Privacy Policy and the GDPR

Privacy Policy, information provision requirement resulting from the GDPR – Clients

Keeping users’ data confidential is of exceptional importance for the Luxury Products Cylwik General Partnership managing a website under the following URL address: nieruchomosci.luxuryproducts.pl. Therefore, its Administrators have created this Privacy Policy, which informs the Clients about key legal bases for processing personal data of users, ways of collecting and utilizing them, as well as about rights of entities the data of whom are being collected. Luxury Products Cylwik General Partnership with its seat in Bialystok, Raginisa 9/10A Street (15-161), Bialystok, the registration acts of which are kept by the Regional Court in Bialystok, 12th Commercial Division of the National Court Register, under the following NCR number: 0000516574 and which is the holder of the 5423238705 TIN number and 200869111REGON number informs about personal data processing in compliance with the applicable law regulations in compliance with article 13 sections 1 and 2 of the Regulation of the European Parliament and of the Council (EU) 2016/679 of 27th April 2016 on the protection of natural persons in connection with personal data processing, on the unrestricted circulation of such data, and on the repeal of the 95/46/WE Directive (General Data Protection Regulation, hereinafter referred to as the “GDPR”):

1. Personal data administrator.

Luxury Products Cylwik General Partnership with its seat in Bialystok, Raginisa 9/10A Street (15-161), Bialystok, the registration acts of which are kept by the Regional Court in Bialystok, 12th Commercial Division of the National Court Register, under the following NCR number: 0000516574 and which is the holder of the 5423238705 TIN number and 200869111REGON number shall be the Administrator of personal data of the Users (hereinafter referred to as the “Administrator”), which means that it shall be the entity specifying the goals and methods of processing such data. This Privacy Policy shall be applicable when the Administrator processes personal data obtained directly from the entity they refer to, as well as when the Administrator has obtained said data from other sources.

When it comes to issues strictly connected with your personal data, you can contact the administration at the following e-mail: nieruchomosci@luxuryproducts.pl, via phone at: +48 791 394 349 or in writing, by sending a letter to the headquarters of the company specified in section 1 above.


2. Definition of personal data and ways of processing them

Personal data shall be understood as pieces of information on an identified or identifiable natural person. Personal data processing shall be understood as any activity oriented towards personal data utilization (performed in an automated manner or otherwise), including data gathering, storage, saving, ordering, modification, browsing, usage, sharing, use limiting, deletion, and erasing. Personal data shall be processed for various purposes. There shall be various ways of gathering them as well as various legal bases governing their processing, use, disclosure, and storage timeframes.

The Administrator processes personal data by using IT systems (including electronic call registration system in the case of concluding agreements and contracts via phone; in said case, the speaker is always informed about the call being recorded and about the possibility of hanging up if he or she does not express consent for his or her data being processed).
The processed pieces of information, including personal data, may incorporate, inter alia: company name, company’s seat location or the place of residence, the position of the contact person, phone number, e-mail address, and other contact data. What is more, in the case of individuals who have concluded fee or subscription-based agreements with the Administrator, additional payment-related data may be gathered, including credit card numbers and bank account numbers.



3. Aims and bases of processing.

The Administrator shall process your data as:

in relation to visiting the website managed by the Administration and taking advantage of digitally rendered services (legal basis: article 6 section 1 point b of the GDPR);
to manage claims, requests, notifications and technical requests sent via e-mail, phone, or in writing to the seat of the company specified in section 1 above (legal basis: article 6 section 1 point c of the GDPR);
to perform undertakings aiming at counteracting using services provided by the Website in a manner that is illegal or breaches Terms and Conditions by analyzing behavioral patterns of the Users of the Website (legal basis: article 6 section 1 point f of the GDPR);
for archiving (proof collection-related) purposes aiming at legally justified information protection by the Administrator shall the legal need to provide supervisory bodies with specific facts arise (legal basis: article 6 section 1 point f of the GDPR);
to pursue, specify, or defend against claims connected with the realization of the legally justified interests of the Administrator (legal basis: article 6 section 1 point f of the GDPR);
for analytic purposes, to select proper services adjusted to the needs of the Users, to optimize products basing on your feedback, and to optimize sales and post-sales servicing, including complaint handling as well being the realization of the legally justified interest of the Administrator (legal basis: article 6 section 1 point f of the GDPR);


to specify the satisfaction level of the Users basing on the legally justified interest of the Administrator connected with the assessment of servicing quality and service provision satisfaction after agreement conclusion (legal basis: article 6 section 1 point f of the GDPR);
to make it possible for the Administrator to offer goods and services, including adjusting them to the needs of the Clients (i.e. profiling) which will be done after obtaining a proper consent (legal basis: article 6 section 1 point a of the GDPR);
to directly offer the Clients products and services (direct marketing) of companies cooperating with the Administrator (Administrator’s partners), including adjusting them to the needs of the Clients (i.e. profiling) which will be done after obtaining a proper consent and will be the realization of legally justified interest of the Administrator and its partners (legal basis: article 6 section 1 point f of the GDPR).
Personal data shall be processed in compliance with the applicable law regulations, including the General Data Protection Regulation and the Act on 18th July 2002 on rendering digital services by the Seller. In some cases, personal data may be processed basing on a consent expressed by the User. In said case, while consent is obtained, the User will also be informed about the goal and scope of personal data processing.

