Personal data processing policy

This information is provided pursuant to Article 13 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, repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the “GDPR”).

For the purposes of this Policy:

„Polus Towers“ means the office buildings named Polus Tower I and Polus Tower II located on Vajnorská Street in Bratislava, as further described on the website www.polustowers.sk.

„Wood&Company“ means Wood & Company, a.s., with its registered office at Gorkého 4, 811 01 Bratislava, Slovak Republic, Company ID No.: 35 827 092, registered in the Commercial Register of the Bratislava III Municipal Court, Section: Sa, File No.: 3093/B.

„WREM“ means WOOD Real Estate Management, s.r.o., with its registered office at Tomášikova 64, 831 04 Bratislava, Slovak Republic, Company ID No.: 35 790 474, registered in the Commercial Register of the Bratislava III Municipal Court, Section: Sro, File No.: 21945/B.

POLUS, a.s.
Company ID No.: 35 906 294
Vajnorská 100, 831 04 Bratislava
info@polustowers.sk

If you have any questions regarding this Policy, the use of personal data, or if you wish to exercise your rights described in this Policy, you may contact our Company by email or in writing at the address indicated above.

The scope of the personal data processed is limited only to the data necessary to achieve the relevant purpose, or only to the data for the processing of which you have given your consent, if such consent has been given.

We obtain personal data mainly directly from you as the data subject or from tenants of Polus Towers.

Before entering into a contract with our Company, the provision of your personal data is voluntary. If you enter into negotiations for concluding a contract and subsequently conclude a contract with us in relation to Polus Towers, the requirement to provide your personal data arises from the relevant legal regulations, i.e. without the provision of your data it will not be possible to conclude a valid contract and subsequently perform the obligations arising therefrom, as well as the obligations arising from the law and related to the existence of such contract.

We process your personal data as controller on the following legal bases and for the following purposes.

Purposes related to the performance of a contract or to steps taken at the request of the data subject prior to entering into a contract, pursuant to Article 6(1)(b) GDPR:

Purpose: Presentation of Polus Towers and communication within pre-contractual relationships or negotiations regarding your expressed interest (e.g. request for a price quotation, questions concerning the offer of premises, etc.).
Personal Data: Email address, and if you included them in the text of the contact form or provided them to us in the course of communication, also the following data: first name, last name, telephone number, and any other personal data that you included in the text of the contact form or provided to us in the course of communication
Retention Period: For the period necessary to answer your question submitted via the contact form, or for the duration of our pre-contractual communication, but no longer than 3 months from your last contact.

Purpose: Performance of contracts with tenants, or negotiation of a contract with prospective tenants in connection with the lease of premises in Polus Towers.
Personal Data: Relevant identification, payment and contact details as specified in the relevant contract between you and our Company.
Retention Period: During the contractual relationship and thereafter for the period necessary to assert claims arising from the contract; in specific cases, e.g. for the purpose of protection against a threatened or existing dispute, the processing period shall be extended until the relevant circumstance ceases to exist (e.g. the termination of court proceedings).

Purposes related to compliance with a legal obligation pursuant to Article 6(1)(c) GDPR:

Purpose: Fulfilment of our obligations in the area of accounting, taxation and archiving.
Personal Data: Relevant identification, payment and contact details contained in contractual, accounting and tax documents.
Retention Period: For a period of 10 years from the end of the tax period in which the transaction took place, unless legal regulations provide otherwise.

Purposes related to the legitimate interests pursued by the controller pursuant to Article 6(1)(f) GDPR:

Purpose: Communication with our existing customers that are legal entities. The legitimate interest pursued by this processing is our ability to communicate with our customers that are legal entities during pre-contractual negotiations and after the conclusion of a contract in connection with its performance and the exercise of our contractual rights and obligations.
Personal Data: Relevant identification and contact details contained in contractual documentation concluded with our customers – legal entities or otherwise notified to us by our customers – legal entities.
Retention Period: During pre-contractual negotiations and for the duration of the contractual relationship with customers – legal entities. Thereafter for the period necessary to assert claims arising from such contractual relationship; in specific cases where justified by a specific interest, e.g. for the purpose of protection against a threatened or existing dispute, the processing period shall be extended until the relevant circumstance ceases to exist (e.g. the termination of court proceedings).

