General Information Clause

Understand our personal data protection principles and how we apply them in practice.

Information Clause

www.novisa.pl

I. Personal Data Controller

The controller of your personal data is Novisa Development sp. z o.o. (formerly: Novisa Development spółka z ograniczoną odpowiedzialnością sp. j.) (ul. Cieślewskich 53, 03-017 Warszawa), KRS: 0000973276, NIP: 7010044936, REGON: 140733062, share capital: 10,000,000.00 PLN (“Novisa”).

II. Data Protection Officer

For matters concerning personal data, you may contact the Data Protection Officer:

1. by phone: (22) 545 70 20;
2. by email at: [email protected];
3. in writing to: Novisa Development sp. z o.o., ul. Cieślewskich 53, 03-017 Warszawa.

III. Purposes and Legal Bases for Data Processing

Depending on the situation, Novisa may process your personal data for the following purposes and on the following legal bases:

1. for the purpose of conducting correspondence – realizing the legitimate interest of Novisa (i.e., pursuant to Article 6(1)(f) of the GDPR), which is to contact clients (including surveying their satisfaction levels), contractors, and other individuals (including responding to their inquiries) via electronic mail (e-mail), traditional mail, telephone, as well as through the website contact form, online chat, helpline, etc.;
2. for the purpose of concluding or performing an agreement entered into with you (i.e., Article 6(1)(f) of the GDPR), including agreements such as: reservation agreement, developer agreement, property transfer agreement, preliminary agreement, property sale agreement;
3. for the purpose of establishing, asserting, or defending against claims – realizing the legitimate interest of Novisa (i.e., pursuant to Article 6(1)(f) of the GDPR) – by taking necessary actions if required, particularly actions concerning your personal data (e.g., responding to claims related to their processing);
4. for the purpose of conducting marketing:
   • realizing the legitimate interest of Novisa (i.e., pursuant to Article 6(1)(f) of the GDPR), which is to present Novisa’s offer in response to a client’s inquiry, submitted via electronic mail (e-mail), traditional mail, telephone, as well as through the website contact form, online chat, helpline, etc.;
   • based on your granted consent (i.e., pursuant to Article 6(1)(a) of the GDPR) to also present you with offers from Novisa’s partners, by contacting you at the phone number you provided (via SMS messages and voice calls) or by sending messages to the email address you provided;
5. for the purpose of fulfilling legal obligations incumbent upon Novisa (i.e., pursuant to Article 6(1)(c) of the GDPR), e.g., by providing or disclosing documentation (including personal data) to authorized public administration bodies to the necessary extent, among others, to enable these bodies to examine Novisa’s compliance with generally applicable regulations.

IV. Categories of Data Recipients

Your personal data may be disclosed to the following categories of entities:

1. to entities authorized by law (courts, state authorities, etc.);
2. to subcontractors and other entities providing services to Novisa, including in particular entities providing accounting, IT, marketing, communication, legal, and debt collection services, credit intermediaries, and entities providing document destruction services;
3. to entities providing analytical services, including entities providing website statistics analysis services;
4. to companies affiliated with Novisa.

In each case, the sharing of your personal data with the aforementioned recipients will only occur when it is necessary and based on appropriate authorization, a personal data processing entrustment agreement, or pursuant to applicable regulations, and with due observance of confidentiality and security requirements.

V. Transfer of Data Outside the European Economic Area

1. Novisa may transfer your personal data outside the European Economic Area – to a third country, to which the transfer of personal data will take place based on appropriate legal mechanisms such as relevant European Commission decisions, standard contractual clauses, or other similar legal instruments provided for in the GDPR.
2. Your data may be transferred to the United States, particularly via Google Analytics, which Novisa uses for website traffic analysis (“Google Analytics”). The transfer of data via Google Analytics involves the potential risk of access to your personal data by US special services (depending on Google Analytics settings, the scope of data may include IP address, identifiers used by Google Analytics such as Client ID, user session data, e.g., time spent on visited subpages). Data transfer to Google Analytics will always occur based on your consent (Article 6(1)(a) of the GDPR), which you can also express through your web browser’s cookie settings.
3. You have the right to obtain a copy of your personal data transferred to third countries at any time.

