Privacy Policy

1. Introduction

Kasama Investments Sp. z o.o. (“Kasama Investments”) can processes your personal data if: you visit our website and use our application; we provide you or the organization we know you through with our products or services; you visit our shopping centres or take part in our events or marketing campaigns. Kasama Investments pays close attention to the privacy security of your personal data and uses this data in lawful and responsible way in accordance with the privacy regulations.

In this Privacy Policy, we describe who we are, how and why we process your personal data, how you can execute your right to privacy, as well as we provide you with all necessary information that may concern you.

We do our best to provide you with all the information in an understandable way. If after reading the Privacy Policy you have any additional questions concerning the usage of your data, you can contact us using contact details below.

As we are constantly developing our products and services, we may change some of the method regarding processing of your personal data. We will make sure that these changes are reflected in this Privacy Policy. We would also like to encourage you to regularly check out the most recent modifications. At the end of this Privacy Policy, you will find information on the latest amendments to the document.

We are allowed to use cookies and similar technologies. More information about the usage of cookies can be found in Cookies Information section.

2. Who we are

Kasama Investments is a limited liability company and the owner of Magnolia Park shopping centre in Wrocław. Our headquarters is located on 1 Mokotowska Street, 00-640 Warszawa. You will find further information about Kasama Investments in “More information?” section below.

3. What kind of personal details the Privacy Policy applies to?

All your personal data which is collected, stored, shared, sent or used in a different way, in connection with Kasama Investments’ website, its applications, shopping centres, products and services in Poland, is covered by this Privacy Policy. It regards, among others, personal details (in any form) of our investors, candidates, business partners, lessees, customers who are provided with products and services by Kasama Investments, as well as suppliers, visitors and others.

4. What is personal data?

Personal data is any information about an identified or possible to identify living person, as well as individual data elements which when collected may lead to the identification of a certain person.

You give us your personal data if: you are our customers; we provide you with some products and service; you are visitors to our shopping centres; or you contact us on any other occasion.

5. Which of your personal data do we collect?

If you would like to come into contact with Kasama Investments or you have already done it, we are eligible to collect the following categories of your personal data:

  • Demographic data (name and surname, gender, date of birth, age, nationality, marital status and dependants)
  • Contact details (name and surname, post, address, place of residence, email address, telephone number)
  • Job application data (CV and cover letter)
  • Financial data (bank account details, credit number, credit card number)
  • Company data (address, commercial register number, tax identification number)
  • Account data (login and password)
  • Marketing preferences (whether you have agreed on direct marketing or not)
  • Interaction data (contact with our customer service, online or written correspondence)
  • Online identifier, browser and website traffic data (IP address, cookies, MAC address, your actions on our websites and apps, purchasing and localisation routine)
  • Participation data (participation in promotions, loyalty programmes, surveys, competitions or social and marketing events)
  • Security data necessary to prevent frauds (official identification, CCTV recordings)
  • Image data (pictures, video recordings)

6. How do we collect, receive or generate your personal data?

We can process the above listed categories of your personal data received directly from you, third party or through profiled and automated decision-making techniques in accordance with law.

Personal data concerning your person and collected directly from you

The following data is collected directly from you:

  • Personal data necessary to create an account, used in our apps, while entering into the contract, participation in promotions, loyalty programmes, social and marketing events, or other information which you transmit using Kasama Investments’ products or services;
  • Your online actions on our website as well as buying behaviour during the participation in our loyalty programmes;
  • Personal data you provide us as visitors to our shopping centres (it could be information about the traffic generated through Wi-Fi localisation);
  • Personal data which you or your organisation we know you through transfers while using our products or services; as well as
  • Personal data you transfer in correspondence while applying for a job, getting feedback, receiving help (questions and answers) and while dispute settlement;

Personal data we receive from the third parties

We can receive (additional) personal data, for example through the services provided by the third parties or social media websites in accordance with law. Limitations stated by the law may, for example, require your prior consent.

We receive your personal data from the following third parties:

  • Data from organizations, which we provide with our products and services (e.g. the owners of shopping malls);
  • Information about companies and their representatives included in the National Court Register (KRS);
  • Data from public sources such as industrial espionage agencies (companies specialised in creating credit profiles), register of insolvent entities (bankruptcy information, statutory debt-relief procedures), sanction lists, lists of Politically Exposed Persons, newspapers, the Internet or social media (Facebook, Instagram, YouTube, Google+ and Twitter); as well as
  • Data from different companies that received your consent on collecting and selling information about you.

Profiling techniques/automated decision making

We might also like to address you in a more adequate and personalized way. Your personal data needs to be analysed in order to make it possible and to establish the most adequate target groups, segment, contents, adds, information, moments and channels. Profiling techniques and automated decision-making processes will be applied by Kasama Investments only with your explicit consent. We will inform you about the principles connected with above mentioned techniques, as well as their consequences. Moreover, we take necessary actions to protect your rights and to ensure that the techniques will not legally or considerably affect you.

If you do not agree on the profiling of your personal data in order to offer you personalized marketing, please contact us using details from the section “More information?

