This privacy policy of the website available at www.konsultacje-dubaj.pl (hereinafter referred to as the “Website”) is informational in nature, meaning it does not impose obligations on Website users. The Privacy Policy sets out primarily the rules for the processing of personal data by the Administrator on the Website, including the legal bases, purposes, and scope of personal data processing, the rights of data subjects, as well as information regarding the use of cookies and analytical tools on the Website.
The controller of personal data collected through the Website and its owner is:
NDN REAL ESTATE CONSULTANTS LLC with its registered office in Dubai, United Arab Emirates (registered address: Emaar Square Building 6 Unit 702, Dubai, United Arab Emirates and mailing address: PO BOX 122347, Dubai, United Arab Emirates); Tax Registration Number (TAX REG. NO.): 104383347200001, email address: kontakt@demo.agencjacudo.pl, telephone number: +48 455444000 (call charges apply as per standard telephone connection rates in accordance with the user’s tariff plan).
(hereinafter referred to as the “Administrator” or “Owner“)
Quick contact:
Personal data on the Website is processed by the Administrator in accordance with applicable law, in particular in accordance with 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 referred to as “GDPR” or the “GDPR Regulation“. Official text of the GDPR: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679
Use of the Website is voluntary. Similarly, the provision of personal data by users of the Website is voluntary, subject to cases where it is necessary to use certain features of the Website, including, for example, the contact form. Failure to provide personal data required for a particular feature of the Website results in the inability to use that feature. The scope of data required to use each Website feature is indicated by the Administrator on the Website (e.g. prior to completing the contact form).
The Administrator takes particular care to protect the interests of data subjects and is responsible for ensuring that data collected is: (1) processed lawfully; (2) collected for specified, lawful purposes and not further processed in a manner incompatible with those purposes; (3) accurate and adequate in relation to the purposes for which it is processed; (4) stored in a form which permits identification of data subjects for no longer than is necessary for the purposes of processing; and (5) processed in a manner that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures.
Taking into account the nature, scope, context and purposes of processing, as well as the risks of varying likelihood and severity to the rights and freedoms of natural persons, the Administrator implements appropriate technical and organisational measures to ensure that processing is carried out in accordance with this Regulation and to demonstrate that fact. Those measures shall be reviewed and updated where necessary. The Administrator applies technical measures to prevent the acquisition and modification of personal data transmitted electronically by unauthorised persons.
This Website is informational in nature, enabling users to familiarise themselves with the Owner’s products or services and to contact the Owner, including by submitting an enquiry via the contact form. The Website may also offer a newsletter concerning the Owner’s activities, news, and new products and services. The governing law for this Website, these terms, and any agreements concluded hereunder is Polish law.
The Website is not an online store and no contract of sale may be concluded through it (meaning, among other things, that advertisements, price lists, and other product information published on the Website should not be treated as an offer, but rather as an invitation to enter into negotiations). A contract of sale may be concluded following a price enquiry submitted to the Owner and only after the parties have agreed on the detailed terms of such a contract — the conclusion and terms of such a contract are governed by a separate sales agreement or separate general terms and conditions of sale made available by the Owner.
The Administrator is entitled to process personal data where — and to the extent that — at least one of the following conditions is met: (1) the data subject has given consent to the processing of their personal data for one or more specific purposes; (2) processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract; (3) processing is necessary for compliance with a legal obligation to which the Administrator is subject; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Administrator or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
Processing of personal data by the Administrator requires, in each case, the existence of at least one of the bases set out above. The specific legal bases for the processing of personal data of Website users by the Administrator are indicated in the following section of this Privacy Policy, with reference to each particular purpose of processing.
The purpose, legal basis, scope, and recipients of personal data processed by the Administrator are determined on a case-by-case basis by the actions taken by each user on the Website.