Purpose: Provision of our newsletter to our existing customers and other marketing communication addressed to our existing customers. The legitimate interest pursued by this processing is our ability to provide our existing customers with information regarding other apartments, premises and related services offered within the Project, and other information relating to the Project.
Personal Data: Relevant identification and contact details to the extent necessary for marketing purposes.
Retention Period: For the duration of our legitimate interest, but no longer than until you object to the processing of your data for this purpose or unsubscribe from the newsletter.

When processing personal data, we respect your rights as a data subject. Pursuant to the applicable legal regulations, as a data subject you have several rights in relation to the processing of your personal data, depending on the legal basis and purpose of processing:

• the right to information about the processing of your personal data;
• the right to obtain access to the personal data concerning you that are processed and stored;
• the right to request rectification of inaccurate, incorrect or incomplete personal data;
• the right to request erasure of personal data when they are no longer necessary or if the processing is unlawful;
• the right to object to the processing of personal data for marketing purposes or for other purposes based on the legal basis under Article 6(1)(f) GDPR;
• the right to request restriction of the processing of your personal data in specific cases;
• the right to receive personal data in a machine-readable format and/or request their transfer to another controller;
• the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal, if you have granted such consent;
• the right to request that decisions based on automated processing concerning you or significantly affecting you, based on your personal data, be carried out by natural persons and not by automated technical means, if personal data are processed by the controller in this manner. You have the right to express your point of view and object to the controller’s decision;
• the right to submit a request or complaint to the controller in connection with the protection and processing of your personal data. Any data subject wishing to submit a request or complaint and exercise their rights may do so in person, by letter or electronically using the contact details specified in Article 2 above;
• the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, and the right to an effective judicial remedy if you consider that the processing of your personal data is contrary to legal regulations. The supervisory authority in the territory of the Slovak Republic is:

Úrad na ochranu osobných údajov SR (Office for Personal Data Protection of the SR)
Hraničná 12, 820 07 Bratislava 27, Slovenská republika
website: www.dataprotection.gov.sk
tel.: +421 2 3231 3214
​​​​​​​e-mail: statny.dozor@pdp.gov.sk

The recipients of your personal data include Wood&Company, WREM, service providers for our Company and external advisers, such as providers of software systems, IT services, postal and courier service providers, translators, accounting and tax advisers, legal advisers and marketing agencies.

Where necessary, your personal data may also be provided to courts and public authorities for the purpose of compliance with our Company’s legal obligations, enabling supervision over our Company’s activities, the exercise of powers of courts and public authorities, dispute resolution and enforcement of decisions.

Your personal data are not processed exclusively by automated means but are always also processed by our trained personnel.

We process your personal data primarily within the territory of the Slovak Republic, or within Member States of the European Union.

A transfer of personal data to a country outside the European Union may take place only if an adequate level of protection of personal data is ensured in accordance with the applicable legal regulations. Such transfer shall take place if the European Commission has decided that the given third country ensures an adequate level of personal data protection, or if other appropriate safeguards have been adopted, such as standard contractual clauses or binding corporate rules.

We have adopted and continuously maintain appropriate technical, organisational and security measures, the purpose of which is to ensure the protection of personal data against loss, destruction, damage, unauthorised access, alteration, disclosure or any other impermissible processing. We set these measures considering the nature, scope, context and purposes of the processing of personal data, as well as the possible risks to the rights and freedoms of data subjects and the current state of technological development.

The measures adopted also include internal control mechanisms, the establishment of rules governing access to personal data, and ensuring that only authorised persons who are bound by confidentiality obligations and have been appropriately instructed or trained come into contact with personal data.

If you are interested in more detailed information regarding the protection of your personal data, you may contact us using the contact details specified in Article 2 of this Policy.

The information that we are required to provide to you in relation to our processing of personal data may change or cease to be current. For this reason, we reserve the right to amend thisPolicy. If we materially change this Policy, we will bring such change to your attention. The current version of this Policy will always be available on the Company’s website.