VI. Data Retention Period

Novisa will store your personal data:

1. for the purpose of concluding and performing agreements:
   • until the termination or expiration of the agreement – this applies to data necessary for the proper performance of the agreement;
   • until the expiration of data retention obligations resulting from legal provisions – to the extent that data will be processed within the scope of fulfilling a legal obligation (e.g., tax regulations);
2. for the purpose of conducting correspondence:
   • until the completion of matters to which the given correspondence relates;
   • until the expiration of the agreement or the expiration or statute of limitations of claims related thereto – when the correspondence concerns the performance of an agreement concluded with you or is conducted for the purpose of concluding a new agreement;
   • until the expiration or statute of limitations of claims – when the correspondence concerns the establishment, assertion, or defense against claims;
   • until the expiration of data retention obligations resulting from legal provisions – when correspondence is conducted for the purpose of fulfilling legal obligations incumbent upon Novisa;
3. for the purpose of realizing the legitimate interests of Novisa
   • until the expiration or statute of limitations of claims – when data will be processed for the purpose of establishing, asserting, or defending against claims;
   • until data retention is no longer necessary for the realization of Novisa’s legitimate interests;
4. for the purpose of conducting marketing:
   • until the completion of correspondence related to the given offer inquiry or until data retention is no longer necessary for the realization of Novisa’s legitimate interests, or
   • until the withdrawal of consent for data processing for this purpose, but for no longer than 3 years;
5. for the purpose of fulfilling legal obligations incumbent upon Novisa – until the expiration of data retention obligations resulting from legal provisions.

VII. Your Rights

When Novisa processes your data, you have the following rights – under the conditions specified in detail in the GDPR:

1. to obtain access to your data and receive copies thereof;
2. to request the immediate rectification (correction) of your data;
3. to request the erasure of your data (unless Novisa has legal grounds for further processing them);
4. to restriction of processing of your data, inter alia, in case of questioning the accuracy of such data – for a period allowing Novisa to verify the accuracy of such data;
5. to data portability – the right to receive personal data provided to Novisa based on your consent or agreement, in a structured, commonly used, machine-readable format, but only when such data is processed by Novisa in an automated manner (this does not apply to paper records); this right may be exercised by requesting the direct transmission of such data to another entity;
6. to lodge a complaint with the supervisory authority – to the President of the Personal Data Protection Office – if you believe that data is being processed unlawfully;
7. to withdraw consent for the processing of personal data – this applies only to data that Novisa will process based on your granted consent, with the reservation that the withdrawal of consent will not affect the lawfulness of data processing prior to the withdrawal of consent.
   To exercise your rights, you may contact Novisa in one of the ways specified in point II.

VIII. Information on Profiling

Your personal data will not be processed by Novisa in an automated manner (including profiling) for the purpose of making decisions that produce legal effects concerning you or similarly significantly affect you.

IX. Right to Object

You may at any time object to Novisa’s processing of your personal data for the purpose of realizing a legitimate interest (Article 6(1)(f) of the GDPR) by contacting Novisa in one of the ways specified in point II. Novisa will then no longer be able to process your personal data, unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or grounds for the establishment, exercise, or defense of legal claims.

X. Information on the Requirement or Voluntariness of Providing Data and the Consequences of Non-Provision

The provision of your personal data is voluntary and is not a contractual or statutory requirement, but it may be a necessary condition for concluding an agreement with Novisa and subsequently performing it correctly.

Information Clause for individuals participating in recruitment conducted by Novisa Development sp. z o.o.

www.novisa.pl

Information Clause for individuals participating in recruitment conducted by Novisa Development sp. z o.o. (formerly: Novisa Development spółka z ograniczoną odpowiedzialnością sp. j.)

