Privacy Policy

Last updated: June 18, 2025

General provisions

We value your privacy and want you to feel comfortable when using our services. Below, you’ll find key information about how Exclusive Worldwide Sp. z o.o. (“we”, “us”) processes your personal data when you use our website. This information has been prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), as well as other applicable laws, including the California Consumer Privacy Act (CCPA/CPRA), the UK GDPR, the revised Federal Act on Data Protection (revFADP), the Lei Geral de Proteção de Dados (LGPD), and the Personal Information Protection and Electronic Documents Act (PIPEDA).

This Privacy Policy applies to users of the website www.exclusiveworldwide.eu, including potential clients, clients, business partners, subcontractors, and job applicants who provide personal data through forms available on the website

Data controller

The data controller for your personal data collected through the website www.exclusiveworldwide.eu is Exclusive Worldwide Sp. z o.o., headquartered in Wrocław, Poland (ul. Krawiecka 6/4, 50-148 Wrocław), registered with the District Court for Wrocław-Fabryczna, 6th Commercial Division of the National Court Register, under KRS number 0000447618, NIP: 896-153-28-19, REGON: 022055248.

For any questions regarding the processing of your personal data, please contact us at: mydata@exclusiveworld.com.

Scope, purpose, legal basis, and retention period of personal data processing

We process the personal data we receive from you in connection with our business activities.

If you are our client or potential client and you send us an inquiry via the contact form, you provide us with your data including: first name, last name, company name, email address, phone number, and any other information related to your accommodation and additional service needs. We process this personal data in order to respond to your inquiry.

The legal basis for this processing is our legitimate interest as the data controller.

If you decide to use the services of Exclusive Worldwide Sp. z o.o., your personal data will be necessary to perform the contract between you and Exclusive Worldwide Sp. z o.o. or to process your request and deliver the services you asked for. The legal basis for this processing will be:

performance of a contract or taking steps at your request prior to entering into a contract (Art. 6(1)(b) GDPR),
our legal obligations as a data controller, particularly related to accounting (Art. 6(1)(c) GDPR), and
our legitimate interest related to business activities, specifically the establishment, exercise, or defense of legal claims (Art. 6(1)(f) GDPR).

We will process your personal data for the duration of the correspondence and, depending on the outcome:

your data may be added to the Exclusive Worldwide Sp. z o.o. client database and processed further for contract performance for the duration of the contract,
after the contract ends, to fulfill legal obligations applicable to the data controller for the period required by applicable laws,
and/or until the expiration of the limitation period for any potential claims,
or your data will be deleted if you do not proceed with using the services of Exclusive Worldwide Sp. z o.o.

If you are a property owner and wish to list your property in our database, you will provide data including: first name, last name, company name, email address, and phone number. We process this data to verify your property and potentially establish cooperation.

The legal basis for this processing is:

performance of a contract or taking steps at your request prior to entering into a contract (Art. 6(1)(b) GDPR),
our legal obligations as a data controller, particularly related to accounting (Art. 6(1)(c) GDPR), and
our legitimate interest related to business activities, specifically the establishment, exercise, or defense of legal claims (Art. 6(1)(f) GDPR).

The retention period for personal data will vary depending on the nature of your relationship with us. We will process your data:

for the duration of the contract,
after the contract ends, to fulfill legal obligations applicable to the data controller for the period required by applicable laws,
and/or until the expiration of the limitation period for any potential claims,
or your data will be deleted if there is no opportunity for cooperation.

If you are our client, potential client, or property owner and you additionally consent to receiving commercial or marketing information, we may also process your email address and/or phone number to send you information about our offers, activities, and services related to Exclusive Worldwide. These communications may be delivered via email, SMS/MMS, or phone call.

You choose whether you wish to receive such information and in which form. You may withdraw your consent at any time by contacting us at: mydata@exclusiveworld.com.

The legal basis for this processing is your consent (Art. 6(1)(a) GDPR) and our legitimate interest in promoting our business (Art. 6(1)(f) GDPR).

We will process your data for this purpose until you withdraw your consent or the processing purpose ceases. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.

