Privacy Policy

Dear Ladies and Gentlemen,

Aurec Capital Group companies take the security of your personal data and privacy very seriously. Below, acting in accordance with the requirements 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 the repeal of Directive 95/46/EC (hereinafter the “GDPR“), we provide you with information on how your data is processed and what rights you have as a result.

1. Pursuant to Article 4 (7) of the GDPR, the administrator of your personal data is LivUp

Management spółka z ograniczoną odpowiedzialnością Poland sp.j with its registered office in Warsaw (00-549), at ul. Piękna 18, entered to the register of entrepreneurs kept by the District Court for the capital city of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under KRS number 0000995911, (hereinafter the “Company”).

1. The Company has appointed a Data Protection Officer (DPO) who can be contacted on matters relating to data protection and the exercise of related rights. For this purpose, contact can be made by e-mail to the iod@aurec-capital.pl address or by post to the Company’s registered office.

1. Your personal data may be processed for the following purposes and on the following legal bases:

1. to carry out correspondence, including ongoing communication in relation to enquiries you make (e.g. enquiries about premises in which you are interested) which is a legitimate interest of the Company (legal basis for processing: Article 6(1)(f) of the GDPR),

1. to carry out activities in the form of direct marketing which is a legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) of the GDPR),

1. to send commercial information electronically (by e-mail) concerning offers for sale and lease of premises and other related services offered by LivUp

Management spółka z ograniczoną odpowiedzialnością Poland sp.j and other entities of the Aurec Capital Group operating in Poland – if a particular person

has agreed to receive this type of information (legal basis for data processing:

Article 6(1)(a) of the GDPR),

1. for marketing communication with the use of telecommunication terminal devices and automatic dialling systems (telephone calls, SMS/MMS messages) for the purpose of presenting offers for the sale and rental of premises and other related services offered by LivUp Management spółka z ograniczoną odpowiedzialnością Poland sp.j. and other entities of the Aurec Capital Group operating in Poland – if a specific person has given his/her separate consent for such communication to the designated telephone number (legal basis for data processing: Article 6(1)(a) of the GDPR),

1. to perform statistical analyses which is a legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) of the GDPR),

1. to store the data for archiving purposes and for the purpose of demonstrating the correctness of the fulfilment of the Company’s legal obligations, which constitutes its legitimate interest (legal basis for processing: Article 6(1)(f) of GDPR),

1. the internal administration of the business and administrative processes carried out within the Aurec Capital Group, which is a legitimate interest of the Company (legal basis for processing: Article 6(1)(f) of the GDPR).

1. Your personal data may be disclosed to the following entities:

1. entities supporting the Company with technical and IT services (including the provision, implementation and maintenance of software and IT hardware services, hosting services and similar),

1. marketing agencies providing services to the Company,

1. law firms providing services to the Company,

1. consulting, auditing and advisory entities – within the scope of the services provided by such entities to the Company,

1. providers of financial intermediation, interior design and fit-out services,

1. Aurec Capital Group entities – in the administration of internal administrative and business processes within the Capital Group.

1. Personal data may be transferred by the Company outside the European Economic Area (EEA). In such case, the Company will guarantee the legally required personal data

protection measures, which may be (as the case may be): I) transfer of data to an entity located in a third country for which an adequacy decision has been issued, as required by Article 45 of the GDPR, II) transfer of data carried out on the basis of a data transfer agreement with a third party based on the Standard Contractual Clauses adopted by decision of the European Commission, III) transfer of data carried out within the framework of the adopted binding corporate rules referred to in Article 47 of the GDPR. The person whose data is transferred in the aforementioned case has the right to obtain a copy of the information on the security measures in place. For more information on the Company’s security measures relating to the transfer of data outside the EEA, please contact us by email at iod@aurec-capital.pl or by post at the Company’s registered office.

1. The Company ensures the right to exercise the rights provided for under the GDPR, i.e. the right to request access to one’s personal data, the right to rectify, erase or request the restriction of processing, the right to data portability, as well as the right to object to its processing, under the terms and in the cases provided for in the GDPR.

1. In the case of processing of personal data by the Company for the purpose of pursuing its legitimate interests (as mentioned above), we inform you of your right to object to the processing of your data on grounds relating to your particular situation, and furthermore of your right to object at any time in the case of processing for direct marketing purposes.

1. In cases of processing of personal data on the basis of consent given, we inform you of the right to withdraw your consent at any time without stating a reason, which will, however, not affect the legitimacy of the processing that took place before your consent was withdrawn.

1. Personal data will be retained by the Company:

1. for the period of time necessary for the Company to document before public authorities, including the supervisory authority for the protection of personal data, the correctness of the fulfilment of its legal obligations,

1. for archiving purposes, where this concerns the history of correspondence and responses to enquiries made, for a maximum period of 3 years after the data was collected,

c) for direct marketing purposes – until such time as you object to the processing of your data or until the data is rendered obsolete,

1. for the purpose of sending commercial communications by electronic means (e-mail) or for marketing communications using telecommunications terminal devices and automatic dialling systems – until you withdraw your consent for such purposes or until your data becomes obsolete.

1. We inform you of your right to lodge complaints in relation to the processing of your personal data with the supervisory authority, which is the President of the Personal Data Protection Office.

1. Your data will not be processed in an automated manner that could at the same time lead to decisions being made against you that produce legal effects or similarly significantly affect you.

1. The provision of your personal data for the above-mentioned purposes is voluntary but necessary for the above-described purposes.