PRIVACY POLICY

Your privacy is a priority for us, and protecting your personal information is a key aspect of our operations. We present you with our Privacy Policy, which explains the steps we take to protect your information. You’ll find information about your rights and how data protection laws contribute to safeguarding your privacy and personal information. We encourage you to read this document carefully before using the services we offer.

RODO: 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.

We/Platforma Devetoper – represented by Janusz Obcowski calle Rio Taibillia 7, 03-193 San Miguel de Salinas, Alicante CIF Y6530008M

You/User: any natural person visiting the DEVETOPER platform or using one or more of the services or functionalities made available on DEVETOPER.

You/Agent: A company/representative/owner of a real estate brokerage using the services and functionality provided in the DEVETOPER platform.

As part of our Privacy Policy:

Who are we?

The main controller of your data for the provision of our international services is devetoper represented by Janusz Obcowski calle Rio Taibillia 7, 03-193 San Miguel de Salinas, Alicante CIF Y6530008M

The data controller of your personal data processed in connection with the services provided through the Polish DEVETOPER Website is: DEVETOPER represented by Janusz Obcowski calle Rio Taibillia 7, 03-193 San Miguel de Salinas, Alicante CIF Y6530008M

Current contact information is posted in the CONTACT section

2 What data do we collect about you?

2.1 Data provided directly by you

Registration on the Platform

To initiate the process of creating an Account on our platform, it is necessary for you to enter the data required for its creation and management. For better customization of services, you have the option to provide additional information, which can be withdrawn at any time. The entry of data considered necessary is mandatory for the creation and maintenance of the account – their absence will prevent registration. Providing other information is completely optional. In the context of the creation and management of your account, we carry out the processing of your Personal Data for specific purposes:

During your registration, in order to use the Services we provide, we may collect the following information about you:

Identification, registration information (such as name, surname, email address, company name, company address, tax identification number – NIP, telephone number, date of birth)

Booking information (e.g., details of each person booking a property or lodging apartment: name, nationality, reservation number, flight details including airlines, accommodations, departure and arrival times, check-in and check-out procedures)

Account information (such as login details, email address, password, account settings)

Payment information (e.g., debit/credit card number, other payment information, billing address)

Your photos (e.g., added to your profile)

Other information you provide (any data about yourself or others that you provide through our services or that you provide us access to on third party platforms)

When using certain functions of our platform, for verification reasons, we may ask you to provide additional information, such as, for example, an extract from the National Court Register or a current entry in the CIDG. Failure to provide this additional data, when requested, will prevent you from accessing certain platform features.

In situations where there is a reasonable suspicion of a violation of our Terms and Conditions that may harm the platform, we reserve the right to request additional information from you regarding the transaction in question. In such cases, the processing of such personal data is based on our legitimate interest in preventing violations of the Terms and Conditions and providing a safe and friendly environment for all Users.

Using the chat function on our site When you use the chat option to contact other agents, we collect the content of your messages and the data you share using this tool.

Telephone communication and e-mail exchanges

When you make contact with us by phone or email, we collect any data you wish to share with us during these interactions with our team or representatives including inquiries, conversations, complaints or other information. Promotional information (information provided when you participate in contests, sweepstakes or other promotional activities in accordance with their rules) We want to inform you that phone calls are not subject to recording.

From the moment personal data is provided to the selected Developer, i.e. from the moment DEVETOPER sends a message to him/her, the Developer, in the cases defined by data protection regulations, becomes an independent controller of such data. When contact information is left by an Agent for the purpose of obtaining details about a particular development, through forms offered or promoted by DEVETOPER, including on external platforms like Facebook used to promote our Developers’ projects, the data is transferred to the Developer responsible for the development. In such circumstances, under data protection laws, this Developer becomes a separate controller of this data.

In both of the described situations, the transfer of data to the selected Developer is justified by our interest to meet the expectations of people who left their data to obtain information about the investment they are interested in.

Using our services, including as an unregistered user

If you use our platform and provide us with your information through the available contact forms to receive an offer from us or initiate contact, we collect this information that you provide to us.

