are:
Your personal data may also be forwarded to the tax authorities to the extent necessary for the fulfilment of tax and accounting obligations. This refers in particular to all declarations, reports, statements and other accounting documents containing your personal data.
In addition, if necessary, your personal data may be made available to entities, authorities or institutions entitled to access the data under the law, such as police, security services, courts, public prosecutors’ offices.
Yes, part of the processing of your personal data may involve transfers to third countries.
We transfer your personal data to third countries in connection with the use of tools that store personal data on servers located in third countries, in particular in the United States of America (USA). The providers of these tools guarantee an adequate level of protection of personal data through the relevant compliance mechanisms provided for by the RODO, in particular through the use of standard contractual clauses.
The storage of personal data on servers located in third countries takes place within the following tools:
We would also like to remind you at this point that we use third-party tools that may collect anonymous information about you. The providers of these tools often use servers located around the world, particularly in the United States of America (USA), to store the collected information.
We do not make decisions towards you based solely on automated processing, including profiling, which would produce legal effects towards you or similarly significantly affect you.
The RODO grants you the following potential rights in relation to the processing of your personal data:
The right to access and receive a copy of your data,
The right to rectification (amendment) of your data,
The right to erasure (if, in your opinion, there are no grounds for us to process your data, you may request that we erase it),
The right to restrict the processing of your data (you can request that we restrict the processing of your data only to storing it or carrying out activities agreed with you if, in your opinion, we have incorrect data or are processing it unduly),
The right to object to processing (you have the right to object to processing on the basis of a legitimate interest; you should indicate the particular situation which, in your opinion, justifies us stopping the processing covered by the objection; we will stop processing your data for these purposes unless we demonstrate that the grounds for our processing override your rights or that your data is necessary for us to establish, assert or defend our claims),
The right to data portability (you have the right to receive from us in a structured, commonly used, machine-readable format the personal data you have provided to us on the basis of a contract or your consent; you may instruct us to send this data directly to another entity),
The right to withdraw your consent to the processing of personal data if you have previously given such consent,
The right to lodge a complaint with a supervisory authority (if you find that we are processing your data unlawfully, you may lodge a complaint to this effect with the President of the Office for Personal Data Protection or any other competent supervisory authority).
The rules related to the exercise of the rights indicated above are described in detail in Articles 16 – 21 of the RODO. The rights indicated above are not absolute and you will not be entitled to them in relation to all processing of your personal data.
One of the rights indicated above is always available to you – if you consider that we have violated data protection regulations in the processing of your personal data, you have the possibility to lodge a complaint with a supervisory authority (the President of the Office for Personal Data Protection).
You can also always request that we provide you with information about what data we hold about you and for what purposes we process it. All you need to do is send us an email at: office@frostinternationalrealestate.com. However, we have made every effort to ensure that the information of interest to you is comprehensively set out in this privacy policy. You can also use the e-mail address given above if you have any questions about the processing of your personal data.
Our website, like almost all other websites, uses cookies on the basis of Article 173 of the Act of 16 July 2004. Telecommunications Law (i.e. Journal of Laws 2022.1648 as amended).
Cookies are small textual information stored on your terminal device (e.g. computer, tablet, smartphone), which can be read by our ICT system (our own cookies) or the ICT systems of third parties (third-party cookies). In cookies, specific information can be saved and stored, which ICT systems can then access for specific purposes.
Some of the cookies we use are deleted when your browser session ends, i.e. when you close your browser (so-called session cookies). Other cookies are stored on your terminal device and enable us to recognise your browser the next time you visit the website (persistent cookies).
If you would like to find out more about cookies as such, you can read, for example, this material: https://pl.wikipedia.org/wiki/HTTP_cookie.
We use cookies on the basis of your consent, except where cookies are necessary for the proper provision of an electronic service to you.
Cookies that are not necessary for the correct provision of the electronic service remain blocked until you have given your consent to our use of cookies. During your first visit to our website, we display a message asking you for your consent together with the option of managing cookies, i.e. deciding which cookies you agree to and which you wish to block.
Disabling or restricting cookies may prevent you from using some of the features available on our website and may cause difficulties in using our website, as well as many other websites that use cookies. For example, if you block social media plug-in cookies, the buttons, widgets and social features implemented on our website may not be available to you.
Yes, you can manage your cookie settings within your internet browser. You can block all or selected cookies. You can also block cookies for specific websites. You can also delete previously saved cookies and other website and plug-in data at any time.
Web browsers also offer the option of using incognito mode. You can use this if you do not want information about the pages you have visited and the files you have downloaded to be saved in your browsing and download history. Cookies created in incognito mode are deleted when you close all windows in this mode.
