Privacy policy

I. DEFINITIONS

1. Personal Data Administrator
   Noho Investment Limited Liability Company with its registered office in Kraków, ul. Armii Krajowej 25, 30-150 Kraków, registered in the Register of Entrepreneurs of the National Court Register maintained by the District Court for Kraków-Śródmieście in Kraków, 11th Commercial Division of the National Court Register under KRS number: 0000600768, NIP: 5252646224, REGON: 363693536.
2. Website
   The website operated by the Administrator at: https://nohomanagement.pl
3. User
   A natural person using the Website.
4. Personal Data
   All information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
5. GDPR
   Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation).

II. GENERAL PROVISIONS

This Privacy Policy and Cookies document explains the rules for processing personal data on the Website by the Personal Data Administrator and related entities. It also outlines the use of cookies, which may be utilized or shared during the User's interaction with the Website.

III. SCOPE AND DATA COLLECTION IN CONNECTION WITH THE USER'S USE OF THE WEBSITE

In connection with the User's use of the Website, information about the User's activity on the Website, including data stored in cookies, extended conversion tags, and server logs, is collected.
Data related to the use of cookies generally do not enable the identification of the User (the Administrator processes only anonymized statistical data).
With the User's consent to data processing, the Administrator may also process certain information related to that consent, including the User's browser version, operating system name, IP address, or type of device used to grant consent.

IV. CONTACT WITH THE ADMINISTRATOR

For any questions regarding the processing of personal data by the Administrator, you may contact us via email at k.czuprynska@nohoinvestement.com or by phone at 509165606.

V. SCOPE OF PROCESSED PERSONAL DATA

While using certain functionalities of the Website, the User may be asked to provide personal data. The scope of mandatory and optional data is determined based on the needs of a given service. The data collected via the Website is directly obtained from the data subjects.
Users browsing the Website solely for informational purposes may have certain data collected through cookies or extended conversion tools, as informed by the Administrator. The use of cookies is described in sections XI and XIII of this Privacy Policy.
Providing data is voluntary but necessary to use the functionalities of the Website, such as contact forms. Lack of acceptance of this Privacy Policy means the User will not be able to use the functionalities requiring data submission.

VI. PURPOSES AND LEGAL BASES FOR DATA COLLECTION

The Administrator collects and processes Users’ personal data only in accordance with the provisions of this Privacy Policy. All data provided by the User will be used exclusively for the following purposes:

• Marketing purposes: when the User consents to receive commercial or marketing communications from the Administrator (including newsletter services) or the use of marketing tools. The legal basis for processing is Article 6(1)(a) of GDPR.
• Customer service: to provide support and contact the User, including updates about the Administrator's offerings, products, and services. The legal basis for processing is Article 6(1)(b) or (f) of GDPR.
• Legal obligations: to fulfill obligations arising from legal provisions. The legal basis for processing is Article 6(1)(c) of GDPR.
• Contractual obligations: to fulfill obligations under agreements with business partners. The legal basis is Article 6(1)(f) of GDPR.
• Analytical and development purposes: to improve user experiences, maintain and administer the Website, and ensure its security. The legal basis is Article 6(1)(f) of GDPR.
• Claims and legal defense: to establish, assert, or defend against claims, enforce terms of use, or investigate potential violations. The legal basis is Article 6(1)(f) of GDPR.
• Contact forms: for responding to inquiries or requests submitted via contact forms. The legal basis is Article 6(1)(f) of GDPR.
• Marketing profiling: for marketing purposes, including the presentation of personalized advertisements and remarketing. The legal basis is Article 6(1)(f) or (a) of GDPR.
• Third-party tools: for functionalities offered via third-party services integrated into the Website. The legal basis is Article 6(1)(f) or, where required, Article 6(1)(a) of GDPR (User’s consent).

VII. RECIPIENTS OF PERSONAL DATA

Users’ personal data may be shared by the Administrator with the following:

• Affiliated companies: entities within the Administrator's capital group or cooperating companies, if necessary for the Administrator’s interests.
• Authorized individuals: employees and collaborators who require access to personal data for their duties.
• Third-party service providers: including IT services, real estate brokerage, administrative services, postal or courier services, accounting, marketing, or legal support.
• Public authorities: in compliance with legal requirements, e.g., courts or law enforcement agencies.

If data is shared with entities outside the European Economic Area (EEA), such transfers will comply with applicable legal standards, including standard contractual clauses or other safeguards established by the European Commission.

VIII. RIGHTS OF DATA SUBJECTS

Users of the Website have the following rights concerning their personal data:

• Access: the right to access their personal data.
• Rectification: the right to correct inaccurate or incomplete data.
• Erasure: the right to request deletion of data.
• Objection: the right to object to processing based on the Administrator’s legitimate interests (e.g., marketing profiling).
• Withdrawal of consent: Users can withdraw their consent for data processing at any time without affecting the lawfulness of prior processing.
• Data portability: the right to transfer data to another controller.
• Restriction: the right to limit data processing.
• Complaint: the right to lodge a complaint with a supervisory authority.

IX. DATA RETENTION PERIOD

The Administrator retains and processes personal data only for the time necessary to achieve the purposes outlined in Section VI or as required by law. Once the purpose of processing is fulfilled, the Administrator will delete or anonymize the data.

X. SECURITY MEASURES

The Administrator employs appropriate technical and organizational measures to ensure the security and integrity of Users' personal data, following established technological standards to prevent unauthorized access.

XI. COOKIES AND SERVER LOGS

1. The Website uses cookies, which are short text files stored in the User's browser.
2. Cookies enable the recognition of the device used to access the Website during subsequent visits.
3. Some cookies are anonymized, preventing the identification of Users without additional information.
4. Users are informed about cookie use upon their first visit to the Website and may consent to their use.
5. Cookies serve the following purposes:
   • Session state: tracking Website usage for improvements.
   • Statistics: analyzing how Users interact with the Website.
   • Advertising: displaying personalized ads and retargeting.
   • User experience: improving Website usability and design.
6. Users can disable cookies via browser settings, but this may limit Website functionality.

XII. THIRD-PARTY TOOLS USED BY THE ADMINISTRATOR

The Website integrates third-party tools, such as:

• Google Services (Ads, Analytics, reCAPTCHA, etc.): used for marketing, analytics, and security.
• Hotjar: analyzes user behavior for optimization purposes.
• Microsoft Clarity: creates heatmaps and records user interactions to improve the Website.

Details on these tools, including how to opt out, are provided in the Privacy Policy.

XIII. PROFILING

The Administrator may use data for marketing profiling to improve the Website and personalize the User experience.

XIV. FINAL PROVISIONS

1. Matters not covered by this Policy are governed by applicable laws, including the GDPR.
2. Any updates to this Policy will be communicated via the Website.
3. This Policy is effective as of November 26, 2024.