P o l i t y k a   p r y w a t n o ś c i

§ 1
Basic information about the Website

This Privacy Policy shall set forth the rights and obligations of Users of the website of Ciril Poland Sp. z o.o.

§ 2
Glossary

For the purposes of the Regulations of the website of Ciril Poland Sp. z o.o.:

1. Personal Data – shall mean personal data constituting a set of information about a natural person that allows him/her to be identified;
2. Contact Form – shall mean the form in which Website Users provide the necessary data in order to receive information about the object of activity and services provided by the Operator;
3. Operator – shall mean Ciril Poland Spółka z ograniczoną odpowiedzialnością [Limited Liability Company] with its registered office in Tarnowo Podgórne, at Sowia 6/1 62-080, entered into the Register of Entrepreneurs of the National Court Register maintained by the District Court for the city of Poznań, 8th Commercial Division of the National Court Register under KRS 0000881818, with REGON 388137103, with NIP 7812017566;
4. Regulations –  shall mean the Regulations of the website of Ciril Poland Sp. z o.o., which shall set forth the rights and obligations of the Operator as well as the rights and obligations of Website Users;
5. Website - shall mean the website operating at the following internet address www.orkana-apartments.pl
6. User – shall mean any natural person visiting the Website and using its resources via the Internet.

§ 3
Privacy Policy

1. The Website Privacy Policy shall be a document concerning the protection and processing of Users' Personal Data. The Policy shall define the rules for ensuring the privacy of Users based on the following laws:
   1. the Regulation of the European Parliament and of the Council 2016/679 of 27 April 2016 on the protection of individuals 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, GDPR);
   2. the Act of 10 May 2018 on the protection of personal data (Journal of Laws item 1000);
   3. the Act of 18 July 2002 on the provision of electronic services (consolidated text, Journal of Laws of 2019, item 123);
   4. the Act of 16 July 2004 Telecommunications Law (consolidated text, Journal of Laws of 2018, item 1954, as amended).
2. The Website shall be used via a secure connection. Information sent and received by the Website shall be private.

§ 4
Browsing the Website's resources by Users

The storage of server inquiries shall not require Personal Data to be processed since the data shall not be associated with specific Users browsing the Website. The resources browsed by the User shall be identified by URL addresses and shall relate to:

1. the public IP address of the end device from which the inquiry has come;
2. the name of the User's station - identification performed by the http protocol, if possible;
3. the name of the User provided in the authorization process;
4. the time of arrival of the inquiry;
5. the first line of the http request;
6. the http response code;
7. the number of items of data sent by the server;
8. the URL of the page previously visited by the User (the so-called referer link) - if the Website has been accessed via an external link;
9. information about the User's browser;
10. information about errors that have occurred during the execution of the http transaction.

§ 5
Cookies policy

1. The Website shall use the "cookies" technique. A cookie shall be a small file with information saved by the Website on the User's end device in connection with the User's use of the Website.
2. The use of "cookies" techniques shall not allow any Personal Data and address date of the User or any confidential information from their computer to be collected. The "cookies" technique shall allow only the profile of the information the User is interested in to be defined. In this way, the collected data shall make it possible to study the aggregate traffic of Users on the Website and to be studied for statistical purposes, e.g. with the use of Google Analytics tools.
3. The purpose of using the "cookies" technique shall be to ensure the proper functioning of the Website, collecting anonymous statistics to help determine how the content posted on the Website is used and to present Users with information and advertisements tailored to their preferences.
4. The User can decide for themselves how cookies shall be stored on their computer. To this end, settings / preferences in the web browser should be changed. The default settings of popular browsers usually allow cookies to be saved. By using the Website, the User shall agree to the use of cookies in accordance with the browser settings. It shall also be possible to use the Website without using and saving cookies, however, not all the website functions may be available then.
5. We shall use the following types of cookies on the Website:
   1. “session cookies" - they shall be stored on the User's end device until they the Website is left, or the web browser has been turned off;
   2. “permanent cookies" - they shall be stored on the User's end device for the time specified in the parameters of cookies or until they are deleted by the User;
   3. “performance cookies" - they shall enable the collection of information on the manner of use of the Website;
   4. “necessary cookies" - they shall enable the use of services available on the Website;
   5.  “own cookies" - posted by the Website.

§ 6
Cookies policy

1. The controller of the personal data of Website Users shall be Ciril Poland Spółka z ograniczoną odpowiedzialnością with its egistered office in Tarnowo Podgórne, at Sowia 6/1 62-080, entered into the Register of Entrepreneurs of the National Court Register maintained by the District Court for the city of Poznań, 8th Commercial Division of the National Court Register under KRS 0000881818, with REGON 388137103, with NIP 7812017566; (hereinafter "Company").
2. The User's personal data shall be processed for the purpose of:
   1. sale and rent of real estate pursuant to Article 6 (1) (b) of the GDPR;
   2. implementation of the legitimate interests of the Company as the controller - pursuant to Article 6 (1) (f) of the GDPR, which should be understood as replying to a message sent using the contact form on the www.orkana-apartments.pl website.io
   3. sending commercial information regarding the Company's offer with consent - pursuant to Article 6 (1) (a) of the GDPR.
3. The personal data of Website Users shall be processed:
   1. for the period necessary for the performance of the contract and for the time necessary for the prescription of any claims related to the performance of the contract;
   2. - in the case of sending a message via the contact form - for the period necessary to reply to the message sent via the contact form;
   3. - in the case of consent to the transmission of commercial information - until the consent to processing is withdrawn.
4. In connection with the processing of their Personal Data provided in the Contact Form, the Website User shall have the right to access the data, the right to rectify the data, the right to delete the data, the right to limit data processing, the right to object to data processing and the right to request the data to be transferred.
5. To the extent that the processing of Personal Data is consent-based, the User shall have the right to withdraw their consent to processing.
6. The Website User shall have the right to lodge a complaint with the supervisory authority – Prezes Urzędu Ochrony Danych Osobowych.
7. Personal Data may be entrusted CIRIL N.V. and Sp. z o.o., CG Development Sp. z o.o., Democo Poland Sp. z o.o. and entities providing marketing, real estate services, legal services and IT services to the above-mentioned companies and the Controller.
8. The personal data of Website Users may be made available in accordance with applicable law at the request of law enforcement authorities, other public administration bodies, the Police and other services. Making personal data available to these services shall not require the consent of the Website User.
9. In accordance with the provisions of Clause 5, Personal Data may be profiled.

§ 7
Final Provisions

1. The Operator shall reserve the right to amend the Website Privacy Policy in order to ensure that it is up-to-date and complies with applicable law. Any amendments to the Website Privacy Policy may also result from changes in technology, methods, purposes or legal grounds for the processing of the Users' personal data.
2. Any inquiries regarding this Website Privacy Policy, including the processing of the Users' Personal Data and the privacy policy, should be sent to the following e-mail address: data.ciril@ciril.com
3. The last amendments to the Website Privacy Policy were introduced on 6 October 2021.