Privacy policy

1. General provisions

This Privacy Policy sets out the rules for processing the personal data of users (“Users”) of the website investdom.org (the “Website”).

Users’ personal data are processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and other applicable laws.

2. Data controller

The controller of Users’ personal data is INVEST DOM s.c., ul. Szymanowskiego 16, 76-200 Słupsk, tax ID (NIP): 839-322-35-10, email: [email protected] (the “Controller”).

3. Scope of data processed

The Controller may process in particular the following categories of personal data provided through the forms on the Website or in direct contact:

• full name,
• email address,
• phone number,
• the content of the message sent through the contact form, including the development and unit the User is asking about,
• the email address and language given when subscribing to email notifications,
• other data voluntarily provided by the User when contacting the Controller.

Providing a name and a phone number or email address is necessary to use the contact form and receive a reply. Without these data the enquiry cannot be handled through the form. Other data are optional but may help the Controller reply or fulfil the User’s request.

In addition, when the Website is used, the Controller may process technical data recorded automatically in system logs, in particular: the IP address of the device, the date and time of use, information about the browser and operating system, and other operational data related to the use of the Website.

Technical data and log data are used to keep the Website secure (including protecting forms against abuse), to display its content correctly and – with consent – to compile visit statistics, on the basis of Art. 6(1)(f) GDPR (the Controller’s legitimate interest) or Art. 6(1)(a) GDPR (consent).

4. Purposes and legal bases of processing

Users’ personal data may be processed for the following purposes:

• replying to an enquiry, confirming its receipt and conducting correspondence – Art. 6(1)(f) GDPR (the Controller’s legitimate interest in handling correspondence);
• concluding and performing a contract, including handling reservations, requests and settlements – Art. 6(1)(b) GDPR (necessary to perform a contract or to take steps at the data subject’s request before entering into a contract);
• fulfilling the Controller’s legal obligations (e.g. under tax and accounting law and the law on housing price transparency) – Art. 6(1)(c) GDPR;
• establishing, pursuing or defending claims – Art. 6(1)(f) GDPR (the Controller’s legitimate interest);
• sending email notifications about new developments, price changes and the last available apartments – solely on the basis of consent (Art. 6(1)(a) GDPR), given by ticking the consent box in the form and confirmed by clicking the link sent to the email address provided;
• ensuring the security and technical stability of the Website – Art. 6(1)(f) GDPR (the Controller’s legitimate interest); compiling usage statistics and marketing using cookies – on the basis of consent (Art. 6(1)(a) GDPR).

Providing data is voluntary, but where marked as required it may be necessary to use certain features of the Website and to receive a reply to an enquiry.

5. Retention period

Personal data are kept for:

• the duration of the correspondence or contract, and then for the limitation period for claims related to that contract or enquiry;
• the period required by law – where data are processed to fulfil legal obligations (e.g. tax and accounting records);
• until consent is withdrawn – where processing is based on consent; withdrawal does not affect the lawfulness of processing before it;
• until any claims become time-barred – on the basis of the Controller’s legitimate interest.

Email notifications: we keep the email address, language, the date and wording of consent and the IP address at sign-up and confirmation – as proof of consent – until the User unsubscribes. Unconfirmed sign-ups are deleted after 30 days. After unsubscribing we keep only the email address and the unsubscribe date so that no further messages are sent to that address.

6. Recipients of data

Personal data may be shared with entities cooperating with the Controller to the extent necessary for the purposes above, in particular:

• providers of IT services and Website maintenance,
• hosting and email service providers,
• the sales office of the Mieszkania Kościelna development in Sławno – for enquiries about that development, which are sent directly to that office,
• providers of accounting, legal and advisory services,
• providers of analytics and marketing tools (Google, Meta) – as described in sections 8 and 9 (cookies only after consent),
• other subcontractors acting on the Controller’s behalf.

As a rule, data are not transferred outside the European Economic Area (EEA). If data were transferred to a third country, the Controller will apply the safeguards required by the GDPR (e.g. standard contractual clauses).

7. User rights

Users have the right to:

• access their personal data,
• rectify (correct) them,
• have them erased (“right to be forgotten”),
• restrict processing,
• data portability,
• object to processing – including direct marketing,
• withdraw consent at any time without affecting the lawfulness of processing before withdrawal – consent to email notifications can be withdrawn via the “Unsubscribe” link in every message, and consent to cookies via the “Cookie settings” link in the Website footer.

To exercise these rights, Users may contact the Controller at: [email protected].

Users also have the right to lodge a complaint with the President of the Personal Data Protection Office (UODO) if they consider that the processing of their personal data infringes the GDPR.

8. Cookies and similar technologies

The Website uses cookies and browser storage (localStorage) on the User’s device for the following purposes:

• necessary – remembering the User’s cookie choice and the selected theme (light/dark); always active, without them the Website cannot remember these settings,
• statistics (Google Analytics) – compiling visit statistics; cookies are set only after consent. Without consent the Google tag runs in a limited mode (Google Consent Mode): it sets no cookies or user identifier and only sends Google anonymous page-view signals (which cannot be linked to a specific person), used to estimate aggregated statistics,
• marketing (Meta Pixel – Facebook, Instagram; Google Ads) – measuring ad effectiveness and showing tailored ads on other websites; loaded only after consent.

On the first visit the Website asks for consent to statistics and marketing cookies. The choice can be changed at any time via the “Cookie settings” link in the Website footer.

Users can also manage cookies themselves, including blocking or deleting them, in their browser settings. Limiting cookies may affect some features of the Website.

9. External tools and third-party services

The Website uses third-party tools that may involve processing Users’ personal data (Google Analytics without consent – only in the limited mode described in section 8; other tools – after consent to cookies):

• Google Analytics (Google Ireland Ltd.) – visit statistics (e.g. aggregated data on page views, time on site, navigation paths);
• Meta Pixel (Meta Platforms Ireland Ltd.) – measuring ad effectiveness and showing Users personalised ads on Facebook and Instagram.

The neighbourhood maps on the Website are drawn directly on the page from OpenStreetMap data and do not fetch information about the User’s device from external services.

The providers of these tools are separate controllers or process data under data processing agreements concluded with the Controller. Details can be found in their privacy policies.

Using some external tools may involve transferring data outside the European Economic Area (EEA). In that case the Controller will apply the safeguards required by the GDPR (e.g. standard contractual clauses).

10. Automated decision-making and profiling

As a rule, Users’ personal data are not used for automated decision-making that produces legal effects concerning the User or similarly significantly affects them.

If the Controller uses profiling in the future (e.g. for marketing), Users will be clearly informed and, where necessary, asked for consent.

11. Changes to this Privacy Policy

The Controller reserves the right to amend this Privacy Policy, e.g. due to changes in the law or in the Website’s features.

The updated Policy will be published on the Website and applies from the moment of publication.