User Location Data

When you use our services, we automatically collect your approximate location (e.g., the city you are in). In addition, with your consent, we are able to collect accurate geolocation information from your mobile device, whether the app is active or not, based on your permission to access location data. We use a variety of technologies to determine your location, including IP address identification, cell tower location, Wi-Fi signals and GPS data.

This information is used and stored to improve and personalize our services, for example, to tailor the features offered to your preferences, to respond more efficiently to your requests (such as finding the nearest service center), or to provide personalized information about the places you visit (such as by sending personalized marketing messages related to accommodations or airport transportation at a particular location).

Using the customer arrival booking service – Fulfilling the order

When placing an order for booking services, your personal information is necessary for processing. To place an order, you must have an account on our platform. It is required to provide the data specified as mandatory in order to accept and process your order. Failure to provide this data will prevent the ordering process. Providing additional, non-mandatory information is optional. Processing of personal data takes place:

• in order to carry out the order process – the legal basis is the necessity to process the data for the performance of the contract (Article 6(1)(b) RODO); in the case of data provided voluntarily, the legal basis is your consent (Article 6(1)(a) RODO);

When you choose to use our specially designed customer arrival booking function, in accordance with the terms and conditions set forth in the terms and conditions, we will process the personal information you provided to us via the contact form to book this service. This includes the processing of your personal data provided to us in the course of the service, including in telephone and email communications, as well as customer information and information related to the booking of the service. Personal data may be processed for the purpose of providing the customer arrival booking service only if you have the status of a registered user. The provision of data is voluntary, but necessary to organize the booking of the customer arrival, which will enable us to contact you in connection with the provision of the service.

Sharing Information with Partners Offering Accommodation

Our business partners include online booking services, car rental companies and short-term tourist accommodation rental companies. When you book accommodation through our platform with one of our partners, we provide them with your personal information necessary to complete the booking and provide the selected service. The data transferred may include your name, contact information, identity document details, itinerary details, stay preferences, any special requests or needs, as well as other information required by the partner to provide the service. The process of sharing your data with partners is the same as if you had directly contacted them

If you provide a cell phone number, our partners may use it to send text messages related to your reservation. Some partners may also require payment card details (credit or debit) to guarantee your reservation.

Transmission of Data for Payment Processing

In order to use certain services (for example, booking accommodation, airport transportation or car rental) and to process payments for the benefit of our business partners, we need payment information, such as credit or debit card details and information necessary to process online payments. This payment information, which you provide when using our services, is shared with the companies we work with and third-party payment transaction processors (including companies specializing in fraud detection and other third-party service providers) to the extent required to fulfill our obligations to you, for example, to guarantee a reservation or process a payment to one of our partners, to protect against fraud and abuse of our platforms or services, with your consent or when required by law.

Specifically, if you use a credit or debit card to secure a reservation made through our services, your card information (including card number, expiration date, and CVV code, if required by the partner) is transmitted to the relevant partner companies that are responsible for processing the transaction.

Use of the contact form

Use of the contact form requires the entry of personal data considered mandatory. Failure to provide them will prevent the form from being processed. The decision to provide other, additional information remains at the user’s discretion and is completely voluntary. Personal data collected through the form are processed for the following purposes:

in order to respond to your inquiry, to resolve the matter presented, and to provide a service via an electronic contact form. This processing is based on our legitimate interest (Article 6(1)(f) of the DPA) and the need to process data for the performance of a contract (Article 6(1)(b) of the DPA);

For analytical and statistical purposes – the processing of data is based on our legitimate interest (Article 6(1)(f) RODO), which is to analyze statistics on user submissions through the platform, among other things, in order to improve its functionality. For marketing purposes, where your response will involve the provision of marketing information about services you are interested in – this processing is justified by your consent, confirmed by your active activity.

2.2 Automatically collected data when using our services

When you use our platform, we automatically collect information about you, such as:

Device Data We collect data about your device, including operating system version and unique identifiers such as the name of your mobile network. This device information is linked to your account with our agent DEVETOPER.

Location Information Depending on the privacy settings on your device, when you register your activity on an agent’s account, we may automatically collect data about your current location. We use a variety of technologies to determine it, including your IP address, GPS, Wi-Fi networks and cell phone base stations. The location information allows us to display your profile to potential customers and facilitate real estate trading in your area.

