GDPR Kluazula Newsletter

1. administrator and contact information

The administrator of the personal data is “MAGNICITY WARSAW” Spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw, 59 Złota Street (Skylight Office Building / 14th floor), 00-120 Warsaw, registered in the register of entrepreneurs, kept by the District Court for the Capital City of Warsaw in Warsaw, XII Economic Department of the National Court Register, under the KRS number 0001043051, NIP 5252961210, REGON 525637863, with the share capital of PLN 5,000.00.

2. contact the administrator

The administrator can be contacted by postal mail at the registered office address indicated above or by email at info@highlinewarsaw.com

3 Sources and scope of data acquired

Personal data was obtained directly from you in connection with newsletter sign-up or as part of business correspondence. In the case of persons representing business entities, the data may be obtained from public sources (public records, website, etc.). The scope of the processed data generally includes: first and last name, e-mail address, in the case of persons representing business entities also: position or function, telephone number, company name and contact details.

4 Purposes and legal basis for processing

The purpose of personal data processing is:

a. sending newsletters and other commercial and marketing information about the Administrator’s products and services by e-mail – including information tailored to the industry or business profile in the case of persons representing business entities.

The data is processed:

• on the basis of consent, i.e. Article 6(1)(a) of the RODO, in conjunction with Article 398(1) and (2) of the Law of July 7, 2023. – Electronic Communications Law (in the case of newsletter sign-up), or
• on the basis of the Administrator’s legitimate interest (Article 6(1)(f) RODO) in sending information about products and services to contacts representing business entities, within the framework of existing business relationships – until you object (Article 21 RODO).

b. archiving of documentation and communications, including correspondence produced by the Administrator in the course of its business activities, due to its legitimate interest, which is the necessity to document evidence of its activities, among other things, in accordance with applicable regulations, and to use the archived material for the purpose of investigating, establishing or defending against claims (based on Article 6(1)(f) of the DPA).

5 Data recipients

The Administrator has the right to transfer your personal data to other recipients if necessary to achieve the purpose of processing, i.e..: entities that provide IT support services to the Administrator, including IT system support and maintenance, data hosting and cloud services, our authorized employees and associates, postal operators and couriers, law firms, auditors, banks, insurers, entities responsible for archiving or destroying data, group companies for internal administrative purposes (based on Article 6(1)(f) of the RODO)

6 Processing outside the EEA

Your personal data may be transferred to a third country (i.e., a country outside the European Economic Area). Such transfer of your personal data may take place on the basis of standard safeguard clauses (based on Article 46(2)(c) and (d) of the RODO) or on the basis of another mechanism that is lawful and legalizes such transfer and will provide adequate guarantees for the protection of personal data in accordance with the applicable legal provisions in this regard. The transfer to the United States is based on the decision of the European Commission dated 10/07/2023, finding an adequate level of personal data protection provided under the EU-US data protection framework (Article 45 RODO).

7. data retention period

Data will be processed for the duration of consent (in the case of newsletter sign-ups) or until you object to processing for marketing purposes (in the case of processing on the basis of legitimate interest), and thereafter for the period necessary to assert or defend against possible claims.

8 Rights of data subjects

You have the right to request from the Administrator access to personal data concerning you, rectification, erasure, restriction of processing and data portability.

9 Right to object

You have the right to object to the processing of personal data for the purpose of pursuing the legitimate interests of the Controller, but the right to object will not be exercised if there are valid legitimate grounds for processing that override your interests, rights and freedoms.

Where data is processed for direct marketing purposes, the filing of an objection will result in the immediate cessation of processing for this purpose – without the need for justification.

You can make an objection at any time by sending an e-mail to: info@highlinewarsaw.com or by clicking on the appropriate link at the bottom of each message.

10. right to file a complaint with the authority

You have the right to complain about the actions of the Administrator to the competent supervisory authority, in particular in the country of your habitual residence, your place of work or the place where the alleged violation was committed. In Poland, the supervisory authority is the President of the Office for Personal Data Protection, 1A Moniuszki Street, 00-014 Warsaw.

11. voluntariness of providing data

Your provision of personal data for the purpose of subscribing to the newsletter is voluntary, but failure to provide data will prevent you from receiving the newsletter. In the case of persons representing business entities, providing data may be necessary to establish or continue a business relationship with the Administrator.

12. profiling

In order to customize the content of newsletters and marketing communications, we may analyze general information about your industry or business profile (e.g., based on your email address on your company domain) or previous business relationships. These activities may be profiling within the meaning of the RODO, but they are of a mere nature and do not lead to automated decision-making that produces legal effects against you or similarly significantly affects you.