The Administrator may process personal data on the Website for the following purposes, on the following legal bases, for the following retention periods, and within the following scope:
| Purpose of Processing | Legal Basis | Retention Period |
|---|---|---|
| Performance of an agreement for the provision of Electronic Services or taking steps at the request of the data subject prior to entering into a contract | Article 6(1)(b) GDPR (performance of a contract) — processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract | Data is retained for the period necessary for the performance, termination or expiry of the contract for the provision of electronic services concluded with the Administrator. |
| Direct marketing | Article 6(1)(f) GDPR (legitimate interests of the controller) — processing is necessary for the purposes of the legitimate interests pursued by the Administrator, consisting in maintaining the Administrator’s interests and good reputation and pursuing the sale of products or services | Data is retained for the duration of the legitimate interest pursued by the Administrator, but no longer than the limitation period for claims against the data subject arising from the Administrator’s business activity. Limitation periods are determined by law, in particular the Civil Code (the standard limitation period for claims related to business activity is three years, and two years for a contract of sale). The Administrator may not process data for direct marketing purposes if the data subject lodges an effective objection in this regard. |
| Marketing | Article 6(1)(a) GDPR (consent) — the data subject has given consent to the processing of their personal data for marketing purposes by the Administrator | Data is retained until the data subject withdraws consent to the further processing of their data for this purpose. |
| Establishment, assertion or defence of claims that may be raised by or against the Administrator | Article 6(1)(f) GDPR — processing is necessary for the purposes of the legitimate interests pursued by the Administrator, consisting in the establishment, assertion or defence of claims | Data is retained for the duration of the legitimate interest pursued by the Administrator, but no longer than the limitation period for claims arising from the Administrator’s business activity (the standard limitation period is three years). |
| Use of the Website and ensuring its proper functioning | Article 6(1)(f) GDPR (legitimate interests of the controller) — processing is necessary for the purposes of the legitimate interests pursued by the Administrator, consisting in operating and maintaining the Website | Data is retained for the duration of the legitimate interest pursued by the Administrator, but no longer than the limitation period for the Administrator’s claims against the data subject arising from the Administrator’s business activity (the standard limitation period is three years). |
| Compiling statistics and analysing traffic on the Website | Article 6(1)(f) GDPR (legitimate interests of the controller) — processing is necessary for the purposes of the legitimate interests pursued by the Administrator, consisting in compiling statistics and analysing Website traffic in order to improve the functioning of the Website | Data is retained for the duration of the legitimate interest pursued by the Administrator, but no longer than the limitation period for the Administrator’s claims against the data subject arising from the Administrator’s business activity (the standard limitation period is three years). |
The proper functioning of the Website requires the Administrator to use the services of external entities (such as software providers). The Administrator uses only the services of processors who provide sufficient guarantees of implementing appropriate technical and organisational measures to ensure that processing meets the requirements of the GDPR and protects the rights of data subjects.
Personal data may be transferred by the Administrator to a third country, provided that the Administrator ensures such transfers take place to countries ensuring an adequate level of protection in accordance with the GDPR, and in the case of other countries, that the transfer is carried out on the basis of standard data protection clauses. The Administrator ensures that data subjects can obtain a copy of their data. The Administrator transfers collected personal data only where necessary and to the extent required to achieve the relevant processing purpose in accordance with this Privacy Policy.
Data may be transferred to the following recipients or categories of recipients:
The GDPR requires the Administrator to provide information about automated decision-making, including profiling referred to in Article 22(1) and (4) of the GDPR, and — at least in those cases — meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject. With this in mind, the Administrator sets out below the relevant information regarding potential profiling.
Profiling on the Website consists of the automated analysis or prediction of an individual’s behaviour on the Website, for example through the browsing of specific product pages. Such profiling requires the Administrator to hold personal data of the relevant individual in order to subsequently send them, for example, a discount code.
The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
Right of access, rectification, restriction, erasure or portability — the data subject has the right to request from the Administrator access to their personal data, its rectification, erasure (“right to be forgotten”) or restriction of processing, as well as the right to object to processing and the right to data portability. The detailed conditions for exercising these rights are set out in Articles 15–21 of the GDPR.