Login information We collect technical data, such as the IP address of the device, time zone and operating system you are using. We also record data related to your access to your account, including the date you registered, the date you last changed your password and the date you last successfully logged in, as well as the type and version of your web browser.

Platform activity data We collect data about your interaction with our platform, including information about the pages from which you were redirected to our site, the dates you visited, your search results and criteria, the listings you viewed, and the time you spent on the platform. We also collect data on the order in which you visit sections of our site.

Social networks-We manage the personal data of users who visit our accounts on social media platforms such as Facebook, YouTube, Instagram and Twitter. We process this data in the context of managing our profiles, in particular to communicate about our activities and to promote various offers and services. The legal basis for processing personal data in these situations is our legitimate interest (Article 6(1)(f) RODO), which involves the promotion of our brand.

Cookies We use cookies to manage user sessions, remember your selected language settings, and present you with advertisements that may be of interest to you. Cookies are small pieces of data sent from a web server that are stored on your device’s hard drive. They are used to collect information such as the time and date of your visit, browsing history, preferences and your login. You have the ability to adjust your browser settings to reject all cookies or a selection of them, and to receive notifications when the site attempts to place cookies on your device. Please note, however, that blocking or rejecting cookies may limit access to certain features of our platform or cause them to malfunction. To learn more about our use of cookies, please read our Cookies Policy.

4.1 Processing of data to enable access and delivery of services through the platform.

When you log in with your username or email address, we will use your first name, last name, phone number or email address to recognize you as a user and allow you to access our platform.

We use your email address and cell phone number (via SMS) to send you proposals and recommendations for our services or offers that may be of interest to you, all according to the preferences set in your agent account.

Such activities are carried out in order to properly fulfill the contract concluded with us, as well as on the basis of our legitimate interest when we conduct marketing activities.

4.2 Processing data to improve the use of the platform, to introduce new features, and to develop and provide other services by DEVETOPER

We use information about your activity, such as how you navigate the PLATFORM (e.g., clicks), to:

provide content tailored to your needs, for example by improving search results when you use our services;

analyze how long and how you use our platform, which helps us understand your interests and improve our services. Based on the ads that have caught your attention, we are able to offer recommendations for other listings that may be of interest to you;

monitor and evaluate the effectiveness of our marketing campaigns, as well as provide reports to our business partners and support our internal analytical processes.

Using login information, such as your email address and phone number, we identify the various devices (e.g., computer, cell phone, tablet) you use to access our Platform. This allows us to synchronize your activity on the Platform between all your devices, making it easier for you to use our services with equal ease, regardless of the device you choose.

We base the processing of this information on our legitimate legal interest, aiming to improve the user experience of the Platform and as part of the proper performance of the contract you have entered into with us.

In order to provide you with an even better user experience and access to innovative and useful features, we are constantly striving to improve our services. As part of this process, activities such as the introduction of new property search filters may require testing and research. In these situations, your personal data may be processed in accordance with our legitimate interest in developing our Platform. To protect your data, we have implemented a number of protection mechanisms, such as pseudonymization and encryption, to support the development of new features.

In an effort to provide services tailored to your expectations and maintain the highest standards of service, we process your personal data based on the legitimate interest of developing our Platform and the services it offers. This includes analyzing your activity on the Platform, using data from surveys and forms you have filled out, and, where necessary, your contact information to gather feedback on the quality of our services.

4.3 Data processing to ensure the security of the Platform and to verify compliance with the DEVETOPER Platform Terms and Conditions

We use your cell phone number, login information and unique device identifiers to administer and secure our platform, including diagnostic purposes, data analysis, testing, fraud prevention, information systems operation, support, reporting and data hosting. In order to prevent abuse and promote a safe environment by eliminating spam or offensive content sent by users, we conduct analysis of your communication carried out through chat functions on the platform.

In order to ensure compliance with the Terms and Conditions of use of the DEVETOPER platform, as well as to identify and combat all forms of abuse and irregularities related to the publication of advertisements or misleading other users, we analyze the information contained in the advertisements and the data obtained during the monitoring of compliance with the Terms and Conditions. To document detected irregularities, we may use, among other things, the content of correspondence with employees of the DEVETOPER platform.