7. Why do we process your personal data?

We collect and process your personal data for the following purposes:

1. singing contracts: signing and executing contracts with you and our other clients, lessees, suppliers and business partners;

2. communication, marketing (direct) and personalization: staying in touch, promotion and passing information about Kasama Investments’ products and services or functioning of other entities (marketing);

3. Quality and management: monitoring and upgrading our products and services;

4. Back office procedures: managing invoices and receiving payments;

5. Protection and safety: for safety reasons, accidents, insurance claims etc.; and

6. Law and regulations: ensuring compliance with law (e.g. in case of verification requirements) or court warrant, in which Kasama Investments is a party.

To be more precise, we process your personal data with the purpose of:

Contract execution

We process your personal data in order to prepare, enter into, execute and (alternatively) terminate the contract, e.g. leasing contract, shopping centre managing contract, purchase and sell contract etc. In order to do so, we need demographic data, contact details, company details and financial data.

Communication, marketing (direct) and personalization

  • Client-relationship management – your relationship with Kasama Investments is really important to us. That is why we pay close attention to ensure you that your personal data is correct and up to date. Managing relationships with clients consists of starting the contact and registration of your account as a client of Kasama Investments. The management also regards making your personal data more attainable for Kasama Investments in order to prepare business offers and send invoices to the right client. We collect your demographic, personal and company data in order to ensure that.
  • Customer service and support – We want to be able to help you as soon as you contact us in order to receive support or submit an additional application or complaint. It is the reason why we need to be able to process your personal data, i.e. making notes, registering reports and making phone calls between you and our employees. Information collected thanks to these procedures makes it easier for us to solve your problems/questions, as well as improve the quality of our services. Due to this reason, we collect your demographic, contact, company and financial data, as well as your applications and complaints.
  • Marketing and special offers – If you are already clients of Kasama Investments or you stated that you want to receive information about products and services of Kasama Investments, as well as other entities, we can put you on our mailing list, which is used to send newsletters, brochures and other information. In order to provide you with these (personalized) offers, we collect your demographic, contact and company data.
  • Participation in loyalty programmes – We can also process your personal data, if you indicated that you want to participate in loyalty programmes in order to receive personalized offers, and send feedback in the form of satisfaction survey or personal interests of a client. To do that, Kasama Investments collects your demographic, contact, financial data as well as account and participation details.

Quality and management

We process your personal data to monitor and upgrade the quality of our products, services, processes and systems, as well as give information to the management board of Kasama Investments and conduct internal audits. For example, Kasama Investments can use Wi-Fi networks to monitor traffic and flux of visitors, as well as assess performance of shopping centres managed by the company. For this reason, Kasama Investments collects data about interactions, online behaviour and visitor’s traffic.

Back office procedures

We process your personal data in order to manage our relationship with you and fulfil the requirements of contracts. For example, clients who did not pay required invoices receive a proper reminder. For this specific reason, we process the following personal data: demographic, contact, company, financial and account details.

Protection and safety

We process your personal data to ensure safety of visitors and also to prevent and detect crimes. For this sake, we are allowed to use Closed Circuit Television (“CCTV”) during your visits to Kasama Investments’ facilities, in accordance with the video register laws. CCTV system is well-designed and used selectively by Kasama Investments with the application of necessary precaution, in order to minimize inappropriate influence on your right to privacy. The information about CCTV monitoring is indicated graphically.

Law and regulations

We process your personal data to verify whether Kasama Investments can accept you as its client or business partner, to prevent fraud, carry out audits, obey the law (civil, criminal, administrative and tax law) and other regulations, as well as to take necessary legal actions in order to realise rights and duties on Kasama Investments side.

8. On what basis do we process your personal data?

In order to act in accordance with law, processing personal data for some purposes (stated above) must be based on appropriate legal basis [1]. Kasama Investments processes personal data based on the following legal basis:

(1) Execution of contract (for the provision of service)

We process your personal data which is necessary to execute contracts that we entered into with you. Without necessary personal data, Kasama Investments wouldn’t be able to fulfil the provisions from the contracts.

(2) Fulfilling legal obligation

As the law stands, Kasama Investments is obligated to process your personal data in order to fulfil the legal obligation.

(3) Our legally valid interest

Kasama Investments uses your personal data in realization of our legally valid interests, such as:

  • improving quality and effectiveness of services provided by Kasama Investments;
  • protecting interest of the visitors to the facilities managed/owned by Kasama Investments or its stakeholders;
  • detecting frauds and cases of safety infringements (e.g. on the website or at Kasama Investments’ shopping centres);
  • obeying the law.

(4) Your consent

If the three above-mentioned legal bases do not apply, Kasama Investments can process your personal data only with your prior and explicit consent. Please remember that you can always withdraw the consent. Moreover, note that the withdrawal is possible only when the consent was given and it does not have retroactive effect.