If you are a job applicant and submit your application via the form on our website, you provide us with data including: first name, last name, contact details (email and/or phone number), and the information contained in your CV.

We process this data for recruitment purposes. We may also process this data to establish, exercise, or defend legal claims related to the recruitment process.

The legal basis for this processing is the performance of a contract or taking steps at your request prior to entering into a contract, and our legitimate interest in establishing, exercising, or defending claims in court or before public authorities (Art. 6(1)(a), (b), (f) GDPR, and Art. 221 of the Polish Labour Code). Providing additional data beyond what is required under the Labour Code is voluntary and requires your explicit consent.

We may also process your personal data for future recruitment purposes if you give your consent. The text of this consent is included under the candidate form. If you wish, you may attach this consent to your CV.

You may withdraw this consent at any time by contacting us at: mydata@exclusiveworld.com.

We will process your data until the recruitment process is completed, but no longer than 6 months from receipt of your application. If hired, we will process your data for up to 10 years after employment ends unless applicable laws require a longer retention period. If you consent to future recruitment, we may process your data for up to 12 months from submission.

Where necessary, we will conduct a data protection impact assessment (DPIA), especially in cases where automated tools, profiling, or IT systems are used to assist candidate selection.

We also process your personal data collected automatically.

If you are a website user, we process data regarding your activity on the site, such as: session data, device information, operating system, browser, location, and IP address. This data is collected through cookies (see the relevant section below) and is used to improve navigation and site functionality. None of this data is used to identify individual users – it is used to monitor and improve our IT services.

The legal basis for this processing is your consent and our legitimate interest in improving our business operations.

Profiling

Your personal data may be processed in the form of profiling; however, this will not result in any legal effects for you nor will it similarly significantly affect your situation. The legal basis for this is our legitimate interest (Article 6(1)(f) of the GDPR).

Profiling of personal data by Exclusive Worldwide Sp. z o.o. consists of processing your data by using it to assess certain information about you, in particular to analyze or predict your personal preferences and interests.

Data recipients

Like most organizations, we rely on the assistance and services of third parties in the course of our business, which often involves the need to share personal data. This means that we may share your personal data with our partners and service providers in order to fulfill your request, for example, accommodation providers, airlines, government offices, and similar entities.

Additionally, we only share your personal data with data processors, such as IT service providers or law firms, who process your data strictly on our behalf and only to the minimum extent necessary.

It may also happen that, based on applicable legal provisions, we may be required to provide your personal data to authorized authorities (e.g., law enforcement or judicial authorities).

The data we collect from you may also be shared with entities operating outside the European Economic Area (“EEA”), specifically, our partners or suppliers. Such entities may, for example, be involved in fulfilling your request (processing your reservation details, payments, or other services we provide).

The legal basis for sharing your data is our legitimate interest in running our business effectively (Article 6(1)(f) GDPR) and your consent (Article 6(1)(a) GDPR).

Whenever data is transferred outside the EEA, we ensure that appropriate safeguards are in place in accordance with Articles 44–49 of the GDPR. Specifically, we use:

Standard Contractual Clauses (SCCs) adopted by the European Commission to secure the transfer of data;
Transfer Impact Assessments (TIA), to assess whether the laws of the recipient country undermine the protections provided by the SCCs;
Additional technical and organizational measures where required (such as encryption or access restrictions);
User consent, when no other legal basis for transfer is available.

In cases where the European Commission has not issued an adequacy decision for a given third country, we inform you that such countries may not guarantee an adequate level of personal data protection as defined by the GDPR, and there is a risk that public authorities in such countries (e.g., the United States) may access your data.

You may request a copy of the safeguards in place for any such data transfers, or information on where they are available, by contacting us at: mydata@exclusiveworld.com.

Your rights regarding the processing of personal data

In accordance with the General Data Protection Regulation (GDPR), you have the following rights:

Right of access to your data and to obtain a copy. You have the right to obtain confirmation from us as to whether or not we process your personal data, and, if so, to access your personal data.