We take such actions in order to properly perform the contract concluded with users, to improve our services, and on the basis of our legitimate interest in preventing abuse, in accordance with Article 6(1)(b) and (f) of the RODO.

4.4 Processing data to improve the quality of our services

In order to improve the quality of the services we offer and to ensure that our team meets the highest standards of customer service, we may contact you to assess your satisfaction, and use correspondence related to your inquiries, complaints or answers to questions. Among other things, this information is used for employee training and as part of our internal quality control procedures.

Your personal data is processed for these purposes on the basis of our legitimate interest, which is to continuously improve the quality of our services and provide the highest level of customer service.

5 Notification of changes to the Privacy Policy

Our Privacy Policy is subject to change or update. You will be notified of any modifications on this page, as well as via email or directly on our platform. If you do not agree with the changes, you have the option to close your account through your account settings and choose to deactivate your account.

Your rights

In connection with the processing of your personal data, applicable data protection regulations grant you certain rights. The extent of these rights depends on the nature of the activities we perform with your data.

Implementation of your user rights

To make it easier for you to exercise your rights, we have introduced special features within your agent account on the DEVETOPER platform. These allow you to update your company data or request the deletion of your account and related personal data. Taking care of the security of our users’ data, we ask you to carry out all actions related to the exercise of your rights directly through the functions available on your agent account in DEVETOPER. This allows us to confidently verify the authenticity of the request as having been made by the correct person. Please note, however, that the option to delete your personal data will be made available after our services have been terminated, i.e. after your account with DEVETOPER has been deactivated.

The right to access your personal data. This gives you the opportunity to see if and what your personal data is being processed by us, and allows you to obtain a copy of it. With this right, you can make sure that data processing is carried out in accordance with the law.

Right to rettification of personal data. Allows you to request the correction of data that is incomplete, incorrect or outdated. In response to your request, in order to ensure the accuracy of your data, we may be required to verify newly provided information.

Right to restrict the processing of your personal data. This right allows you to ask us to stop the processing of your personal data in the following situations: (a) when you want us to verify the accuracy of the data; (b) when our processing is unlawful; (c) when you need the data to establish, assert or defend your claims, even though we no longer need your data for our own processing purposes; (d) when you have objected to our processing, but we need to verify that we still have an overriding and legitimate basis to continue processing your personal data.

Right to erasure of personal data. This right allows you to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected. You also have the option to request the deletion of your data if you have successfully exercised your right to object to its processing, the data is being processed unlawfully, or we are required to delete it in order to comply with legal requirements. However, please be aware that under certain circumstances our legal obligation to process your data may prevent us from fulfilling your request for deletion.

Right to object to the processing of your personal data. You have the right to object to the processing of your data when it is done on the basis of our legitimate interests or those of third parties. You can do so for reasons based on your specific situation, especially if you believe the processing violates your rights or freedoms. You also have the right to object when your data is processed for direct marketing purposes. However, in some situations, we can prove that we have valid legitimate reasons for processing that outweigh your rights and freedoms, for example, to ensure the security of our Platform or to combat fraud. In such circumstances, your right to object will not result in the deletion of your personal data.

Right to Port Personal Data. As part of this right, we will provide you or your personally designated third party with your personal data in a structured format that is widely used and machine-readable. It is important for you to know that this right only applies to data that is processed automatically and is based on your consent or is necessary for the performance of a contract with us.

Exercising your rights is generally at no cost to you. You will not be charged any fees for access to your personal information or for exercising your other rights. However, where your request is clearly unreasonable or unreasonably repetitive, we may request a reasonable fee. We also have the right to refuse your request under special circumstances.

Implementation of your requests. We make every effort to respond to all legitimate requests within one month. In cases where your request is exceptionally complex or you make multiple requests, the process may extend beyond this period. In such a situation, you will be informed of the need to extend the deadline and we will keep you updated on the progress of your request.

You also have the right to file a complaint with the relevant regulatory authority at any time.

We would appreciate the opportunity to resolve your concerns before filing a complaint with the supervisory authority. Therefore, we encourage you to first contact us using the available contact form on our platform.

