Information policy on personal data protection for Tenants, Users of the virtual office and persons representing them Memos sp. z o. o.

1. In accordance with Article 4 para. 7 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter referred to as “RODO”), the controller of personal data of persons acting as:

Tenants or Users of the virtual office who are parties to contracts concluded with Memos sp. z o.o. (natural persons conducting so-called sole proprietorship, natural persons conducting business in the form of civil law companies),
persons representing tenants or users of the virtual office,
persons indicated by tenants or users of the virtual office for contact and for the performance of the subject of contracts executed with Memos sp. z o.o. is Memos sp. z o.o. with its registered office in Kraków at ul. Mogilska 43, 31-545 Kraków, (hereinafter referred to as the “Company”).

2. In matters concerning personal data protection, you can contact by e-mail at info@wx-cowork.com, as well as by post at the address of the Company’s registered office.

3. The personal data of the persons indicated in point 1, depending on the role performed by them, may be processed for the following purposes and on the following legal grounds:

a) to conclude and perform the subject matter of the contract (legal basis for data processing: Article 6(1)(b) RODO),
b) to conduct correspondence, including ongoing communication related to the establishment of cooperation, conclusion and performance of the subject matter of the contract, which constitutes the legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) RODO),
c) to handle complaints related to concluded contracts (Article 6(1)(b) RODO),
d) to consider and assert claims, to defend against claims, and for the purposes of pursuing out-of-court dispute resolution, which is a legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) RODO),
e) to carry out statistical analyses, which is a legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) RODO),
f) to comply with legal requirements in terms of tax and accounting regulations, in particular those stipulated by the provisions of the Value Added Tax (VAT) Act of 11 March 2004, the Corporate Income Tax Act of 15 February 1992 and the Accounting Act of 29 September 1994 (legal basis for data processing: Article 6(1)(c) RODO),
g) to store data for archiving purposes and for the purpose of demonstrating the correctness of the fulfilment of the legal obligations incumbent on the Company, which constitutes its legitimate interest (legal basis for data processing: Article 6(1)(f) RODO);
h) to carry out activities in the form of direct marketing, which is a legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) RODO),
i) to send commercial information by electronic means (e.g. Newsletter) – if a specific person has given a separate consent to receive commercial information by electronic means to the indicated e-mail address (legal basis for data processing: Article 6(1)(a) RODO),
j) for marketing communications with the use of telecommunication terminal equipment (e.g. telephone) and automatic calling systems – if a specific person has given a separate consent to receive this type of information to a designated telephone number (legal basis for data processing: Article 6(1)(a) RODO).

4. Personal data may be disclosed to the following entities:

  • entities supporting the Company in the field of technical and IT services (including the provision, implementation and maintenance of software and IT hardware services, hosting services and the like),
  • law firms servicing the Company, as well as entities providing debt collection services,
  • consulting, auditing and advisory entities – to the extent of services provided by these entities to the Company. 5.

5. Personal data will not be transferred by the Company outside the European Economic Area (EEA).

6. Personal data will be retained by the Company for the period necessary for the establishment of cooperation, execution of concluded agreements and until their proper settlement, and furthermore:

a) until the statute of limitations for potential claims arising from the contracts indicated above,
b) for the time necessary for the assertion of specific claims, in connection with the concluded contracts referred to above,
c) for the time necessary to fulfil obligations arising from the provisions of law, including in particular tax and accounting regulations, e.g. obligations related to the retention of records as required by Article 74 of the Accounting Act of 29 September 1994,
d) for the period of time necessary for the Company to document before the public administration authorities, including the supervisory authority for the protection of personal data, the correctness of the fulfillment of the legal obligations incumbent upon it,
e) for archiving purposes, where this concerns the history of correspondence conducted and provided answers to the reported enquiries – for the period not longer than 2 years from the data collection,
f) for direct marketing purposes – until you object to the processing of your data or until your data becomes obsolete,
g) for the purpose of sending commercial information by electronic means (e.g. Newsletter) – until you withdraw your consent to this purpose or until your data becomes obsolete,
h) for marketing communications with the use of telecommunication terminal equipment (e.g. telephone) and automatic calling systems – until you withdraw your consent for this purpose or until your data becomes obsolete.

7. The Company shall ensure the right to exercise the rights provided for under the RODO, i.e. the right to request access to one’s personal data, the right to rectify, erase or request restriction of processing, the right to data portability, as well as the right to object to their processing, on the principles and in the cases provided for in the RODO provisions.

8. In the case of the processing of personal data by the Company for the purpose of pursuing legitimate interests (as referred to above), we inform you of your right to object to the processing of your data on grounds related to your particular situation, and furthermore of your right to object at any time in the case of processing for direct marketing purposes.

9. In cases where personal data are processed on the basis of consent given, we inform you of the right to withdraw consent at any time without giving any reason, which will not, however, affect the compatibility of the processing that took place before the withdrawal of consent[A4].

10. We inform you of your right to lodge a complaint in relation to the processing of your personal data with the supervisory authority, which is the President of the Office for Personal Data Protection.

11. The provision of personal data for the purposes of:

a) the performance of the subject matter of the contract is a condition for the conclusion of the contract, and failure to provide data may result in the impossibility of concluding the contract or the impossibility of its proper performance,
b) the handling of complaints, the assertion of possible claims is necessary for the Company to properly consider a possible complaint or assertion of claims,
c) for the purposes of the law, it is obligatory on the basis of the quoted legal provisions,
d) in other cases it is voluntary.

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