PRIVACY POLICY

This document sets out the ways and rules for WRO-Investment SL to obtain, process and use data and information from users of the www.wroinvestment.com website. Please read this Privacy Policy carefully. By accessing or using this website, as well as by providing us with any personal information, you confirm that you accept the terms and conditions contained in this document.

1. Data controller

The administrator of your personal data is WRO-Investment SL in Alicante AVDA BENISS, num 2,ESC, 2 PLANTA 35, PUERTA 196 EDF, BENIDOR BEACH I 03502 BENIDORM -(ALICANTE)

Tax identification number B56387392 (hereinafter: “WRO-Investment” or “Administrator”).
The Administrator can be contacted:
1) at the mailing address: Złota 44 lok. 333, 00 – 120 Warsaw,
2) at the e-mail address: biuro@wro-investment.pl,
3) at the telephone number: + 48 539 092 544.

1. Ways of obtaining data

We obtain your personal information:
1. through forms filled out online – information is collected through forms available on our website for the purposes of contacting us, booking, submitting questions and expressing comments;

2. by contacting us without going through the network – there are phone numbers and email addresses on the website where you can contact us;
3. When using the resources of the website www.wroinvestment.com – information about users is collected through cookies – these are small text files called “cookies”, sent by our website and stored on the user’s terminal device (computer, laptop, smartphone). Two types of cookies are used:
   a) session files – temporary files that are stored on the user’s terminal device until the user leaves the website or shuts down the web browser;
   b) permanent files – stored on the user’s terminal device for the time specified in the parameters of cookies or until they are deleted by the user.

Cookies are used for the following purposes:
1. Essential Cookies – contribute to the usability of the website by enabling basic functions such as site navigation and access to secure areas of the website. The website cannot function properly without these files,

2. Preference Cookies-allow the site to remember information that changes the look or function of the site, such as your preferred language or the region where you are located,
3. Statistical Cookies – help us understand how different users behave on our website by collecting and reporting anonymous information,
4. Marketing cookies – we use them to customize content and services to the individual needs and interests of website users and to continuously improve our website, making it even friendlier and better suited to users’ needs,
5. Unclassified cookies – are files that are in the process of classification, along with the providers of individual files.

The law states that we may store Cookies on your device if it is necessary for the operation of the website. For all other types of Cookies, the user’s permission must be obtained. Some Cookies are placed on your device by third-party services that appear on our website.

Our website uses cookies, which collect various information that, as a rule, do not constitute personal data (they do not allow the identification of a given user). They allow you to create profiles through which WRO-Investment SL evaluates your preferences. However, some information, depending on its content and use, can be linked to a specific person and thus be considered personal data.
The user can disable the option to accept Cookies in his browser at any time, however, the effect of such a change may be the loss of use of www.wroinvestment.com.

III. Purposes and basis of data processing

The personal data provided by you are processed:
1. for marketing purposes, including sending offers for rental and sale of real estate, information on promotions, new investments and events, as well as analyzing data for marketing purposes – on the basis of your consent (Article 6(1)(a) RODO),

2. for purposes resulting from the Administrator’s legitimate interests, on the basis of Article 6(1)(f) RODO, including:
   a) for statistical purposes;
   b) to tailor content and services to the individual needs and interests of service users and to continuously improve our website,
   c) to handle user inquiries sent via contact forms,
   d) to assert claims and defend against possible claims.
3. Data obtained through cookies are used, among other things, to ensure proper operation of the website, for statistical purposes, to remember information that changes the appearance or functioning of the site (such as the user’s preferred language or region), as well as for marketing purposes.
4. Period of data processing

Your personal data will be processed:
1. in the case of processing under 6(1)(a) RODO – until you revoke your consent to the processing of personal data;

