PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA AND YOUR RIGHTS
under Art. 13 and 14 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
(hereinafter referred to as the „GDPR“)
In case you are providing your personal data, we as a data controller and owner of the Varso Place, CHM 2 SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ with its registered seat in Warsaw, address: Postępu 14 street, 02-676 Warsaw and CHM 1 SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ with its registered seat in Warsaw, address: Postępu 14 street, 02-676 Warsaw (hereinafter referred to as the “HB Reavis” or “we”), would like to inform you about the processing of your personal data and of your rights related to the said processing.
HB Reavis is part of the HB Reavis Group, which consists of all entities consolidated under the group holding HB Reavis Holding S.A. with its headquarters in Luxembourg (hereinafter referred to as the “HB Reavis Group“) due to which the reference to HB Reavis Group may be found in the Privacy Notice.
What is our purpose for processing your personal data?
1. Ensuring the safety of visitors and users of the building as well as protection of the building and property.
2. Acceptance, processing and handling of complaints.
3. The issuing of entry cards.
4. Acceptance, processing and handling of insurance claims.
5. Mutual communication.
6. Promotion of our events.
7. Sending of reminders.
8. Invoice issuance.
Description of our purpose:
1. If you enter into the building or garage or take part in events organized by one of the building tenants, then:
a) we verify your identity at reception for the purpose of ensuring security and protection of the building as well as people using the building;
b) in case that our tenant is using our visitor management system we will process personal data to be able to provide you with the QR code to enter the building;
c) we make a photograph of your face as well as your vehicle licence plate number (LPNo) in case you use the intercom system located at the ramp or enter the garage using an entry card;
d) we scan your LPNo in the case if LPNo recognition technology or a UHF code functioning for the automatic opening on the ramp to authorised vehicles is used in conjunction with the vehicle;
e) we collect data regarding the entry card upon entry and departure through contact points in the building, i.e. from the public part to the private part of the building, so that we ensure access to authorised persons only;
f) we produce your audio-visual images by means of an installed CCTV camera system, which records the internal spaces of the building and a part of the area outside the building.
2. In each lift in the building, as well as at the entrance to the garage, there are voice communicators, through which it is possible to contact the central security desk of the building in real-time, should a problem arise. These calls are recorded, so that in case of a complaint associated with the handling of a problem, we have available an audio recording of the given event.
3. In order for us to permit you to enter the premises of your employer, we will issue to you an entry card which allows you access to restricted premises of the building. Moreover, we will issue to you a temporary entry card in case that you are a guest of our tenant.
4. Personal data that you provide to our company will be used mainly in the following processing activities:
- recording of the insurance claim,
- examination of the insurance claim with the insurance company,
- to provide a notification about the result of the insurance proceedings with the insurance company.
5. Our philosophy is to be open and transparent at all times. This includes being open to communication from any person interested in HB Reavis. To fulfill this goal, we created several types of contact forms which can be used to contact us. Additionally, we have also published emails of particular employees working for us, so you can contact them at any time with any question related to our building and business you may have. However, to ensure such effective, flawless and clear communication, we process some of your personal data.
6. Furthermore, we may process your personal data by taking the photographs and audio-visual recordings, which are used for the purpose and legitimate interests of promotion of our events and services and to help us improve our brand and goodwill by providing you with our newsletters and follow-up marketing materials related to our events and publishing the photographs (where you can appear) and audio-visual recordings on our social media profiles such as YouTube, LinkedIn, Facebook, Twitter and Instagram and via other channels such as our websites
7. We also process your personal data for the purpose of sending reminders related to unsend webpage forms. Whenever you start filling out any webpage form published on our website, we automatically process the personal data you fill in. In some cases, you might forget to send the form, therefore we use the automatically saved personal data to remind you to finish filling out the form or to send the filled-out form.
8. In order for us to issue VAT invoices for using parking lots in the Forest buildings we have to process some personal data. In such cases necessary personal data is transferred to the reception.
What is our legal basis for the processing of your personal data?
1. We process your personal data on the basis of the legitimate interests under Article 6 (1) (f) of GDPR for the protection of our rights and interests and for ensuring security in our premises.
2. In case of acceptance, processing and handling of complaints, we process your personal data on the basis of the legitimate interests under Article 6 (1) (f) of GDPR.
3. We process your personal data on the basis of legitimate interests under Article 6 (1) (f) of GDPR to issue entry cards.
4. Your personal data are processed during the insurance proceedings in accordance with Article 6 (1) (c) GDPR, i.e. the processing is necessary for compliance with a legal obligation to which our company is subject.
5. If you contact us via e-mail or web-based form, we process your personal data on the basis of legitimate interests under Article 6 (1) (f) of GDPR.
6. In case of promoting our events and services provided by us, we process your personal data on the basis of the legitimate interests under Article 6 (1) (f) of GDPR.
