prywatnosc

§1 Definitions
Service - the "comfortapartments.eu" website operating at https://comfortapartments.eu.
External service - websites of partners, service providers or service recipients cooperating with the Administrator.
Service / Data Administrator - the Administrator of the Service and the Data Administrator (hereinafter the Administrator) is the company: Comfort Apartments & Properties sp. z o.o., NIP: 5851473043, with its registered office at ul. Chmielna 3C/11, 80-748 Gdańsk.
User - a natural person for whom the Administrator provides services electronically via the Service.
Device - an electronic device together with software through which the User accesses the Service.
Cookies - text data collected in the form of files placed on the User's Device.
GDPR - 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, and repealing Directive 95/46/EC (General Data Protection Regulation).
Personal data - means information about an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing - means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Restriction of processing - means the marking of stored personal data with the aim of limiting their processing in the future.
Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Consent - consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.
Personal data breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Pseudonymisation - means the processing of personal data in such a manner that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures preventing it from being attributed to an identified or identifiable natural person.
Anonymisation - Data anonymisation is an irreversible process of operations on data that destroys / overwrites "personal data", making it impossible to identify or link a given record to a specific user or natural person.

§2 Data Protection Officer
Pursuant to Art. 37 GDPR, the Administrator has not appointed a Data Protection Officer. For matters concerning data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies
Internal cookies - files placed on and read from the User's Device by the Service's ICT system.
External cookies - files placed on and read from the User's Device by the ICT systems of external Services. Scripts of external Services that may place cookies on the User's Devices have been deliberately included in the Service through scripts and services made available and installed in the Service.
Session cookies - files placed on and read from the User's Device by the Service during a single session of a given Device. Once the session ends, the files are deleted from the User's Device.
Persistent cookies - files placed on and read from the User's Device by the Service until they are manually deleted. The files are not deleted automatically after the Device's session ends, unless the User's Device is configured to delete cookies after the Device's session ends.

§4 Security of data storage
Cookie storage and read mechanisms - The mechanisms for storing, reading and exchanging data between Cookies saved on the User's Device and the Service are carried out through the built-in mechanisms of web browsers and do not allow other data to be retrieved from the User's Device or data from other websites the User has visited, including personal data or confidential information. Transferring viruses, Trojan horses and other worms onto the User's Device is also practically impossible.
Internal cookies - the cookies used by the Administrator are safe for Users' Devices and do not contain scripts, content or information that could threaten the security of personal data or the security of the Device used by the User.
External cookies - the Administrator takes all possible measures to verify and select the service's partners with regard to User security. The Administrator works with well-known, large partners of global social trust. However, the Administrator does not have full control over the content of cookies originating from external partners. To the extent permitted by law, the Administrator is not responsible for the security of cookies, their content or their licence-compliant use by Scripts installed in the service that originate from external Services. The list of partners is provided later in the Privacy Policy.
Cookie control. The User can, at any time, independently change the settings concerning the saving, deletion and access to data of saved cookies for every website
Information on how to disable cookies in the most popular desktop browsers is available at: how to disable cookies or from one of the following providers:

Managing cookies in the Chrome browser
Managing cookies in the Opera browser
Managing cookies in the FireFox browser
Managing cookies in the Edge browser
Managing cookies in the Safari browser
Managing cookies in the Internet Explorer 11 browser

The User may at any time delete all cookies saved so far using the tools of the User's Device through which the User uses the Service's services.

Threats on the User's side - The Administrator applies all possible technical measures to ensure the security of data placed in cookies. However, please note that ensuring the security of this data depends on both parties, including the User's actions. The Administrator is not responsible for the interception of this data, impersonation of the User's session or its deletion as a result of the conscious or unconscious activity of the User, viruses, Trojan horses and other spyware with which the User's Device may be or has been infected. To protect themselves against these threats, Users should follow the rules of using the network.
Storage of personal data - The Administrator ensures that it makes every effort to keep the personal data voluntarily provided by Users secure, with access to it limited and carried out in accordance with its purpose and the purposes of processing. The Administrator also ensures that it makes every effort to protect the data it holds against loss, by applying appropriate physical and organisational safeguards.

§5 Purposes for which cookies are used
Improving and facilitating access to the Service
Personalising the Service for Users
Keeping statistics (users, number of visits, types of devices, connection, etc.)

§6 Purposes of personal data processing
Personal data voluntarily provided by Users is processed for one of the following purposes: Provision of electronic services:
Communication between the Administrator and Users on matters related to the Service and data protection
Ensuring the Administrator's legitimate interest
Data about Users collected anonymously and automatically is processed for one of the following purposes: Keeping statistics
Ensuring the Administrator's legitimate interest

§7 Cookies of external Services
On the Service, the Administrator uses javascript scripts and web components of partners that may place their own cookies on the User's Device. Remember that in your browser settings you can decide for yourself which cookies may be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookies:

Keeping statistics: Google Analytics

Services provided by third parties are beyond the Administrator's control. These entities may change their terms of service, privacy policies, the purpose of data processing and the way cookies are used at any time.