2. in the case of processing based on 6(1)(f) RODO – until an objection is lodged, unless the Controller demonstrates the existence of valid legitimate grounds for the processing overriding the interests, rights and freedoms of the data subject, or grounds for establishing, asserting or defending claims.
3. Principles of personal data protection
4. WRO-INVESTMENT SL takes special care to ensure that all personal data are processed in a manner consistent with the requirements of generally applicable law, in particular in compliance with the Regulation (EU) 216/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons in relation to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (RODO), the Act of May 10, 2018, on the protection of personal data (Dz. Journal of Laws of 2019, item 1781, i.e.), the Act of July 18, 2002, on the provision of electronic services (Journal of Laws of 2020, item 344, i.e.) and the Act of July 16, 2004, Telecommunications Law ( Journal of Laws of 2024, item 34, i.e. )including, in particular, in accordance with the purposes for which they were collected and in accordance with the scope of authorizations (consents) granted and areas of processing permitted by law.
5. WRO-INVESTMENT SL processes personal data of website users to the extent appropriate for the purposes for which they are obtained. Some of the data must be made available on a mandatory basis, due to the technologies used on the Internet, the need for the proper functioning of our website, or in the event of a desire to use specific services offered by us or to obtain answers to specific requests and inquiries. Other data is provided by users voluntarily through our contact forms. In each case, we always inform you in a special statement (information clause) about, among other things, the purpose of processing your personal data, the legal basis, the categories of data collected and, above all, your rights and who to contact if you wish to exercise those rights.
6. We process the data for the period necessary to achieve the purposes for which they were collected and, in addition, for the period of the statute of limitations for claims related to the products and services offered by us and for the period in which we are obliged to do so under generally applicable laws.
7. We ensure the confidentiality, integrity and accountability of the personal data we process.
8. Processed personal data shall not be shared without the consent of the data subjects, unless the data is shared with entities related to the Administrator in terms of capital or personality, persons authorized to process personal data on the basis of an entrustment agreement concluded with WRO-INVESTMENT SL (including entities cooperating with the Administrator: entities providing IT services, accounting services, legal services, couriers), as well as entities authorized under applicable laws.
9. Please be advised that we use services and technologies offered by entities such as: Facebook, Microsoft, Google, which may transfer data outside the European Union. We inform you that the entities referred to in the preceding sentence, when transferring data, rely on decisions stating the appropriate degree of data protection in countries outside the European Economic Area, are certified by the Privacy Shield, as well as use standard contractual clauses approved by the European Commission, and guarantee that they will comply with the high standards of personal data protection that apply in the European Union, so the use of their services and technologies in the processing of personal data is lawful.
10. WRO-INVESTMENT SL ensures data security through appropriate technical and organizational measures aimed at preventing unlawful data processing and their accidental loss, destruction, damage and access to unauthorized persons.
11. User rights
12. You have the right of access to the content of your data and the right to rectification, erasure, restriction of processing, the right to data portability, the right to object, the right to withdraw consent at any time without affecting the legality of the processing performed on the basis of consent before its withdrawal. In detail, the scope of each of the above-mentioned rights and the situations in which you can exercise them are indicated in Articles 15-22 of the RODO.
13. You have the right to lodge a complaint with a supervisory authority if you believe that the processing of personal data concerning you violates applicable data protection laws.
14. If the processing is based on the data subject’s consent, the data subject has the right to withdraw consent at any time, with the proviso that this will not affect the lawfulness of the processing carried out on the basis of consent before its withdrawal.
15. A person whose data is processed may request information from WRO-INVESTMENT SL in writing or electronically regarding his/her personal data collected and processed by WRO-INVESTMENT SL , as well as his/her rights in connection with such processing.

VII. Changes regarding privacy policy
We reserve the right to make changes to this Privacy Policy, in particular in the event of changes in the sphere of applicable laws, including the protection of personal data. Users will be promptly informed of any changes at www.wroinvestment.com.

VIII. Contact
Any questions related to the processing and protection of personal data, including this Privacy Policy, please contact: biuro@wro-investment.pl