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

1. Pursuant to Article 4 para. 7 of the 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 the Tenants or Users of the virtual office to contact and to execute the subject of the agreements executed with Memos sp. z o.o. is Memos sp. z o.o. with its registered office in Kraków at Mogilska 43, 31-545 Kraków, (hereinafter referred to as the “Company”).

2. In matters of data protection, you can contact by e-mail at lodz@wx-cowork.com , as well as by postal mail to the Company’s registered address.

3. 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) conclusion and execution of 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 execution of the subject matter of the agreement, which is the legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) RODO),

c) processing of complaints related to the concluded agreements (Article 6(1)(b) RODO),

d) processing and asserting claims, defending against claims, as well as for the purposes of implementing out-of-court dispute resolution, which is the Company’s legitimate interest (legal basis for data processing: Article 6(1)(f) RODO)

e) to conduct statistical analysis, which is a legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) RODO),

(f) implementation of legal requirements for tax and accounting regulations,

in particular those stipulated by the provisions of the Value Added Tax (VAT) Act of March 11, 2004, the Corporate Income Tax Act of February 15, 1992, and the Accounting Act of September 29, 1994 (legal basis for data processing: Article 6(1)(c) of the RODO),

g) storage of data for archiving purposes and for the purpose of demonstrating the correctness of fulfillment of legal obligations incumbent on the Company, which constitutes its legitimate interest (legal basis for data processing: Article 6(1)(f) RODO);

h) to conduct activities in the form of direct marketing, which constitutes the Company’s legitimate interest (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 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 telecommunications terminal equipment (e.g. telephone) and automatic calling systems – if a specific person has given 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 support (including the provision, implementation and maintenance of software and IT hardware service, hosting services and the like),

– law firms serving the Company, as well as entities providing debt collection services,

– consulting, auditing and advisory entities – within the scope of services performed by these entities for the Company.

5. Personal data shall 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 in addition:

a) until the statute of limitations for potential claims arising from the agreements indicated above,

b) for the time necessary to assert specific claims, in connection with the concluded agreements mentioned above,

c) for the period of performance of obligations under the law, including in particular tax and accounting regulations, such as obligations related to the retention of records as required by Article 74 of the Accounting Act of September 29, 1994,

d) for the period of time necessary for the Company to document before public administration authorities, including the supervisory authority in the field of personal data protection, the correctness of fulfillment of legal obligations incumbent on it,

e) for archiving purposes, when it concerns the history of correspondence conducted

and provided answers to reported inquiries – for a period not exceeding 2 years from the acquisition of the data

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 the moment of withdrawal of consent for this purpose or until the moment of ascertaining the obsolescence of data,

h) for the purpose of marketing communications with the use of telecommunications terminal equipment (e.g. telephone) and automatic calling systems – until the withdrawal of consent for this purpose or until the data becomes outdated.

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

8. In the case of processing of personal data by the Company for the purpose of pursuing legitimate interests (referred to above), we inform you of your right to object to the processing of 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 of processing of personal data on the basis of consent granted, we inform you

of the right to withdraw consent at any time without stating a reason, which, however, will not affect the compatibility of data processing that took place before the withdrawal of consent.[A4].

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

11. providing personal data for the purposes of:

(a) execution of the subject matter of the contract is a condition for the conclusion of the contract, and failure to provide the data may result in the inability to conclude the contract or the inability to properly perform the contract,

b) processing of complaints, investigation of possible claims is necessary for the Company to properly consider a possible complaint or investigation of claims,

c) for the purposes of the law is mandatory under the cited legal provisions,

d) in other cases is voluntary.