I. Personal Data Controller

The controller of your personal data is Novisa Development sp. z o.o. (formerly: Novisa Development spółka z ograniczoną odpowiedzialnością sp. j.) (ul. Cieślewskich 53, 03-017 Warszawa), KRS: 0000973276, NIP: 7010044936, REGON: 140733062, share capital: 10,000,000.00 PLN (“Novisa”).

II. Data Protection Officer

For matters concerning personal data, you may contact the Data Protection Officer:

1. by phone at: (22) 545 70 20;
2. by email at: [email protected];
3. in writing to: Novisa Development sp. z o.o., ul. Cieślewskich 53, 03-017 Warszawa.

III. Purposes and Legal Bases for Data Processing

Depending on the situation, Novisa may process your personal data for the following purposes and on the following legal bases:

1. for the purpose of conducting recruitment:
   • fulfilling legal obligations incumbent upon Novisa (i.e., pursuant to Article 6(1)(c) of the GDPR) – this applies to data that must be collected from a job candidate in accordance with regulations (particularly labor law);
   • taking necessary steps prior to entering into an agreement with you (i.e., pursuant to Article 6(1)(b) of the GDPR) – this applies to data provided in recruitment documents, conducted for the purpose of establishing cooperation on a basis other than an employment contract;
   • based on your consent (i.e., pursuant to Article 6(1)(a) of the GDPR) – this applies to data provided for future recruitment purposes and the processing of additional data provided in recruitment documents (e.g., photos);
2. for the purpose of concluding and performing agreements by Novisa, including employment contracts:
   • taking necessary steps prior to concluding an agreement and subsequently performing an already concluded agreement (i.e., pursuant to Article 6(1)(b) of the GDPR);
   • fulfilling legal obligations incumbent upon Novisa (i.e., pursuant to Article 6(1)(c) of the GDPR) – e.g., those arising from tax regulations, labor law, and social insurance;
3. for the purpose of establishing, asserting, or defending against claims – including those related to a concluded agreement or the processing of your personal data – when it is necessary for the realization of Novisa’s legitimate interest (i.e., pursuant to Article 6(1)(f) of the GDPR);

IV. Categories of Data Recipients

Your personal data may be disclosed to the following categories of entities:

1. to entities authorized by law (courts, state authorities, etc.);
2. to subcontractors and other entities providing services to Novisa, including in particular entities providing accounting, IT, marketing, communication, legal, and debt collection services, and entities providing document destruction services;
3. to entities providing analytical services, including entities providing website statistics analysis services;
4. to companies affiliated with Novisa. In each case, the sharing of your personal data with the aforementioned recipients will only occur when it is necessary and based on appropriate authorization, a personal data processing entrustment agreement, or pursuant to applicable regulations, and with due observance of confidentiality and security requirements.

V. Transfer of Data Outside the European Economic Area

1. Novisa may transfer your personal data outside the European Economic Area – to a third country, to which the transfer of personal data will take place based on appropriate legal mechanisms such as relevant European Commission decisions, standard contractual clauses, or other similar legal instruments provided for in the GDPR.
2. Your data may be transferred to the United States, particularly via Google Analytics, which Novisa uses for website traffic analysis (“Google Analytics”). The transfer of data via Google Analytics involves the potential risk of access to your personal data by US special services (depending on Google Analytics settings, the scope of data may include IP address, identifiers used by Google Analytics such as Client ID, user session data, e.g., time spent on visited subpages). Data transfer to Google Analytics will always occur based on your consent (Article 6(1)(a) of the GDPR), which you can also express through your web browser’s cookie settings.
3. You have the right to obtain a copy of your personal data transferred to third countries at any time.

VI. Data Retention Period

Novisa will process your personal data:

1. for the purpose of conducting recruitment:
   • for the time necessary to conduct the recruitment process;
   • for 1 year from the date of expressing consent – in the case of expressing consent for data processing in future recruitments;
   • until the expiration of data retention obligations resulting from legal provisions – to the extent that data will be processed within the scope of fulfilling legal obligations;
2. for the purpose of concluding and performing agreements, including employment contracts:
   • until the termination or expiration of the agreement – this applies to data necessary for the proper performance of the agreement;
   • until the expiration of data retention obligations resulting from legal provisions – to the extent that data will be processed within the scope of fulfilling a legal obligation (e.g., tax regulations);
3. for the purpose of establishing, asserting, or defending against claims – until the expiration or statute of limitations of claims.