You also have the right to:

receive information regarding your personal data
receive information regarding the purposes of processing, the categories of personal data concerned, the recipients or categories of recipients to whom your data has been disclosed, the planned storage period or criteria used to determine this period, your rights under GDPR, the right to lodge a complaint with the supervisory authority, the source of the data, the existence of automated decision-making, including profiling, and safeguards applied in connection with transfers of data outside the European Union.
Additionally, you may obtain a copy of your personal data.

Right to rectification (correction) of data. You have the right to request that we correct or complete any inaccurate or incomplete personal data concerning you.

Right to erasure (“right to be forgotten”). If you believe there is no legal basis for us to process your data, you may request that we delete it. You may exercise this right if:

you have withdrawn your consent (to the extent the processing was based on your consent),
the data is no longer necessary for the purposes for which it was collected or otherwise processed,
you have objected to the processing for statistical purposes and your objection has been deemed justified,
your personal data is being processed unlawfully.

Please note that even if you request the erasure of your personal data, we may retain certain data as necessary to establish, exercise, or defend legal claims. This applies especially to: your name, email address, and application history, retained for handling potential complaints or claims related to the use of our services.

Right to restriction of processing. You have the right to request that we restrict the processing of your personal data to storage only, or to actions agreed with you, if you believe that we hold inaccurate data about you, or are processing your data without a valid legal basis, or if you do not want us to erase the data because you need it to establish, exercise, or defend legal claims, or for the period during which you have objected to the processing of your data. You may request restriction of the use of your personal data in the following cases:

you contest the accuracy of your personal data (restriction will apply for the time necessary to verify this),
the processing is unlawful and you oppose erasure and request restriction instead,
the data is no longer needed for the purposes of processing, but is required for you to establish, exercise, or defend legal claims,
when you have objected to the processing of your data — the restriction will apply for the period necessary to assess whether, due to your particular situation, the protection of your interests, rights, and freedoms outweighs the legitimate interests we pursue by processing your personal data

Right to object to processing. If you object to the processing of your personal data and your objection is justified, and we do not have any overriding legal grounds to continue processing, we will stop processing your data for those purposes.

Right to data portability. You have the right to receive your personal data, which you provided to us with your consent, in a structured, commonly used, machine-readable format (such as CSV), and you may request that we transfer this data to another entity.

Right to lodge a complaint with a supervisory authority. You may submit any complaints, inquiries, or requests regarding the processing of your personal data to us. If you believe we are processing your data unlawfully, you may file a complaint with the President of the Personal Data Protection Office (UODO), based in Warsaw, ul. Stawki 2.

You may exercise your rights by submitting a request to the following email address: mydata@exclusiveworld.com

We will make every effort to process your request as quickly as possible. However, please be aware that there may be situations where we cannot fulfill your request – for example, we may be legally required to retain certain data. We will inform you in writing or by email of the outcome of your request.

Security of personal data

The data controller ensures the security of personal data through appropriate technical and organizational measures designed to prevent unlawful processing of data, as well as accidental loss, destruction, or damage. In addition to these safeguards, we make every effort to ensure that personal data is always:

accurate and processed in a lawful manner,
collected for specified purposes and not processed further in a way that is incompatible with those purposes,
stored no longer than necessary,
processed in accordance with the rights of the individuals to whom it relates, including the right to restrict disclosure,
not transferred without appropriate protection.

To this end, we use the latest technologies and appropriate personal data protection procedures, as well as modern mechanisms for securing data transmissions. Your personal data is stored in a database that incorporates technical and organizational measures ensuring the protection of the processed data in accordance with applicable data protection laws. Access to the database is granted only to persons who have been authorized by the data controller.

Cookies are small text files stored on your end device (such as a computer, tablet, or smartphone), which can be read by our IT system. Cookies typically contain the name of the website they originate from, the duration of storage on your device, and a unique number.

When you visit our website for the first time, you will see a notification regarding our use of cookies. By accepting and closing this notification, you consent to the use of cookies in accordance with this Privacy Policy. You can withdraw your consent at any time by deleting cookies or changing your cookie settings in your browser. Information on how to do this can be found from your browser provider (e.g., Opera, Firefox, Internet Explorer, Chrome, Safari). However, please note that disabling cookies may affect your ability to use the website and other websites that rely on cookies.