§8 Types of data collected
The Service collects data about Users. Some of the data is collected automatically and anonymously, and some of the data is personal data provided voluntarily by Users when signing up for individual services offered by the Service. Anonymous data collected automatically:
IP address
Browser type
Screen resolution
Approximate location
Subpages of the service opened
Time spent on a given subpage of the service
Operating system type
Address of the previous subpage
Referring page address
Browser language
Internet connection speed
Internet service provider
Data collected during registration: First name / surname / nickname
Email address
IP address (collected automatically)
Data collected when subscribing to the Newsletter service: Email address
Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to the statistics service provider.

§9 Access to personal data by third parties
As a rule, the sole recipient of the personal data provided by Users is the Administrator. Data collected as part of the services provided is not transferred or resold to third parties. Access to the data (most often on the basis of a data processing entrustment agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to run the service, i.e.:

§10 Manner of processing personal data
Personal data voluntarily provided by Users: Personal data will not be transferred outside the European Union, unless it has been published as a result of an individual action by the User (e.g. entering a comment or post), which will make the data available to anyone visiting the service.
Personal data will not be used for automated decision-making (profiling).
Personal data will not be resold to third parties.
Anonymous data (without personal data) collected automatically: Anonymous data (without personal data) will be transferred outside the European Union.
Anonymous data (without personal data) will not be used for automated decision-making (profiling).
Anonymous data (without personal data) will not be resold to third parties.

§11 Legal bases for processing personal data
The Service collects and processes Users' data on the basis of: 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, and repealing Directive 95/46/EC (General Data Protection Regulation), Art. 6(1)(a)
the data subject has given consent to the processing of their personal data for one or more specific purposes
Art. 6(1)(b)
processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
Art. 6(1)(f)
processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)
Act of 16 July 2004 – Telecommunications Law (Journal of Laws 2004, No. 171, item 1800)
Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994, No. 24, item 83)

§12 Period of personal data processing
Personal data voluntarily provided by Users: As a rule, the indicated personal data is stored only for the period during which the Administrator provides the Service within the Service. It is deleted or anonymised within 30 days of the end of the provision of services (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.). An exception is a situation that requires securing the legitimate purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of the User's request for its deletion, for no longer than 3 years in the event of a breach or suspected breach of the service's terms and conditions by the User. Anonymous data (without personal data) collected automatically: Anonymous statistical data, which does not constitute personal data, is stored by the Administrator for the purpose of keeping the service's statistics for an indefinite period.

§13 Users' rights related to the processing of personal data
The Service collects and processes Users' data on the basis of: The right to access personal data.
Users have the right to access their personal data, exercised upon a request submitted to the Administrator
The right to rectification of personal data
Users have the right to request that the Administrator immediately rectify personal data that is incorrect and/or complete incomplete personal data, exercised upon a request submitted to the Administrator
The right to erasure of personal data
Users have the right to request that the Administrator immediately erase personal data, exercised upon a request submitted to the Administrator. In the case of user accounts, deletion of the data consists of anonymising the data enabling identification of the User. The Administrator reserves the right to withhold the fulfilment of a data deletion request in order to protect the Administrator's legitimate interest (e.g. where the User has breached the Terms and Conditions or the data was obtained as a result of correspondence).
In the case of the Newsletter service, the User can delete their personal data themselves using the link included in every email sent.
The right to restrict the processing of personal data
Users have the right to restrict the processing of personal data in the cases indicated in Art. 18 GDPR, including questioning the accuracy of the personal data, exercised upon a request submitted to the Administrator
The right to data portability
Users have the right to obtain from the Administrator the personal data concerning the User in a structured, commonly used, machine-readable format, exercised upon a request submitted to the Administrator
The right to object to the processing of personal data
Users have the right to object to the processing of their personal data in the cases specified in Art. 21 GDPR, exercised upon a request submitted to the Administrator
The right to lodge a complaint
Users have the right to lodge a complaint with the supervisory authority responsible for the protection of personal data.

§14 Contacting the Administrator
You can contact the Administrator in one of the following ways
Email address - booking@comfortapartments.eu

§15 Service requirements
Restricting the saving of and access to cookies on the User's Device may cause some functions of the Service to malfunction.
The Administrator bears no responsibility for malfunctioning Service functions in the event that the User restricts in any way the ability to save and read cookies.

§16 External links
Within the Service – in articles, posts, entries or Users' comments – there may be links to external websites with which the Service Owner does not cooperate. These links, and the pages or files indicated by them, may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for content located outside the Service.

§17 Changes to the Privacy Policy
The Administrator reserves the right to change this Privacy Policy at will, without the need to inform Users, with regard to the use of anonymous data or the use of cookies.
The Administrator reserves the right to change this Privacy Policy at will with regard to the processing of Personal Data, of which it will inform Users who have user accounts or are subscribed to the newsletter service, by email within 7 days of the change. Continued use of the services constitutes acknowledgement and acceptance of the changes made to the Privacy Policy. If the User does not agree with the changes introduced, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.
The changes introduced to the Privacy Policy will be published on this subpage of the Service.
The changes introduced come into force upon their publication.

GDPR & Privacy policy

GDPR

Privacy Policy