PRIVACY POLICY

Date of the last update: October 8th 2020

1. GENERAL PROVISIONS
We care about your privacy as a user of this website and we want you to feel comfortable while using our services. Therefore, below you will find the most important information about how Exclusive Worldwide Sp. z o.o. (hereinafter referred to as “we”, “us”) collect, store and process your personal data when you browse our website. This information was prepared in accordance with the Regulation of the European Parliament and of the Council (EU) 2016/679 of April 27, 2016 on the protection of natural persons 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) (hereinafter referred to as “GDPR”).

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

2. PERSONAL DATA CONTROLLER
The data controller of your personal data in connection with the use of the website www.exclusiveworldwide.eu is Exclusive Worldwide Sp. z o.o. with its registered office in Wrocław at ul. Krawiecka 6/4, 50-148 Wrocław, registered in the District Court for Wrocław Fabryczna, 6th Commercial Division of the National Court Register, under the number KRS 0000447618, Tax Identification Number (NIP): 896-153-28-19, REGON: 022055248.

In all matters related to the processing of your personal data, you can contact us by e-mail at the following address: mydata@exclusiveworld.com.

3. SCOPE, PURPOSE, LEGAL BASIS FOR PROCESSING AND RETENTION PERIOD FOR PERSONAL DATA

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

If you are our client or a potential client and you send us an inquiry via the contact form, you provide us with your data such as: name, surname, company name, e-mail address, telephone number and other information regarding your accommodation needs and additional services referring to it. We process the personal data obtained in this way in order to respond to your inquiry and process your request.

Our legal basis for processing data for this purpose is a legitimate interest in operating our business.

If you decide to use the services of Exclusive Worldwide Sp. z o.o., your personal data will either be necessary for us to perform a contract between you and Exclusive Worldwide Sp. z o.o., or to process your request and provide you with the service you have asked for. Our legal basis for processing data will be performance of a contract or taking steps at your request prior to entering into a contract, as well as our legal obligation as the data controller, primarily related to accounting and our legitimate interest in operating our business, which include establishment, exercise or defence of legal claims.

Your personal data will be processed by us, as the controller, as long as the correspondence with you continues. If you and Exclusive Worldwide Sp. z o.o. enter into a contract, we, as the controller, will add your personal data to the client base of Exclusive Worldwide Sp. z o.o. It will be processed as long as our contract is in force, and after the contract expires, as long as we, as the data controller, are legally obliged to and/or until the expiry of the limitation period for any claims. If the contract with us is not concluded, your data will be erased.

If you are the owner of an apartment and you want to add your property to our database, you have to provide us with data such as: name, surname, company name, e-mail address, telephone number. We process your data in order to verify the property you wish to add and to work on our potential cooperation.

Our legal basis for data processing is the performance of a contract or taking steps at your request prior to entering into a contract, as well as our legal obligation as the data controller, primarily related to accounting and our legitimate interest in operating our business, which include establishment, exercise or defence of legal claims.

It will be processed as long as our contract is in force, and after the contract expires, as long as we, as the data controller, are legally obliged to and/or until the expiry of the limitation period for any claims. If the contract with us is not concluded, your data will be erased.

If you are our client, potential client or owner of an apartment and additionally you consent to receiving our marketing information and commercial communications , we can also process your personal data such as e-mail address and/or telephone number in order to send you marketing information and commercial communications, i.e. current information about the Exclusive Worldwide offer and activities, as well as other information regarding Exclusive Worldwide’s business operations. We will provide you with our marketing information and commercial communications by sending e-mails and / or sms / mms messages and / or telephone calls.

You decide whether you want to receive such information from us and in what form it will be delivered to you. You may withdraw your consent to the processing of your data for marketing purposes at any time by sending us your request at mydata@exclusiveworld.com.

Our legal basis for data processing for this purpose is your consent and our legitimate interest in marketing our business operation.

We will process your personal data until the consent is withdrawn or the purpose of processing ceases. Withdrawal of consent does not affect activities performed prior to the withdrawal.

If you are a job candidate and you send us your application through the form on our website, you provide us with the following data: name, surname, contact details (e-mail address and/or telephone number) and that information contained in the attached CV. We process your data provided in this way in order to carry out the recruitment process. We may process your personal data contained in the job application also for the purpose of establishment, exercise or defence of legal claims, if the claims relate to our recruitment process.