You can control the use of cookies in your browser (visit www.allaboutcookies.org to learn more).

During your first visit, a cookie banner will appear, allowing you to accept or decline cookies in an equal manner (e.g., through “Accept” and “Decline” buttons). You may also access advanced settings to choose which categories of cookies you consent to (granular consent). Non-essential cookies (such as analytical or marketing cookies) are only used after receiving your active consent.

Types of cookies used:

Session cookies – these are temporary files stored in your browser’s memory until you end your browser session (i.e., close the browser). These cookies are necessary for some applications or functionalities to work correctly.

wordpress_test_cookie – used to check if cookies are enabled.

Persistent cookies – these cookies make it easier to use frequently visited websites (for example, they provide optimal navigation, remember your chosen resolution, content layout, etc.). This information remains in your browser’s memory for a longer period, depending on your browser settings.

eww-cookie – records whether the cookie banner has been closed; retention period: 365 days.
wp-wpml_current_language – stores the user’s selected language to remember the preferred site language; retention period: 1 day.

Third-party cookies – these are cookies from, for example, the servers of companies providing services on our site, business partners, or advertising servers. We use Google Analytics, a web analytics tool that collects information about your visit to our site, such as which subpages you viewed, how much time you spent on the site, and your navigation between subpages. This uses cookies provided by Google LLC through the Google Analytics service. We also collect demographic and interest data via Google Analytics. In your cookie settings, you can decide whether to allow such data collection or not. Detailed information about this service is available at:

https://privacy.google.com/businesses/compliance/.

Non-eea jurisdictions

United States – California

(California Consumer Privacy Act – CCPA/CPRA)

9.1

If you are a resident of California, you have specific rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). These rights include:

The right to know what categories and specific pieces of personal data we collect;
The right to request the deletion of your personal data;
The right to opt out of the sale of your personal data (Exclusive Worldwide Sp. z o.o. does not sell personal data as defined by the CCPA);
The right to request correction of inaccurate personal information;
The right not to be discriminated against for exercising your privacy rights.

To exercise these rights, you can contact us at mydata@exclusiveworld.com with the subject line: “California Privacy Rights Request”.

United Kingdom

(UK GDPR)

9.2

If you are located in the United Kingdom, your personal data is processed in accordance with the UK General Data Protection Regulation (UK GDPR). You are entitled to the same rights as under the EU GDPR (e.g., access, rectification, erasure, restriction, etc.). For any data transfers outside the UK, we apply appropriate safeguards, including Standard Contractual Clauses. For any questions or requests concerning your personal data in the UK, please contact us at mydata@exclusiveworld.com.

Switzerland

(revFADP)

9.3

If you are located in Switzerland, your personal data is processed in accordance with the revised Federal Act on Data Protection (revFADP). We ensure that data is processed lawfully, fairly, and transparently, for specific purposes, and not transferred to third countries without adequate safeguards.

Brazil

(Lei Geral de Proteção de Dados – LGPD)

9.4

If you are a user from Brazil, your personal data is subject to the rights granted under the Lei Geral de Proteção de Dados (LGPD), including:

The right to confirm the existence of data processing;
The right to access your data;
The right to correct incomplete, inaccurate, or outdated data;
The right to anonymize, block, or delete unnecessary or excessive data;
The right to data portability.

Requests may be directed to mydata@exclusiveworld.com.

Canada

(PIPEDA)

9.5

If you are a resident of Canada, the processing of your personal data is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA). We ensure that your data is collected and used for reasonable purposes and that your consent can be withdrawn at any time.

Changes to the privacy policy

To ensure that our Privacy Policy always complies with current legal requirements, we reserve the right to amend it at any time. We recommend checking this page frequently and referring to the date of the last modification above.

All rights reserved © Exclusive Worldwide Sp. z o.o. — copying, reproduction, retransmission, or redistribution of any materials published on the exclusiveworld.com website, in whole or in part, in any medium, without the official consent of the owner, is prohibited.