7. We process your personal data on the basis of legitimate interests under Article 6 (1) (f) of GDPR to send you reminders related to unsend webpage forms.
8. Your personal data are processed during the insurance proceedings in accordance with Article 6 (1) (c) GDPR, i.e. the processing is necessary for compliance with a legal obligation to which our company is subject.
What kind of personal data do we process?
1. a) Name and Surname;
b) Your Photograph and Photograph of LPNo;
c) Photograph of LPNo;
d) card number, place and entry time;
e) Audio-visual image of yourself.
2. An audio recording containing your audio track.
3. Name, Surname and business name of your employer in case that you are guest we will process only name and surname.
4. Requested data in the insurance form.
5. Name, surname, e-mail address and phone number.
6. Photograph or/and audio-visual image of yourself.
7. Personal data requested by the particular webpage form (such as name, surname, e-mail, phone number etc.).
8. In case of payment under 450 PLN we process Tax Identification Number assigned by the parking user to his receipt. In case of payment over 450 PLN, we process: (i) name and surname/name of the company, (ii) address, (iii) Tax Identification Number, (iv) receipt with Tax Identification Number on it and (v) parking ticket.
How long do we store your personal data?
1. a) We store your personal data for 15 days.
b) We store your personal data for 15 days.
c) We store your personal data for 15 days.
d) We store your personal data for 30 days.
e) We store your personal data for 15 days.
2. We store your personal data for 15 days.
3. During your contractual relationship with our tenant or the duration of rental relationship which relationship will end sooner. In case that you are guest of our tenant we will store your personal data for 30 days.
4. Your personal data will be processed during the period set by the applicable legal obligation or line with it.
5. If you contact us or any employee via e-mail or web-based form, we store your personal data until you unsubscribe from our contact database.
6. We store your personal data during the time strictly necessary to achieve the given purpose.
7. We store your personal data for 30 days.
8. Your personal data will be processed during the period set by the applicable legal obligation or line with it.
As soon as we no longer need your personal data for the processing purposes for which the personal data have been collected, we will delete them unless the statute-barred period applies. Certain details and correspondence may be retained until the time limit for claims, in respect of the pre-contractual or contractual relationship, has expired or in order to comply with regulatory requirements regarding the retention of such personal data.
With whom do we share your personal data?
We may share your personal data within the companies in HB Reavis Group or with our business partners with which we have conducted an agreement as they are in position of processors, controllers or joint-controllers. We also may be obliged to provide your personal data to public authorities, in particular courts and law enforcement agencies (police and prosecutors) only to the extent necessary and within the limits of the law.
From whom do we get the personal data?
We get personal data from you or from our tenant.
Do we use automated individual decision-making?
No, we do not use automated individual decision-making.
Do we transfer your personal data to third countries?
Your personal data are processed within the territory of the Republic of Poland and other states of the European Union. Your personal data can be processed by a country outside of European Union if this third country has been confirmed by the European Commission as a country with adequate level of data protection or if other appropriate data protection safeguards exist (for example, binding corporate privacy rules or EU standard data protection clauses).
Personal data may also, in justified cases, be subject to use (processing) for the purpose of dealing with legal matters, including the performance of public authority obligations and monitoring for possible legal protection. Personal data may also be archived for a given public interest, as well as for scientific, historical or statistical research.
What are your rights?
Your rights as a data subject are stated below. Please note that the exact conditions to exercise these rights are set out in detail in Chapter III of GDPR, while in a particular circumstance not all rights may be exercised. You have following rights:
- Access to personal data we process about you
- Rectification of incorrect or inaccurate personal data and add incomplete personal data
- Restriction, i.e. blocking of processing of your personal data
- The deletion of personal data in case the purpose absence or unauthorized data processing
- Submission of an objection to the processing of personal data if you believe that our data processing is not justified
- Be excluded from automated decision-making
- Listing of personal data in a structured and machine-readable format or for another controller
- Revocation of consent to the processing of personal data
- To lodge a complaint with the supervisory authority
How can you exercise your rights?
In writing to the address: Postępu 14 St. 02-676 Warsaw or at HB Reavis Group s.r.o., Twin City C, Mlynské Nivy 16, 821 09 Bratislava, Slovakia
Telephone: +421 918 723 243
We strive to protect your privacy as much as possible and therefore we process your personal data in compliance with GDPR and all other relevant laws. However, if you disagree with the way we handle your personal data, you can exercise your rights via our Data Protection Officer at:
Data Protection Officer’s contact: Erika Wild, contact point at Twin City C, Mlynské Nivy 16, 821 09 Bratislava, Slovak Republic, tel. +421 918 723 243, email: email@example.com
Or you can file a complaint in supervising authority regarding the processing of your personal data. Your local supervisory authority may be found at: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm