Privacy Policy
CLICK THE FLAT (WWW.CLICKTHEFLAT.PL)
We care about your privacy and we want you to feel comfortable when using our services. This Privacy Policy indicates what kind of information about you may be collected and who is the administrator of your personal data. It also explains for what purpose, scope and for what period of time it will be processed, with whom and on what terms it can be shared, and what are your rights in relation to their processing.
In addition, this Privacy Policy defines the basic principles of personal data protection applicable to the ClickTheFlat service and contains information about cookies used by our website, as well as the rules for storing and accessing information stored on your device via cookies.
The information specified in this Privacy Policy has been prepared in accordance with the requirements of the Regulation (EU) 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 (General Data Protection Regulation, GDPR), in force since 25 May 2018.
Whenever we speak about data, we mean your personal data, e.g. your name, email address or telephone number, provided by you or obtained by us from other sources.
§ 1
Personal Data Administrator
The personal data administrator is OtoHo company with headquarters at 30 Mikolaj Kopernik St. in 00-336 Warsaw, Poland.
§ 2
Personal Data and Privacy
1. When are we processing your data?
If you intend to use our services, you will be asked to provide us with your personal information. Your data will be processed by us for the purposes mentioned below, related to the functioning of the website and the provision of services. Whenever you use our services (e.g. when you make an apartment reservation through our website), your personal data is processed. Each time you send your comments or complaints, or when you use the contact form on our website, we also process your personal information. We also process your personal data when we send you marketing information or when you participate in contests and promotional campains organized by us.
2. Why are we processing your data?
We process your data primarily to provide services offered through our website and to conclude and perform the contract, including handling complaints, or to take action on your request before concluding the contract. If necessary, we are able to contact you on organizational matters, e.g. related to your reservation. The processing of some of your data is also necessary to meet our legal obligations (e.g. resulting from tax acts, Accounting Act etc.), such as the obligation to store certain data for a certain period of time, gathering some information to verify and identify the user or provide data to authorized bodies or entities. We also process your data in other legitimate purposes, including:
a) monitoring of your activity on our websites (e.g. through cookies and other tools),
b) possible profiling of your interests and needs (also with the help of cookies) to send you only those services that may interest you,
c) possible direct marketing of our products or services, which allows us to inform you about our offer,
d) possibility of establishing, investigating and defending us from any claims related to our activity,
e) possibility of monitoring, detecting and preventing any frauds or abuses commited through our services.
If you have given us the proper permission, we can send you our newsletter or contact you regarding new offers by phone, e-mail or SMS. When you participate in a contests or other promotional campaign organized by us, we process your data based on your permission to organize the event, select winners and award prizes. If we decide to process your personal data for a different purpose, we will inform you about it and ask your permission (if required by law).
3. What kind of data are we processing?
We process both the data you gave us and the data we have gathered ourselves (e.g. by using cookies or other tools), as well as the data that have been made available or entrusted to us by other data controllers, e.g. external booking sites, your bank, etc. We also process data sent to us by your device while using our services (cookies). The data is processed only for the purpose for which it was collected (data minimization).
4. The legal basis of data processing
The legal grounds for data processing are:
1) performing of a contract to which you are party or in order to take steps at your request prior to entering into a contract (Article 6 paragraph 1(b) of GDPR) or
2) consent given by you to the processing of your personal data (Article 6 paragraph 1(a) of GDPR) or
3) legitimate interests pursued by data administrator (Article 6 paragraph 1(f) of GDPR), including e.g.:
a) data processing to determine, assert or defend any claims,
b) data processing for analytical and statistical purposes,
c) conducting a customer satisfaction survey or
4) compliance with a legal obligation (Article 6 paragraph 1(c) of GDPR), e.g. related to accounting or resulting from:
a) The Accounting Act of 29 September 1994,
b) The Goods and Services Tax Act of 11 March 2004,
c) The Act on Providing Services by Electronic Means of 18 July 2002,
d) The Telecommunications Act of 16 July 2004.
We process your personal data in accordance with the applicable provisions on the protection of personal data, including the GDPR.
5. Providing data
Providing data by you is voluntary, although in some cases it may be necessary (e.g. to conclude a contract and proper provision of our services, or to meet law requirements). Not providing the data may result in disabling access to some services and functionalities of our website.
§ 3
Processing Period
Your personal data will be processed as briefly as possible, i.e. only for the period defined by the legal basis, so until:
a) the legal obligation that obliges us to process your data will cease,
b) the contract concluded via our website and the possibility of pursuing claims related to it will cease to apply,
c) you will cancel the consent you gave to the processing of your personal data given for a specific purpose, or if the basis for the data processing was the legitimate interest of the data administrator, or if the data were processed for direct marketing, including profiling.
§ 4
Data Safety
When processing your personal data, we apply appropriate security measures in accordance with applicable law, to ensure confidentiality, protection against unauthorized or unlawful processing and accidental loss, destruction or damage of the data. Thus, we take full responsibility for your data safety. We protect your personal data by using state-of-the-art technologies, not only by complying with applicable laws, but also by using additional solutions that will ensure the security of the data. The main methods of protection are the use of secure connections (e.g. SSL protocols), data encryption and the use of other technical, programming or organizational solutions (e.g. limiting and controlling access to data). We assure you that your personal data is processed only by authorized persons and entities.
§ 5
Your rights
1. You have the right to request us to know whether we process your personal data, for what purpose we process it, which categories of your data we have collected, what are the categories of recipients of your data and what is the duration of your data storage.
2. You have the right to request access to your personal data, to correct it or to complete the missing data.
3. You have the right to request deletion of your personal data being processed by us. We will promptly execute your request, as long as the law does not oblige us to continue processing of your data, the law does not indicate an obligation that we must fulfill, or if we do not need your data to establish, assert or defend any claims. We will delete your personal data if:
a) it is no longer necessary for the purposes for which it was collected or otherwise processed,
b) we were processing it based on your consent, which you withdrew, and there is no other legal basis for processing it,
c) you objected to the processing of your data serving the legitimate interest of the administrator, and at the same time there are no other circumstances that justify the further processing of the data,
d) it was processed unlawfully,
e) the law requires it.
4. You have the right to request the withdrawal of consent to the processing of your personal data by us, as long as the basis for processing is your consent; data processing will be legal until you withdraw your consent.
5. You have the right to request restricting the processing of your personal data if:
a) you contest the accuracy of the data; the restriction takes place until the data can be verified,
b) there is no legal basis for processing, and you oppose the definitive deletion of the data,
c) we no longer need your data for the purposes in which we have collected it, but it is necessary for you to defend your interests or to pursue your claims,
d) you objected to the processing of your data; the restriction remains in effect until it is established whether there is a basis for processing superior to your objection.
6. You have the right to object to the processing of your personal data at any time:
a) on grounds relating to your particular situation – regarding the data processing based on the legitimate interests of the administrator (listed in Article 2 paragraph 4(3) of this Privacy Policy) – in this case, we will immediately stop processing as long as there is no overriding reason for the objection,
b) if the data is processed for direct marketing purposes.
7. As a result of using the rights listed above (Article 5 paragraphs 3-6 of this Privacy Policy), it is possible that we will cease (in whole or in part) to provide you with some services that require processing of your personal data.
8. You have the right to receive personal data that you have provided to us in a structured, commonly used and machine readable format. You also have the right to request that we transmit this data directly to another controller. This applies to data processed in an automated manner:
a) which we process based on your consent or
b) which we process on the basis of the contract concluded with you.
Contact us if you want to exercise your rights.
If you decide that your personal data is being processed unlawfully or your rights have been violated, you can file a complaint with the supervisory body, i.e. the Inspector General for Personal Data Protection, or his successor – the President of the Personal Data Protection Office.
§ 6
Data sharing, external services, data receivers
We do not share your personal data with individuals or third parties. The only exceptions are:
1. If you voluntarily agree to share your data; your consent can be canceled at any time.
2. The situation in which data sharing is necessary in order to provide the service or to perform part of the tasks related to its proper implementation – in this case your personal data may be transferred for a specific purpose to external entities, including our subcontractors (at the time we remain the administrator of the data and we are still responsible for its security); these include among others:
a) persons cooperating with us on the basis of civil-law agreements, supporting our current activity,
b) our website software provider,
c) our host provider,
d) our accounting office,
e) entity facilitating the optimization of our website,
f) entity providing us with technical support.
3. In special cases, we may be asked to disclose your personal data to third parties (e.g. law enforcement authorities) on the basis of generally applicable laws. Each request for access is thoroughly examined by us, and the transfer of the data can only take place if we are sure that there is an important and effective legal basis for such action.
§ 7
Cookies
Our service uses the so-called cookies files (cookies) - IT data, especially small text files, saved and stored in the memory of your device, enabling you to use our website.
1. We use cookies and similar technologies to store information or access information stored on the your device.
2. Thanks to the use of cookies, we can customize our offer to your individual needs and lead possible profiling and monitoring of your activity on our website. Cookies contain the name of their source domain, information on the time of their storage in the device and the assigned value.
3. The cookies we use are safe for your devices, in particular they are not viruses or other unwanted software and do not contain such software. The way cookies work does not allow them to download any data from your device, but only allows access to selected information.
4. The cookies we use differ in terms of type and duration.
4.1. Due to the time the cookie file will be placed on your device, cookies used on the website can be divided into:
a) session cookies – they are stored on your device and remain there until the session of the browser is terminated; the saved information is then permanently deleted from the device's memory;
b) persistent cookies – they are stored in your device and remain there until they are deleted or expired; ending the browser session or turning off the device does not delete them.
4.2. Due to the origin, cookies used on our website can be divided into:
a) our own cookies – placed on the website directly by us;
b) external cookies – placed on the website by external entities whose page components have been triggered by us, e.g. Google Analytics, Facebook, etc.
5. We use cookies for the following purposes:
a) website configuration (including adjusting its content or functionality to your preferences) and optimization of its functioning;
b) creating anonymous statistics that allow us to analyze how users use our website, which in turn allows us to improve its structure and content;
c) obtaining information about the manner in which the user has visited our website (e.g. advertising banner displayed on the third party's website, Google Adwords, etc.);
d) ensuring the safety and reliability of the service.
6. Using cookies to store information or access information stored on your device is possible only if you give your prior consent to such action; unless the storage or access to information is necessary to provide requested service – then your consent is not required.
6.1. You can manage your consents by modifying the settings of software used to access our website (e.g. web browser settings or your device software settings).
6.2. You can reject or withdraw your consent at any time by changing the appropriate settings of your browser or device.
7. In most cases, the software allowing the use of our website (mainly web browsers) allows for the use and storage of cookies on your device by default. Therefore, we recommend you to check the settings and possibly make changes according to your privacy preferences. Remember that you can block the automatic use of cookies. To learn how to manage cookies, including disabling them in your browser, you can use your browser help files.
8. If you agree to the use of cookies, this means your consent to use them in accordance with the rules described in this Privacy Policy. In this case, we will be entitled to use cookies and similar technologies to store information or access information stored on your device.
9. Remember that if you disable cookies, you may experience difficulties in using some of the features of our website.
While providing our services, we may also need to install certain software on your device and use this software. However, we will inform you of this fact and we will ask your permission.
§ 8
Contact with the Data Administrator
Would you like to exercise your rights related to personal data or ask about something related to our Privacy Policy?
Please contact us by sending a message to info@clicktheflat.pl or writing a letter addressed to ClickTheFlat, 30 Mikolaj Kopernik St., 00-336 Warsaw, Poland with the annotation „personal data protection”.
We reserve the right to update or change our Privacy Policy at any time. All such changes will be published on our website in the PRIVACY POLICY section. By using our website, you accept the above Privacy Policy.