4. Your rights pertaining to personal data and enforcement methods

You shall have the right to:
access data stored by the Administrator and receive a copy thereof;
change, update, and amend data pertaining to them;
in the case of data being processed basing on a granted consent – to withhold such consent at any time;
file a complaint to a supervisory body being the General Personal Data Protection Inspector (address: General Personal Data Protection Inspector, Stawki 2 Street, 00-193 Warsaw);
to the extent, to which the legally justified interest of the Administrator is the basis for data processing, to limit personal data processing and to disallow for their further use. Said right can be taken advantage of at any time. In such a case, the Administrator shall stop processing data for the discussed purpose, unless the Administrator is capable of proving that there are vital legal basis that are superior to your interests, rights, or that such data are required to pursue or defend against claims;
request personal data to be deleted or transferred.

All the aforementioned rights can be pursued by sending an e-mail message to the following address: nieruchomosci@luxuryproducts.pl, calling the following phone number: +48 791 394 349 or contacting the Administrator in writing by sending a request to the address specified in section 1. Personal data can be modified in applications by means of which the registration process has been executed.

5. Data storage timeframe

Your personal data shall be processed by the Administrator:
if the Administrator processes personal data basing on a consent granted, till the withdrawal of such consent;
if the Administrator processes such data on the basis of a legally justified interest of the Administrator, till the end of such interest (for example, for the period specified in the Civil Code or in other applicable legal regulations) or till the party such data pertain to disallows for further processing – providing that the applicable law regulations allow for that;
if the Administrator processes personal data as it is necessary due to applicable law regulations, till the moment specified in such regulations;
in the case of the lack of specific legal or agreement-specific regulations, the basic timeframe of keeping agreement-related documentation shall be maximally 10 years.
The Administrator shall keep personal data during the agreement validity period and after its elapse if there is a risk of claims being pursued in connection with its execution, but no longer than for 6 years till the agreement validity period elapse.

6. Data recipients (third parties and third countries)

Personal data of the Users may be disclosed to entities authorized to receive them in compliance with applicable law regulations, including some specific law enforcement bodies. Personal data of the Users may be also disclosed to third parties specified by the Administrator and providing services for the Users.
Your personal data may be disclosed to: Administrator’s partners that is – to companies the Administrator has been cooperating with while providing its services. The provided personal data shall be disclosed only to the extent to which and when it is needed and required by the applicable legal regulations. In such a case, while concluding an agreement with a third party, the Administrator shall specify security mechanisms that will ensure the proper protection of personal data, maintaining data protection standards, as well as granting their confidentiality and safety. The recipients of personal data disclosed by the Administrator may be:
entities processing data on the basis of agreements on personal data processing right transfer;
entities providing hosting services for the Administrator;
entities managing marketing or sales campaigns for the Administrator;
other Administrator’s subcontractors, including IT-specific companies providing hardware, software, and maintenance-related services;
suppliers of goods the Administrator has been using;
legal advisors, tax advisors;
law enforcement bodies, regulatory bodies, and other administrative bodies.
Personal data may be provided outside the European Economic Area to Google LLC basing on proper legal provisions being contractual clauses on personal data protection approved by the European Commission.

7. Automated decision-making

Pieces of information gathered by the Administration in relation to the use of the Website may be processed in an automated manner (in the form of profiling). Such an approach shall not result in any legal outcomes for the User, nor shall if affect his or her situation. The Administrator informs that:
for the purpose of profiling, no sensitive data are processed;
for the purposes of profiling, only pseudonimized data are utilized or such pieces of information of e-mail address, IP address, and Cookie files.
The aim of profiling is to analyze or to forecast personal preferences and fields of interest of individuals utilizing the website, adjust goods and services offered by the Administrator, and to make the content and products available on the Website compatible with Users’ preferences. Profiling may also be used for marketing purposes, in order to adjust marketing offers to users’ preferences. The Seller may utilize IP addresses of Clients gathered while visiting the website for technical and administrative purposes. Furthermore, IP addresses can be utilized to gather general statistical data allowing to specify traffic within the Website.

8. Amendments to this Privacy Policy

The Administrator shall attempt to regularly review this Privacy Policy and to change its content if needed. Amendments introduced may be caused by: new legal regulations, new recommendations of bodies responsible for supervising personal data protection-related processes, new technologies used to process personal data, as well as changes in ways, aims, and legal bases of personal data processing.

Terms and Conditions of individual services provided within the Website may include specific terms of personal data processing that are different from the ones discussed in this Privacy Policy. In the case of incompatibility between the two, the specific terms of personal data processing shall prevail, unless specified otherwise.

Dear User,
We would like to inform that within the scope of our website, we utilize online markers, such as Cookie files, to gather and process personal data for the purpose of personalizing content and advertising materials, as well as to analyze website traffic.
Cookie files are IT data stored in files and saved on your end device (such as your computer, phone, etc.), which your browser sends to the sever during every visit on the website from said device in the course of Internet browsing. Detailed information on Cookie files and their functioning can be found here. Familiarize yourself with the provided pieces of information and click the „Go to the website” button.