Browser plug-ins for controlling cookies are also available, such as Ghostery (https://www.ghostery.com). The option to control cookies may also be provided by additional software, in particular anti-virus packages, etc.
In addition, there are tools available on the internet to control certain types of cookies, in particular to collectively manage behavioural advertising settings (e.g. www.youronlinechoices.com/, www.networkadvertising.org/choices).
Disabling or restricting cookies may prevent you from using some of the features available on our website and may cause difficulties in using our website, as well as many other websites that use cookies. For example, if you block social media plug-in cookies, the buttons, widgets and social features implemented on our website may not be available to you.
First-party cookies are used to ensure the correct functioning of the various mechanisms of the website.
First-party cookies also store information about the cookie settings you have defined via the cookie management mechanism.
The following third-party cookies operate as part of our website:
Details of individual third-party cookies are described below.
We use the Google API tool, which provides functions such as analytics, machine learning as a service (Prediction API) or access to user data (when permission has been granted to read the data). Another important example is an embedded Google map on a website, which can be accessed using the Static Maps API, Places or Google Earth API.
In addition, as part of Google’s services, we use the Google Reviews plug-in, which enables the presentation of reviews voluntarily posted by users via Google services such as Google Maps on our website.
Google APIs are application programming interfaces (APIs) developed by Google that enable communication with Google Services and their integration with other services. Examples include search, Gmail, Translator or Google Maps. Third-party applications can use these APIs to leverage or extend the functionality of existing services.
https://developers.google.com/terms/api-services-user-data-policy
Our website uses plug-ins, buttons and other social media tools, collectively referred to as „plugins”, provided by social networks such as Facebook, Instagram, LinkedIn and YouTube.
When displaying our website containing a plug-in of a particular social network, your browser sends information to the administrator of this social network about the visit. As the plug-in is a fragment of a social network embedded in our website, your browser sends a request to download the content of the respective social network to our website.
The plug-ins collect certain information about you, such as your user ID, the website you visited, the date and time and other browser information.
The social network administrators use some of this information to personalise the viewing experience on our site. For example, when you visit a page with a „Like” button, the social network administrator needs information about who you are in order to show you which of your friends also like our page.
The information collected by the plugins may also be used by the social network administrators for their own purposes, such as, for example, improving their own products, creating user profiles, analysing and optimising their own activities, targeting advertisements. We have no real influence on how the information collected by the plugins is subsequently used by the social network administrators. You can look for details in this regard in the rules and privacy policies of the individual social networks.
Social network plug-ins collect and transmit information to the administrators of these social networks even when you browse our website without being logged into your social network account. However, the browser then sends a more limited set of information.
If you have logged into one of the social networks, the site administrator will be able to directly attribute your visit to our website to your profile on the respective social network.
If you do not want the social networks to allocate the data collected during your visit to our website directly to your profile on the respective website, you must log out of the respective website before visiting our website. You can also prevent the loading of plug-ins on the website altogether by using appropriate extensions for your browser, e.g. blocking scripts.
In addition, the use of certain plugins may involve the publication of certain information within your social profiles. For example, information about clicks on the 'Like’ button may be available on your Facebook timeline. Of course, if you share any content on your social media using plugins embedded on our website, this sharing will naturally be visible on your profile.
With regard to the details related to the processing of the information collected by the plugins by the administrators of the social networks, in particular the purpose and scope of the data collection and its further processing and use by the administrators, as well as the possibility of contacting you and your rights in this respect and the possibility of making settings to ensure the protection of your privacy, you will find everything in the privacy policies of the respective service providers:
Yes, we use Google API tools that involve collecting information about your activity on our website. These tools are described in detail under the question on third-party cookies, so we will not repeat this information here either.
We do not use this type of tool.
The answer to this question can be found in many places in this privacy policy when describing individual tools, behavioural advertising, consent to cookies, etc. Nevertheless, we have once again gathered this information in one place for your convenience. Below you will find a list of options for managing your privacy.
The use of the website involves sending requests to the server where the website is stored. Each request made to the server is recorded in the server logs.
The logs include, among other things, your IP address, the date and time of the server, information about the web browser and the operating system you are using. The logs are saved and stored on the server.
The data stored in the server logs is not associated with specific users of the website and is not used by us to identify you.
The server logs are only ancillary material for the administration of the site, and their contents are not disclosed to anyone other than those authorised to administer the server.
The topics of personal data processing, the use of cookies and the management of privacy in general are quite complex. We have done our best to ensure that this document provides you with as much knowledge as possible on the issues that are important to you. If anything is unclear to you, if you would like to find out more, or if you would simply like to discuss your privacy, please send us an email at: office@frostinternationalrealestate.com.
Fill out the form. Optionally, write what you are looking for. We will send you listings that are not available on any portals.