VII. Your Rights

When Novisa processes your data, you have the following rights – under the conditions specified in detail in the GDPR:

1. to obtain access to your data and receive copies thereof;
2. to request the immediate rectification (correction) of your data;
3. to request the erasure of your data (unless Novisa has legal grounds for further processing them);
4. to restriction of processing of your data, inter alia, in case of questioning the accuracy of such data – for a period allowing Novisa to verify the accuracy of such data;
5. to data portability – the right to receive personal data provided to Novisa based on your consent or agreement, in a structured, commonly used, machine-readable format, but only when such data is processed by Novisa in an automated manner (this does not apply to paper records); this right may be exercised by requesting the direct transmission of such data to another entity;
6. to lodge a complaint with the supervisory authority – to the President of the Personal Data Protection Office – if you believe that your data is being processed unlawfully;
7. to withdraw consent for the processing of personal data – this applies only to data that Novisa will process based on your granted consent, with the reservation that the withdrawal of consent will not affect the lawfulness of data processing prior to the withdrawal of consent.
   To exercise your rights, you may contact Novisa in one of the ways specified in point II.

VIII. Right to Object

You may at any time object to Novisa’s processing of your personal data for the purpose of realizing a legitimate interest (Article 6(1)(f) of the GDPR) by contacting Novisa in one of the ways specified in point II. Novisa will then no longer be able to process your personal data, unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or grounds for the establishment, exercise, or defense of legal claims.

IX. Information on the Requirement or Voluntariness of Data Provision and Consequences of Non-Provision

The provision of your personal data is voluntary and is not a contractual or statutory requirement, but it may be a necessary condition for concluding an agreement with Novisa and subsequently performing it correctly.

Marketing Information Clause

General Information Clause (marketing offers on the website)

I. Personal Data Controller

The controller of your personal data is Novisa Development sp. z o.o. (formerly: Novisa Development spółka z ograniczoną odpowiedzialnością sp. j.) (ul. Cieślewskich 53, 03-017 Warszawa), KRS: 0000973276, NIP: 7010044936, REGON: 140733062, share capital: 10,000,000.00 PLN (“Novisa”).

II. Data Protection Officer

For matters concerning personal data, you may contact the Data Protection Officer:

1. by phone: (22) 545 70 20;
2. by email at: [email protected];
3. in writing to: Novisa Development sp. z o.o., ul. Cieślewskich 53, 03-017 Warszawa.

III. Purposes and Legal Bases for Data Processing

Depending on the situation, Novisa may process your personal data for the following purposes and on the following legal bases:

1. for the purpose of conducting marketing:
   • realizing the legitimate interest of Novisa (i.e., pursuant to Article 6(1)(f) of the GDPR), which is to present Novisa’s offer in response to a client’s inquiry, submitted via electronic mail (e-mail), traditional mail, telephone, as well as through the website contact form, online chat, helpline, etc.;
   • based on your granted consent (i.e., pursuant to Article 6(1)(a) of the GDPR) to also present you with offers from Novisa’s partners, by contacting you at the phone number you provided (via SMS messages and voice calls) or by sending messages to the email address you provided;
2. for the purpose of establishing, asserting, or defending against claims – realizing the legitimate interest of Novisa (i.e., pursuant to Article 6(1)(f) of the GDPR) – by taking necessary actions if required, particularly actions concerning your personal data (e.g., responding to claims related to their processing);
3. for the purpose of fulfilling legal obligations incumbent upon Novisa (i.e., pursuant to Article 6(1)(c) of the GDPR), e.g., by providing or disclosing correspondence (which may contain personal data) to authorized public administration bodies to the necessary extent, among others, to enable these bodies to ensure Novisa’s compliance with generally applicable regulations.

