Privacy Policy
effective as of 25 May 2018.
The security of your personal data is very important to us. We are committed to ensuring that their processing is carried out to the highest standards, which is why we have prepared this privacy policy, which describes how and for what purpose we process your personal data and what rights you have.Spruce
Who is the controller of your personal data?
The administrator of the personal data is:
AV INWESTOR Spółka akcyjna, REGON: 016309328, NIP: 5262468310, ul. Ratuszowa 11, 03-450 Warsaw, entered in the Register of Entrepreneurs of the National Court Register kept by the Registration Court for the Capital City of Warsaw in Warsaw, XXI Economic Division of the National Court Register under the number 0000229750.
Owner of the website available at: www.avinwestor.com hereinafter referred to as the ‘website’ correspondence e-mail address: office@avinwestor.com
Why do we process your personal data?
We process personal data in connection with the services provided through the website, as well as ancillary processes designed to ensure the highest level of satisfaction with our services and products.
What personal data do we process?
We process personal data obtained from you in the course of using our website only when you use the contact form and subscribe to the mailing list.
We process the following categories of personal data:
contact data related to the use of the contact form and subscribing to the mailing list, such as your name, e-mail address, telephone number, VAT number, mailing address.
data relating to your use of our service and your behaviour on our site which is collected automatically (including but not limited to type of device used, unique device number, device IP address, operating system, browser type, website usage and diagnostic information, search history, session summary, location information and other data provided automatically through your web browser).
What is the legal basis for processing personal data?
The processing of your personal data is necessary for the use of some of our accessible services such as using the contact form or subscribing to the mailing list.
In addition, we may process personal data within the framework of legitimate interests in order to offer, improve the quality and development of our services and products, marketing communications and advertising, to ensure user security, to combat fraud and abuse, or if necessary to establish and protect our rights or assert claims.
We also process personal data on the basis of and within the framework of our obligations under applicable law.
For how long will we process your personal data?
We will process your personal data for as long as you do not contact us to have it deleted.
After this period, your data will be deleted unless further processing to a certain extent is a legal obligation, remains necessary for the fulfilment of contractual obligations, to ensure user security, to combat fraud and abuse or to establish and protect our rights or assert claims.
Do we process your data automatically (including through profiling)?
Some personal data may be processed automatically by us, in particular for the purposes of statistical analysis or the presentation of personalised marketing content, but this will not affect your rights or have any legal effect.
Where do we store your personal data?
Your personal data will be stored in countries of the European Economic Area (‘EEA’). However, some of the services we use may also require data to be transferred and processed outside the EEA. Any such transfer of personal data will comply with applicable laws and will be based on appropriate legal safeguards (standard contractual clauses for the protection of personal data approved by the European Commission).
With whom do we share your personal data?
Service providers
We share personal data with partner services and companies that provide services for us, such as hosting and data storage, mailing, data analysis and customer satisfaction surveys, and other services that are necessary or supportive of conducting business electronically to ensure quality service, user satisfaction and security. We may also share personal data with entities that provide the following services for us: accounting services, payroll services, marketing services, IT services, financial services,
legal services, consulting services and other services related to the running of the business. Entities that process personal data as part of the services they provide to us are obliged to ensure that your personal data is protected and that your rights are respected in accordance with applicable law.
Related parties
We may share personal data with entities that are related to us personally, by equity or otherwise. In the event of a merger or acquisition, as well as the reorganisation of our business, entering into joint ventures with other entities, and the spin-off or disposal of all or part of our business, we may transfer some or all of your personal information to other entities.
Legal obligations and security
We may transfer personal data to competent administrative authorities, institutions and other authorised entities at home and abroad if we are required to do so by applicable law, as well as at their request within the framework of procedures provided for by law. We may also transfer personal data to authorities, institutions and third parties for the purpose of ensuring user security, combating fraud and abuse, or if this is necessary to establish and protect our rights or assert claims.
What rights do you have?
You benefit from a number of rights in relation to the processing of your personal data. You can obtain further information about the scope and exercise of your rights by contacting us via email address: office@avinwestor.com
Right of access to data
You have the right to request information from us about whether we process your personal data and, among other things, to what extent, for what purpose and in what way we do so, with whom we share the data we hold and where we obtained the data from. You can make a request to this effect via the contact email address we have indicated or by any other means of your choice.
Right to data portability
You have the right to receive a copy of the personal data you have provided to us in a structured, commonly used and machine-readable format, and to request that the data be transferred to another entity.
Right of rectification
You have the right to request us to correct incorrect data without delay and, taking into account the purposes of the processing, to supplement incomplete personal data, including by providing an additional statement.
Right of erasure
You have the right to request the immediate deletion of personal data concerning you when:
are no longer necessary for the purposes for which they were collected or otherwise processed,
you have withdrawn your consent to the processing and we have no other valid basis for processing,
you have objected and there are no overriding legitimate grounds for the processing,
your personal data has been unlawfully processed,
the personal data must be erased in order to comply with a legal obligation.
However, there may be legitimate exceptional cases in which we are unable to comply with your request.
Right to restrict processing
You have the right to request that we restrict the processing of your personal data:
if you believe your data is incorrect and you report it to us – we will restrict the processing until we have checked the accuracy of the data,
if the processing is unlawful but you do not agree to the erasure of the data,
if we no longer need your personal data for the proper purposes of the processing, but it is necessary for the purposes of pursuing claims, establishing or protecting your rights,
if you object to the processing, until we have investigated whether we have a legitimate overriding interest justifying further processing despite your objection.
Right to withdraw consent to processing
If the basis for the processing of your personal data is your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of our processing of your personal data that we have already carried out on the basis of your consent prior to its withdrawal.
Right to object
You have the right to object at any time to the processing of your personal data (including profiling) for purposes arising from the legitimate interests of the controller or a third party. Further processing is only possible,
when there are valid legitimate overriding grounds for the processing of your personal data or the data in question are necessary for the assertion, establishment or protection of your rights.
Right not to consent to direct marketing
You have the right to object at any time to the processing of your personal data for direct marketing purposes (including profiling) to the extent that the processing is related to such direct marketing. If you object, your personal data will not be used for such purposes.
How can you exercise your rights?
The law does not require a specific form or method of communication for the exercise of your rights. Contact channel via email for enquiries, notifications and requests related to the exercise of the above rights: office@avinwestor.com
Right to lodge a complaint with a supervisory authority
If you believe that we are processing your personal data inappropriately, you can always contact us, as well as lodge a complaint with the supervisory authority (President of the Office for Personal Data Protection).
Updating the Privacy Policy
If it becomes necessary to update this privacy policy, you will always have access to the current version on our website. We will also inform you of any significant change as soon as it is implemented.