Communications and marketing activities

We will contact you via phone, chat, email, SMS or through notifications regarding our services/platform. The purpose of this communication will be to confirm your registration, inform you of the expiration or deactivation of your notices, provide other transactional information related to our services, and survey customer satisfaction. Since we consider the transmission of this information to be essential, you may not have the option to opt out of receiving such communications.

In addition, we may contact you to collect feedback on the quality of services provided by the DEVETOPER platform.

Some of our Services may involve receiving notifications or communications from us of a certain type (e.g., Observed service or Hot offers). In such case, these communications are part of the Service you have requested. You always have the option to opt-out of such service or limit its functionality according to the settings in your DEVETOPER agent account.

8 Recipients of your data

For the purposes set forth in Section 4 hereof, your personal data may be shared with the following categories of recipients:

Law enforcement, regulatory and other authorities. Your personal information may be transferred to law enforcement agencies, regulators, government agencies, institutions performing public tasks or acting on behalf of authorities, and other third parties if required by law.

In the event of a reorganization, sale, transfer or merger of a portion of our business or assets, as well as in situations where we seek to acquire or merge with other companies, the new owner may use your personal information in accordance with the applicable Privacy Policy.

Data transfer to third countries

When transferring personal data outside the European Economic Area (EEA), we ensure an adequate level of protection by applying one or more of the following measures:

Data is transferred to countries that, according to the European Commission, provide an adequate level of data protection. For more information, visit the European Commission’s page on the adequacy of data protection in countries outside the EU.

When working with certain suppliers, we use standard agreements approved by the European Commission that guarantee personal data protection on par with that offered in the EU. For more information, see the European Commission’s page on model agreements for the transfer of personal data to third countries.

Location and time of data storage

We store the data we collect about you both within and outside the European Economic Area (EEA) on servers that provide adequate security. We operate in such a way as to offer the highest quality of service, for example, through fast-loading websites or continuous improvement of our mobile applications.

Your personal data is kept for the period necessary to achieve the purposes for which it was collected, which includes meeting legal, accounting or reporting requirements.

To determine an appropriate retention period, we consider the amount of data, the type of data, including special category data, the risk of unauthorized access or disclosure, and the possibility of achieving the processing objectives by other means. We also consider the applicable regulations for the data we process.

We keep the personal data associated with your agent account on the DEVETOPER platform for the entire period of account ownership in order to be able to perform the services offered in accordance with the Terms and Conditions, as well as for marketing purposes.

After you deactivate your account, some of your personal information may continue to be retained by us to the extent and for the duration necessary to comply with legal requirements or to protect our legitimate interests, for example to prevent fraud.

Data related to the use of cookies is stored until the cookies expire or until you delete them.

If you have any questions about how long your data will be stored, we invite you to contact us through the available contact form.

10Security measures and data protection

We store the information we receive from you on servers that are properly secured. We have implemented the necessary technical and organizational measures to protect your personal data. At DEVETOPER, we regularly conduct security assessments of our network infrastructure and monitor internal regulations and procedures. These measures are designed to: (a) prevent accidental or illegal data loss, access or disclosure, (b) identify potential threats to network security, and (c) minimize security risks, including through risk assessments and regular testing. In addition, we ensure that payment data is encrypted using SSL technology.

However, please be aware that despite our security measures, transmission of information over the Internet or other publicly accessible networks may expose data to the risk of access by unauthorized third parties.

Privacy of ChildrenThe services we offer are not intended for minors under the age of 16. We do not knowingly collect personal information from individuals under this age. If you discover that we have received information from a child under the age of 16 without the consent of their guardians, please contact us immediately using the details available in the Contact Us section.

Contact

For more information or to exercise your rights, you can visit the “My Account” section and check the available settings or contact our team via the contact form available on our platform. If you have questions about the processing of your personal data, you also have the option to send us a letter at the address below:

Supervisory Authorities

The main data protection supervisory authority we work with is the Spanish Data Protection Agency: …

For local data protection issues, you also have the option to address inquiries to the President of the Office of Personal Data Protection, located at: 2 Stawki Street, 00-193 Warsaw.

Consent/withdrawal of consent

 I consent to the processing of personal data by the devetoper platform for marketing purposes, in particular for the display of advertisements tailored to your interests and preferences on the devetoper platform and on the Internet.