IV. Categories of Data Recipients

Your personal data may be disclosed to the following categories of entities:

1. to entities authorized by law (courts, state authorities, etc.);
2. to subcontractors and other entities providing services to Novisa, including in particular entities providing IT, marketing, communication, legal, and debt collection services, and entities providing document destruction services;
3. to entities providing analytical services, including entities providing website statistics analysis services;
4. to companies affiliated with Novisa.
   In each case, the sharing of your personal data with the aforementioned recipients will only occur when it is necessary and based on appropriate authorization, a personal data processing entrustment agreement, or pursuant to applicable regulations, and with due observance of confidentiality and security requirements.

V. Transfer of Data Outside the European Economic Area

1. Novisa may transfer your personal data outside the European Economic Area – to a third country, to which the transfer of personal data will take place based on appropriate legal mechanisms such as relevant European Commission decisions, standard contractual clauses, or other similar legal instruments provided for in the GDPR.
2. Your data may be transferred to the United States, particularly via Google Analytics, which Novisa uses for website traffic analysis (“Google Analytics”). The transfer of data via Google Analytics involves the potential risk of access to your personal data by US special services (depending on Google Analytics settings, the scope of data may include IP address, identifiers used by Google Analytics such as Client ID, user session data, e.g., time spent on visited subpages). Data transfer to Google Analytics will always occur based on your consent (Article 6(1)(a) of the GDPR), which you can also express through your web browser’s cookie settings.
3. You have the right to obtain a copy of your personal data transferred to third countries at any time.

VI. Data Retention Period

Novisa will store your personal data:

1. for marketing purposes:
   a.) until the completion of correspondence related to the given offer inquiry or until data retention is no longer necessary for the realization of Novisa’s legitimate interests, or
   b.) until the withdrawal of consent for data processing for this purpose, but for no longer than 3 years;
2. for the purpose of establishing, asserting, or defending against claims or for the purpose of fulfilling legal obligations incumbent upon Novisa – until the expiration or statute of limitations of claims, respectively, or until the expiration of the legal obligation to retain data.

VII. Your Rights

When Novisa processes your personal data, you have the following rights – under the conditions specified in detail in the GDPR:

1. to obtain access to your data and receive copies thereof;
2. to request the immediate rectification (correction) of your data;
3. to request the erasure of your data (unless Novisa has legal grounds for further processing them);
4. to restriction of processing of your data, inter alia, in case of questioning the accuracy of such data – for a period allowing Novisa to verify the accuracy of such data;
5. the right to data portability – the right to receive personal data provided to Novisa, based on your consent or a contract, in a structured, commonly used, machine-readable format, but only when such data is processed by Novisa in an automated manner (this does not apply to paper records); this right may be exercised by instructing Novisa to transmit this data directly to another entity;
6. the right to lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office – if you believe that your data is being processed unlawfully;
7. the right to withdraw consent for the processing of personal data – this applies only to data that Novisa will process based on your consent, with the reservation that the withdrawal of consent will not affect the lawfulness of data processing prior to the withdrawal of consent.
   To exercise your rights, you may contact Novisa using one of the methods specified in point II.

VIII. Information on Profiling

Your personal data will not be processed by Novisa in an automated manner (including profiling) for the purpose of making decisions that produce legal effects concerning you or similarly significantly affect you.

IX. Right to Object

You may, at any time, object to Novisa’s processing of your personal data for the purpose of pursuing a legitimate interest (Article 6(1)(f) GDPR) by contacting Novisa using one of the methods specified in point II. In such a case, Novisa will no longer be able to process this personal data unless it demonstrates compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or grounds for the establishment, exercise, or defense of legal claims.

X. Information on the Requirement or Voluntariness of Providing Data and the Consequences of Non-Provision

The provision of your personal data is voluntary and is not a contractual or statutory requirement, but it may be necessary for corresponding with you or for obtaining information you expect regarding Novisa’s offer.

Cookie Information Clause

This clause refers to the use of cookies and pixel tags on the website https://www.novisa.pl/

I. Data Controller

The controller of your personal data is Novisa Development sp. z o.o. (formerly: Novisa Development spółka z ograniczoną odpowiedzialnością sp. j.) (ul. Cieślewskich 53, 03-017 Warszawa), KRS: 0000973276, NIP: 7010044936, REGON: 140733062, share capital: 10,000,000.00 PLN (“Novisa”).

II. What are Cookies

1. Use of the Website requires your acceptance of its use of pixel tags, as well as the placement of so-called cookies in your web browser. Cookies are small text files containing information used by websites that connect with your browser.
2. When using the Website, information from your browser is downloaded and stored, which may contain personal data.

III. Purpose and Legal Basis for Processing Personal Data in Connection with the Use of Cookies

1. Novisa primarily uses essential cookies to properly provide you with the services and functionalities of the Website that you wish to use. The legal basis for processing personal data in connection with the use of essential cookies is the necessity of processing for the performance of a contract (Article 6(1)(b) GDPR).
2. For other cookies, so-called “optional cookies” (statistical, analytical, functional, and advertising), the legal basis for processing personal data is your consent (Article 6(1)(a) GDPR). By managing cookie settings in your own browser, you can withdraw your consent at any time (see: point IV, sub-points 2 and 3 below).

IV. Cookie Activity Period

1. Files used on the Website may be:
   • temporary – they are automatically deleted after a specified expiry date;
   • persistent – they remain active in your browser until you delete them, which you can do at any time.
2. You have the right to use the options offered by every browser to view, delete, restrict, and control the acceptance of cookies. For additional information, you can consult the help content or privacy/security settings in your browser. However, deleting cookies may affect the proper functioning and features of the Website.
3. You can change the automatic settings for the most commonly used browsers according to the instructions found at the following addresses: Chrome; Edge; Firefox; Internet Explorer; Safari; or Opera.
4. Deleting or blocking certain cookies may affect the availability of Website functionalities, its correct display, and the loss of preferred Website settings.

V. Types of Cookies Used

Novisa uses the following types of cookies transmitted by your device:

1. essential – files ensuring the proper functioning of the Website, i.e., files storing your session and enabling and improving the Website’s operation;
2. statistical – files enabling the collection of Website statistics;
3. analytical – files enabling the acquisition of information such as the number of visits and traffic sources on the Website;
4. functional – files used to remember and adapt the Website to your choices, including language preferences;
5. advertising – files used in the case of running advertising campaigns to tailor advertisements to you and remember their settings.

VI. Transfer of Data Outside the European Economic Area

1. Novisa may transfer your personal data outside the European Economic Area – to a third country, to which the transfer of personal data will take place based on appropriate legal mechanisms such as relevant European Commission decisions, standard contractual clauses, or other similar legal instruments provided for in the GDPR.
2. If possible, we recommend that entities with whom we cooperate process your personal data within the European Union.
3. If Novisa uses the services of partners who are based in the United States or belong to a capital group with companies based in the United States, Novisa cannot rule out that American security services may gain access to your personal data, e.g., through remote access or a legally binding order. There is a risk that American security services may access your personal data without a specific reason, which may result in your inability to take effective legal action in the United States.
4. You have the right to obtain a copy of your personal data transferred to third countries at any time.

VII. Third Parties

1. Cookies and pixel tags may be used by third parties (e.g., Google, Facebook) to provide their own content or advertisements on websites or portals based on the records from these files and pixel tags.
2. Your data may be transferred to the United States, particularly via Google Analytics, which Novisa uses to analyze website traffic (“Google Analytics”). The transfer of data via Google Analytics involves the potential risk of United States special services gaining access to your personal data (depending on Google Analytics settings, the scope of data may include IP address, Client ID identifiers used by Google Analytics, user session data, e.g., time spent on visited subpages). Data transfer to Google Analytics will always take place based on your consent (Article 6(1)(a) GDPR), which you can also express through your browser’s cookie settings. Google Analytics will not collect data generated by cookies or data related to website use (including the user’s IP address), nor will it process this data if you download and install the browser plugin available here. More information on Google Analytics code and cookies can be found in the Google Analytics Security and Privacy Principles available here.