RODO

This clause is addressed to natural persons who intend to give or have given their consent to Syrena Management Ltd. with its registered seat at 15 Zajęcza Street, 00-351 Warsaw to process their personal data for direct marketing purposes (hereinafter referred to as “you”). Direct marketing may be conducted via e-mail, incoming phone calls or SMS/MMS messages.

In accordance with Articles 13 and 14 of the Regulation (EC) 2016/679 of the European Parliament and of the Council of 27 April 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 (hereinafter “RODO”), we would like to inform you that: the administrator of your personal data is Syrena Management Sp. z o.o. entered in the register of entrepreneurs kept by the District Court in Warsaw, 12th Commercial Department of the National Court Register, under number KRS 0000742734, Tax Identification Number (NIP) 5252758124 and statistical number (REGON) 380903354, with the share capital amounting to PLN 5,000.00, fully paid-up (hereinafter referred to as the “Administrator”); your personal data will be processed a. on the

basis of your consent (Article 6(1)(a) of the RODO), the Administrator will process your personal data for direct marketing purposes only on the basis of your explicit, voluntary and previously given consent. The lawfulness of such processing is based on your consent. Such consent given may be withdrawn at any time. This also applies to the withdrawal of consents that were given before the application of the RODO, i.e. before 25 May 2018. Please note that the withdrawal of consent is only effective for the future and does not affect the lawfulness of the processing that was carried out based on consent before its withdrawal.
b. for purposes arising from the legitimate interests pursued by the Administrator (Article 6(1)(f) of the RODO); The processing may be considered necessary for the pursuit of the legitimate interests of the Administrator or a third party, if it does not unduly affect your interests or fundamental rights and freedoms.

When processing personal data on this basis, we always try to balance our legitimate interests with your privacy. When processing on this legal basis, the Administrator has analysed the risks of violation of your rights or freedoms and the measures adopted to protect your personal data. Examples of such “legitimate interests” are the use of cookies and profiling for marketing purposes.

The Administrator processes the following categories of your personal data:
a. identification and contact data provided by you on the marketing form, i.e. name, surname, e-mail address and telephone number;
b. data concerning your preferences and the offers you are interested in, collected directly from you or from external providers, e.g. real estate portals, social networks;

The purpose of processing your personal data is direct marketing of products and services of Syrena Invest Ltd. and entities related to Syrena Invest Ltd., the current list of which can be found at www.syrenainvest.pl/rodo/lista-spolek-zaleznych/.

The Administrator collects your personal data for marketing activities either directly from you or from third parties, such as:
a. real estate portals (e.g. www.rynekpierwotny.pl, www.gratka.pl, www.otodom.pl,www.tabelaofert.pl,
www.morizon.pl, www.obido.pl);
b. social networks (e.g. Facebook);
c. individuals in connection with a referral program.

In connection with the marketing activity conducted by the Administrator, your personal data may be
provided to and shared with the following entities:
a. financial intermediaries,
b. entities providing and administering IT systems dedicated to marketing activity (e.g. CRM system, Marketing Automation system);
c. providers of cloud services;
d. entities cooperating with the Administrator in the field of sales and commercialisation of premises; in the case of withdrawal of your consent to process your personal data for direct marketing purposes, your data will be regularly deleted as of the moment of withdrawal of consent; we process your personal data for the purposes indicated below for the period specified below:

Name of the purpose of processing

Description of the purpose of processing

Processing period

Legal basis for processing

Direct marketing

Conducting direct marketing by the Administrator

Consent of the data subject (Article 6(1)(a) RODO)

The period for which the Administrator processes personal data for other purposes or until withdrawal of consent

Marketing based on cookies

Conducting direct marketing by the Administrator

Legitimate interests of the Administrator (Article 6(1)(f) of the RODO)

Session cookies these are temporary files that are stored in the terminal equipment of the User till log-off time, leaving the website or disabling software (web browser). Permanent cookies are stored in the terminal equipment of the User for the time specified in the parameters of cookies or until they are deleted by the User.

Name of the purpose of processing

Description of the purpose of processing

Processing period

Legal basis for processing

Marketing profiling

Customer profiling for marketing purposes

Legitimate interests of the Administrator (Article 6(1)(f) of the RODO)

The period for which the Controller processes personal data for other purposes or until you object

You have the following rights:

– the right to demand access to your personal data,
– the right to demand rectification of data,
– the right to demand erasure of data,
– the right to demand restriction of data processing,
– the right to demand data portability,
– the right to object to certain data processing activities,- the right to withdraw consent to data processing at any time without affecting the lawfulness of processing on the basis of consent before its withdrawal.

You can exercise the above rights by sending an appropriate letter to the address of the Administrator’s registered office or by using the contact form on the website www.syrenainvest.pl/kontakt.

You have the right to lodge a complaint to the competent supervisory authority (in Poland this authority is the President of the Office for Personal Data Protection), if you consider that the processing of personal data concerning you violates the provisions of RODO;

Providing your personal data collected by the Administrator for the purposes of direct marketing in electronic or telephonic form is voluntary. The consequence of failing to provide the required personal data is the Administrator’s inability to conduct direct marketing to you.

The Administrator may use your personal data for automated decision-making, including profiling. As a result of such actions, however, the Administrator does not make decisions that are based solely on automated decision-making, including profiling, and that could produce legal effects or similarly affect you. Profiling is the Administrator’s process of automatically processing information about you, including personal data such as your age, gender, interests, place of residence or preferences regarding specific products or services that the Administrator is marketing. This process is used to build your profile and to analyse it.
In connection with your participation in promotional campaigns for investments carried out by the Administrator and entities that have capital ties to the Administrator, your personal data is profiled for marketing purposes. The purpose of these operations is the best possible adjustment of the products or services offered by the Administrator to your needs. Profiling does not affect your legal situation.

For the purposes of profiling, the Administrator uses the data referred to in section 3 above, i.e. both the data provided by you directly and the data concerning, for instance, your activity on the website of a given investment, collected through cookie files and the data obtained from external sources, e.g. Facebook. The Administrator ensures that the collection and use of such data is carried out without excessive interference with your privacy. On the basis of the processed data, the Administrator’s employees learn about your preferences, adjust the offer of their products or services to them and make decisions on undertaking specific marketing actions towards you or personalize marketing messages, which they send with your separate consent. Personalizing marketing messages consists in particular in adjusting their content to a particular recipient, his/her interests and preferences. This also means that persons or groups of persons who are assigned to certain categories, based for example on age or gender data, may receive specific advertising messages adapted to their age or gender. In addition, you may be targeted for remarketing activities, which will typically be based on statistical data that is not personally identifiable. This means that visitors to the Administrator’s website may be shown advertising content concerning the Administrator’s investments while visiting other websites. The Administrator has implemented appropriate measures to protect your rights, freedoms and legitimate interests. You have the right to obtain human intervention from the Administrator, the right to express your opinion and to challenge the decisions taken in this way. During your activity on the www.syrenainvest.pl website, cookie identifiers generated by your devices, applications, tools, etc. are assigned to you.

On the basis of these identifiers Administrator, in conjunction with other information obtained through web servers, can collect data on your activity, create profiles and identify your identity. Detailed rules on the collection and use of cookies are laid down in the “Cookies Policy” document, which you can read at www.syrenainvest.pl /policy-cookies/.

This clause has been updated on 27.02.2021 and may be subject to further changes. If required by law, any information regarding future changes or additions to the processing of personal data described in this clause that may concern you will be communicated to you through the appropriate forms of communication usually used by the Administrator in its dealings with you.

Subsidiaries
www. syrenainvest.pl /rodo/lista-spolek-zaleznych/.

Syrena Consulting Ltd., seated at 00-351 Warsaw, 15 Zajęcza Street

Syrena Invest Ltd., seated at 00-351 Warsaw, 15 Zajęcza Street

Syrena II Ltd. , with registered office in 00-351 Warsaw, 15 Zajęcza Street

Syrena III Ltd., seated at 00-351 Warsaw, 15 Zajęcza Street

Syrena IV Ltd., with registered office in 00-351 Warsaw, 15 Zajęcza Street

List of subsidiaries

Syrena Consulting Ltd., seated at 00-351 Warsaw, 15 Zajęcza Street

Syrena Invest Ltd., with registered office in 00-351 Warsaw, 15 Zajęcza Street

Syrena II Ltd., with registered office in 00-351 Warsaw, 15 Zajęcza Street

Syrena III Ltd., seated at 00-351 Warsaw, 15 Zajęcza Street

Syrena IV Ltd., with registered office in 00-351 Warsaw, 15 Zajęcza Street