Kasama Investments processes your personal data if it is collected because of the above mentioned reasons based on the following legal bases:

PURPOSE LEGAL BASIS
Contract performance: entering into and executing the contract with you and other clients, suppliers or business partners. (1) Performing obligation stated in the contract (for the provision of service);

Communication, marketing (direct) and personalization: maintaining contact, promoting and giving information about product and services offered by Kasama Investments or about activity of other entities (marketing). (1) Performing obligation stated in the contract (for the provision of service);

(3) Legally valid interest of Kasama Investments;

(4) Your consent;

Quality and management: monitoring and upgrading products and services of Kasama Investments; (3) Legally valid interest of
Kasama Investments;

(4) Your consent;

Back office procedures: invoices and fees management;

(1) Performing obligation stated in the contract (for the provision of service);

(3) Legally valid interest of Kasama Investments;

Protection and safety: safety reasons, accidents, insurance claims etc.; (3) Legally valid interest of Kasama Investments;

Laws and regulations: obeying the law (e.g. verification requirements) or court warrants where Kasama Investments is a party.

(2) Fulfilling of legal obligation;

(3) Legally valid interest of Kasama Investments;

 

9. To whom do we pass on your personal data?

According to this Privacy Policy, we can pass on your personal data to third parties to the extend allowed by the law. Your personal data can be passed on to the following recipients:

Companies form the Group

We can pass on your Personal Data to other entities of Kasama Investments in order to provide you with information and services (such as registration, customer support), create new websites, applications, services, promotions and messages, as well as to prevent, track and investigate supposedly illegal actions, infringements of our guidelines, fraud or cases of safety violation of our data.

Authorities

We can pass on your personal data to supervisory organs such as taxation and customs administration, the police and other statutory institutions. We pass on your personal data in order to:

  • meet legal obligation, court warrant or binding laws; or
  • if it is necessary to prevent, investigate and procecute crimes; or
  • if it is necessary to meet our guidelines or to protect rights and freedom of other people;

Service companies (processing data)

While performing activities, we can make use of services of other service companies. These companies fulfil only our demands and are bound by the contract not to use your personal data for their own purposes.

Other

Every third party to whom we pass on, by your consent, your personal data (e.g. in the context of cooperation, freelance contracts (or service provision contract) or when they are or will be the part of our organisation as the result of restructuring, merge or purchase.

10. Is your personal data pass on outside of the European Union?

Your personal data is passed outside of the European Union. We took all necessary measures to ensure that the transfer is safe and in accordance with law.

Your personal data is transmitted to the following countries from outside of the European Union:

  • Turkey
  • Ukraine
  • the United States of America

In order to ensure the appropriate security level, we pass on your personal data only if it is covered with one of the following safety measures:

Decision on the appropriate security level

We are allowed to transmit your personal data outside of the European Union, on the basis of the so called ‘decision on the appropriate security level’. It is a decision by the European Commission, which states whether a certain country ensures the appropriate level of personal data security.

EU-USA Privacy Shield

Your personal data is passed on outside of the European Union only if its recipient or the processing entity guarantees the appropriate level of personal data safety, in compliance with the USA Privacy Shield framework.

Standard EU contract clauses and rule of law

Passing on (legally) personal data outside of the European Union is possible due to appropriate safety measures applied by us and data recipients or data processing entities. We implemented safety measures in question because of the rule of law applied by Kasama Investments and our standard personal data privacy clauses which are agreed on with all the entities processing personal data on our behalf.

11. How long do we store your personal data?

We store your personal data as for long as it is necessary to process it, or for as long as it is required by law. Your personal data will be deleted or made anonymous when the purpose for which it has been processed ceases, the consent to process personal data will be withdrawn or required period of its storage will elapse.

12. How can you execute your privacy rights?

You have a right to demand access to your personal data, and under certain conditions you can also correct or delete it. Moreover, you are allowed to: reduce your personal data processing, object to processing and transmitting your data.

In order to execute your right to access, correct or delete your personal data, and also the right to reduce or object to processing your data, you should contact us using contact details that can be found in “More information?” section below.

Please remember that we have the right to ask you for additional information necessary to verify your identity.

If you do not want to receive marketing information directly, you should contact us using contact details that ca be found in “More information?” section below.

All additional information, including how to object to profiling, can be found in the above-mentioned section on profiling techniques.

13. Can you submit a complaint?

Please submit all complains using contact details indicated in “More information?” section below. You can also file a complaint to appropriate supervisory organ handling personal data security. For example, you can file a complaint: when you think that we do not use your personal data with due caution, or if you are not satisfied with the received answer to your complaint regarding the access to your personal data or its correction, or the lack of answer in the due time.

14. More information?

If you have any additional questions about the way we process your personal data that haven’t been answered in this Privacy Policy, or you would like to execute your right to privacy as well as submit a complaint, please contact us using the contact details below:

MULTI POLAND SP. Z O.O. (Magnolia Park’s administrator)

Skylight Building,

Złota 59, 9th floor

00-120 Warszawa

Poland

Our Data Protection Officer: F.L.H. Gerards.

Phone number: +31 20 2588 100

Email: compliance@multi.eu

15. The date of the last modification of this Privacy Policy

This Privacy Policy has been in force since 25th May 2018. The last amendments were introduced on the 25th May 2018.