Our legal basis for your data processing is performance of a contract or taking steps at your request prior to entering into a contract, and Art. 22(1) of the Polish Labour Code, as well as our legal obligation as the data controller and our legitimate interest in or the establishment, exercise or defence of legal claims in the court proceedings or government authority proceedings. If you voluntarily provide additional personal data beyond that referred to in the Polish Labour Code, you are required to give your explicit consent for its processing.

We may also process your personal data for the purpose of future recruitment, if you send us your consent necessary for this purpose (the required wording is included below the candidate form). If you want to send us the necessary consent you can add it to your CV. Our legal basis for data processing will be your consent.Remember that you can withdraw your consent at any time by contacting us at mydata@exclusiveworld.com.

We will process your personal data until the recruitment process is completed, but for no longer than 12 months from providing us with your application. And, if you are employed, then we will process your data for 10 years after you finish working with us. This obligation results from the provisions of law in this regard. However, if you consent to the processing of your data in future recruitment processes, we have the right to process your data also in future recruitment, but for no longer than 12 months from the date of data transfer.

We also process your personal data that we collect automatically.

If you are browsing our website, we process information on your activity on the website, that is: session data, your device and operating system, browser type, location and your unique IP address. This data is collected in the form of cookies (you will find information about cookies in the further content of the Policy) and is processed in order to facilitate navigation on our website and to improve the functionality of the website. None of this information is used to identify an individual user, as we use it to monitor and improve IT services on our website.

Our legal basis for your data processing for this purpose is consent and our legitimate in improving our business operation.

4. DATA PROFILING
Your personal data will be processed in the form of profiling, however, it produces neither legal effects concerning you nor similarly significantly affects you.

Profiling of personal data by Exclusive Worldwide Sp. z o.o., consists of processing of your personal data to evaluate certain information about you, in particular, to analyse or forecast your personal preferences and interests.

5. RECIPIENTS OF DATA
Like most organisations, we cooperate with other entities, which often involves the necessity to provide your personal data. This means that we transfer your personal data to our business partners, suppliers whose services we use to process your order, e.g. accommodation facilities, airlines, authorities, etc.

In addition, we transfer your personal data solely to processors, that is entities processing it on our behalf, including IT service providers and law firms. These entities process your personal data only at our request and to the minimum extent as requested by us.

In addition, it may happen that, for example, on the basis of the applicable law, we will have to transfer your personal data to authorized bodies (e.g. judicial authorities or tax office).

The data that we collect from you may be transferred to our business partners and suppliers operating outside the European Economic Area (“EEA”) who may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of services.

Our legal basis for sharing your data is our legitimate interest in cost effectively operating our business.

6. YOUR RIGHTS RELATING TO PROCESSING YOUR PERSONAL DATA
In accordance with the provisions of the General Data Protection Regulation, you have the right to:

– access your personal data, and also to get a copy thereof. You have the right to obtain confirmation from us as to whether we process your personal data, and if this is the case, you have the right to:

• get access to your personal data,
• obtain information about the purposes of processing, categories of personal data being processed, recipients or categories of recipients of this data, about the period for which the personal data will be stored, or if that is not possible, about the criteria used to determine that period, about your rights under the GDPR and the right to lodge a complaint with the supervisory authority, about the source of this data, about automated decision making, including profiling, and about the security measures used regarding transfer of this data outside the European Union,
• obtain a copy of your personal data.

– rectification (correction) of data. You have the right to rectify and supplement the personal data provided by you. You have the right to request us to correct this data if incorrect and supplement it if incomplete.

– erasure of data (the right to be forgotten). If, in your opinion, there are no grounds for us to process your data, you can request us to delete it. You have the right to request the erasure of personal data if:

• you have withdrawn your specific consent on which the processing is based and there are no other legal grounds for the processing;
• your personal data is no longer necessary for the purposes for which it was collected or processed;
• you objected to the use of your data for the purpose of collecting anonymised and aggregated statistics of the usage of our website, and the objection was considered justified;
• your personal data is processed unlawfully.

Despite your request to delete your personal data in connection with the objection or withdrawal of consent, we may retain certain personal data to the extent necessary for the purpose of the establishment, exercise or defence of legal claims. This applies in particular to personal data including: name, surname, e-mail address and application history, which we keep for the purpose of handling complaints and claims related to the use of our services.

– restrictions on data processing. If, in your opinion, we have incorrect data about you, or we process it unreasonably, or you do not want us to delete it because you need it for establishing, investigating or defending claims, you can request that we only store your data or process it only with your consent or for the establishment, exercise or defence of legal claims. You have the right to request the restriction of the use of your personal data in the following cases:

• when you contest the accuracy of your personal data for a period enabling us to verify the accuracy of your data;
• when the processing of your data is unlawful, and instead of erasure of your data, you request the restriction of its use;
• when your personal data is no longer necessary for the purposes for which we collected or use it, but you need it for the establishment, exercise or defence of legal claims;
• when you object to the processing of your data – then the restriction takes place for the time needed to consider whether, due to your particular situation, the protection of your interests, rights and freedoms overrides our legitimate grounds to process your personal data.

– object to processing. If your objection turns out to be justified and we have no other legal basis to process your personal data, we will erase your data to the extent that it is related to your objection;

– data portability. You have the right to receive from us your personal data, provided to us with your consent, in a structured, commonly used and machine-readable format, e.g. CSV. You can also order us to transmit that data to another entity;

– lodge a complaint with the supervisory authority. All your complaints, inquires and requests in relation to processing of your personal data and exercising your rights can be submitted to us. If you believe that we are processing your data unlawfully, you can submit a complaint to the President of the Office for Personal Data Protection, with it’s registered office in Warsaw, ul. Stawki 2, Poland.

You can exercise your rights by submitting a request to the e-mail address indicated above in the Policy.

If you send us your request, we will make every effort to handle it as quickly as possible. However, the request is not always feasible. For example, the right to erase data cannot be exercised, if we are legally obliged to store your data. We will inform you in writing or by e-mail about how we are dealing with your request.

7. PROTECTION OF PERSONAL DATA

We, as the data controller, ensure the appropriate level of security of your personal data thanks to appropriate technical and organisational measures aimed at preventing unlawful data processing and its accidental loss, destruction or damage. Regardless of the above, we make every effort to ensure that your personal data is always:

• accurate and processed in accordance with the law,
• collected only for specific purposes and not further processed in a manner inconsistent with these purposes,
• stored no longer than necessary,
• processed in accordance with the rights of the persons they relate to, including the right to object to share the data,
• not transferred without adequate protection.

For this purpose, we use the latest technologies and appropriate personal data protection procedures, as well as modern data protection mechanisms. Your personal data is stored in a database protected with technical and organisational measures to comply with the requirements set out in generally applicable laws relating to personal data protection. Only persons authorised by us, as the data controller, have access to the database.

8. COOKIES
Cookies are small text files stored on your device as you are browsing (e.g. computer, tablet, smartphone) that can be read by our IT system. Cookies usually contain the name of the website they come from, their storage time on the end user device and a unique number.

The first time you visit our website, you will see a banner on the page containing information about the use of cookies. By accepting this information and closing the banner you consent to the use of cookies in accordance with the provisions of this Privacy Policy. You can always withdraw your consent by deleting cookies and changing cookie settings in your browser. Information on how to use the above option can be found on the website of the browser you use (Opera, Firefox, Internet Explorer, Chrome, Safari). However, please remember that disabling cookies may cause difficulties in using our website.

You can control the use of cookies in your browser (one of many websites explaining how to do it is https://www.pcmag.com/how-to/how-to-control-and-delete-cookies-on-your-browser).

Cookies we use:
Session cookies – these are temporary cookie files, which are stored until you leave the site and close your browser. They are necessary for the operation of some applications and functionalities of our website.
– wordpress_test_cookie – checks if your browser accepts cookies
Persistent cookies – thanks to these cookies, browsing websites you regularly visit is easier (for example they ensure optimal navigation, remember screen resolution you chose, the content arrangement, etc.). These cookies remain in your browser for a set period of time after the browser session. This period depends on your choice in the browser settings.
– eww-cookie – stores information whether the cookie banner was closed, duration – 365 days
– wp-wpml_current_language – stores information about the language you have chosen, duration – 1 day
Third-party cookies -information placed by the servers of service suppliers on the website who cooperate with the owner of the website or advertisers. We use functions of the web analysis service Google Analytics which collect information about your visits to our website, such as the subpages you browse, the time you spent on the website or the transitions between individual subpages. For this purpose, Google LLC cookies are used for the Google Analytics service. As part of Google Analytics, we collect demographic data and data on interests. You can give your consent or not to the collection of such data about you by choosing appropriate cookie settings. Detailed information about the service is available at the following links: https://policies.google.com/technologies/types?hl=en.

9. CHANGES TO THE PRIVACY POLICY
In order to ensure that our Privacy Policy complies with the current statutory requirements at all times, we reserve the right to amend it at any time. We recommend that you check this page frequently and refer to the date of the last update as shown above.

10. COPYRIGHT
Copyright © Exclusive Worldwide Sp. z o.o. All rights reserved.