Right to withdraw consent at any time — where personal data is processed by the Administrator on the basis of consent (pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR), the data subject has the right to withdraw consent at any time without affecting the lawfulness of processing carried out on the basis of consent prior to its withdrawal.
Right to lodge a complaint with a supervisory authority — the data subject whose data is processed by the Administrator has the right to lodge a complaint with a supervisory authority in the manner and under the procedure set out in the GDPR and Polish law, in particular the Personal Data Protection Act. The supervisory authority in Poland is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych).
Right to object — the data subject has the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data based on Article 6(1)(e) (public interest or official authority) or Article 6(1)(f) (legitimate interests of the controller), including profiling on the basis of those provisions. In such a case, the Administrator may no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or grounds for the establishment, exercise or defence of legal claims.
Right to object to direct marketing — where personal data is processed for direct marketing purposes, the data subject has the right to object at any time to the processing of their personal data for such marketing, including profiling to the extent that it is related to such direct marketing.
To exercise any of the rights referred to in this section, the data subject may contact the Administrator by sending a written or electronic message to the Administrator’s address indicated at the beginning of this Privacy Policy.
Cookies are small pieces of textual information in the form of text files sent by a server and stored on the device of the person visiting the Website (e.g. on the hard drive of a computer, laptop, or on the memory card of a smartphone — depending on the device used to visit the Website). Detailed information about cookies and their history can be found, among other places, at: https://pl.wikipedia.org/wiki/HTTP_cookie
The Administrator may make available on the Website a tool for easy and active cookie management — accessible upon first visit to the Website and subsequently available in the Website’s footer. Active management allows users to, among other things, check which cookies are or may be stored when using the Website, as well as to select and subsequently modify the scope and purposes of cookie use in relation to their device and browsing session. Upon first visiting the Website, the user will be asked to choose their cookie settings. These settings may be changed at a later time via the management tool available on the Website.
Cookies sent by the Website may be classified according to the following criteria:
By provider: first-party (created by the Administrator’s Website) and third-party (created by entities other than the Administrator).
By storage duration: session cookies (stored until the user leaves the Website or closes the browser) and persistent cookies (stored for a defined period specified by the parameters of each file, or until manually deleted).
By purpose:
The Administrator may process data contained in cookies when users visit the Website for the following specific purposes:
To check which cookies (including their lifespan and provider) are currently being sent by the Website, users may follow these steps in the most popular browsers:
By default, most web browsers accept cookies. Each user may define their cookie preferences through their browser settings, allowing them to partially restrict (e.g. temporarily) or entirely disable the saving of cookies — though the latter may affect certain Website features.
Browser settings regarding cookies are relevant from the perspective of consent to the use of cookies by the Website — under applicable regulations, such consent may also be expressed through browser settings. Detailed information on changing cookie settings and manually deleting cookies in the most popular browsers is available in the browser’s help section and at the following links:
The Administrator may use on the Website the services of Google Analytics 4 and Google Search Console, provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). These services assist the Administrator in compiling statistics and analysing traffic on the Website. Data collected within these services is processed to generate statistics useful in administering the Website and analysing traffic. Such data is aggregated in nature. Through the use of these services, the Administrator collects data such as sources and mediums through which visitors arrive at the Website, their behaviour on the Website, information about the devices and browsers used, IP addresses and domains, geographic data, and demographic data (age, gender) and interests.
Users may easily block the sharing of information about their Website activity with Google Analytics by installing the browser add-on provided by Google Ireland Ltd., available at: https://tools.google.com/dlpage/gaoptout?hl=pl
In connection with the possible use of services provided by Google Ireland Ltd. on the Website, the Administrator notes that full information on the principles of processing data of Website visitors (including information stored in cookies) by Google Ireland Ltd. is available in the Google Privacy Policy at: https://policies.google.com/technologies/partner-sites
The Website may contain links to other websites. The Administrator encourages users, upon navigating to other websites, to review the terms and privacy policies established thereon. This Privacy Policy applies solely to this Website.
Should you have any questions or concerns regarding the use of the Website, please contact the Website Owner: