Information Policy on the Protection of Personal Data for Tenants, Virtual Office Users, and Their Representatives at Memos Ltd.
1. According to Article 4(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 “GDPR”), the data controller for personal data of individuals acting as:
· Tenants or Users of virtual office services entering into agreements with Memos Ltd. (individuals conducting sole proprietorship, individuals conducting business activities in the form of civil law partnerships),
· Representatives of Tenants or Users of virtual office services,
· Individuals designated by Tenants or Users of virtual office services for contact and for the implementation of agreements with Memos Ltd. is Memos Ltd., with its registered office at 9 Próżna Street, 00-107 Warsaw, Poland (hereinafter referred to as “the Company”).
2. For matters related to personal data protection, you can contact us via email at info@wx-cowork.com or by traditional mail to the Company’s registered office.
3. Personal data of individuals mentioned in point 1, depending on their role, may be processed for the following purposes and based on the following legal grounds:
a) Conclusion and performance of the agreement (legal basis for data processing: Article 6(1)(b) of the GDPR),
b) Conducting correspondence, including ongoing communication related to cooperation, conclusion and performance of the agreement, which constitutes the legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) of the GDPR),
c) Handling complaints related to concluded agreements (Article 6(1)(b) of the GDPR),
d) Handling and pursuing claims, defending against claims, as well as for the purpose of implementing out-of-court dispute resolution methods, which constitutes the legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) of the GDPR),
e) Conducting statistical analysis, which constitutes the legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) of the GDPR),
f) Fulfilling legal requirements regarding tax and accounting regulations, especially as specified by the 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) of the GDPR),
g) Storing data for archiving purposes and for demonstrating compliance with legal obligations imposed on the Company, which constitutes its legitimate interest (legal basis for data processing: Article 6(1)(f) of the GDPR),
h) Conducting direct marketing activities, which constitutes the legitimate interest of the Company (legal basis for data processing: Article 6(1)(f) of the GDPR),
i) Sending commercial information electronically (e.g., Newsletter) – if a specific individual has separately provided consent to receive commercial information electronically to the provided email address (legal basis for data processing: Article 6(1)(a) of the GDPR),
j) Conducting marketing communication using telecommunications end devices (e.g., telephone) and automatic calling systems – if a specific individual has separately provided consent to receive such information to the provided telephone number (legal basis for data processing: Article 6(1)(a) of the GDPR).
4. Personal data may be disclosed to the following entities:
· Entities supporting the Company in technical and IT services (including the delivery, implementation, and maintenance of software and IT hardware, hosting services, and similar services),
· Law firms providing legal services to the Company, as well as entities providing debt collection services,
· Consulting, auditing, and advisory entities – for the purposes of services provided to the Company by these entities.
5. Personal data will not be transferred by the Company outside the European Economic Area (EEA).
6. Personal data will be stored by the Company for the period necessary to establish cooperation, perform concluded agreements, and ensure their proper settlement, as well as:
a) Until the expiration of potential claims arising from the aforementioned agreements,
b) For the time necessary to pursue specific claims related to the aforementioned agreements,
c) For the duration of obligations resulting from legal regulations, in particular in the scope of tax and accounting regulations, e.g., obligations related to document retention in accordance with the requirements of Article 74 of the Accounting Act of 29 September 1994,
d) For the period necessary to document compliance with legal obligations by the Company before public administration authorities, including the supervisory authority in the field of personal data protection,
e) For archiving purposes, relating to the history of conducted correspondence and provided responses to inquiries – for a period not exceeding 2 years from the acquisition of the data,
f) For direct marketing purposes – until the objection to the processing of data is raised or until the data is determined to be outdated,
g) For sending commercial information electronically (e.g., Newsletter) – until the withdrawal of consent to carry out this purpose or until the data is determined to be outdated,
h) For marketing communication using telecommunications end devices (e.g., telephone) and automatic calling systems – until the withdrawal of consent to carry out this purpose or until the data is determined to be outdated.
7. The Company ensures the right to exercise the rights provided under the GDPR, including the right to request access to personal data, the right to rectification, erasure, or restriction of processing, the right to data portability, as well as the right to object to the processing of data, in accordance with the rules and conditions specified in the GDPR.
8. In case of processing personal data for the purposes of the legitimate interests of the Company (as mentioned above), we inform about the right to object to the processing of data for reasons related to the specific situation, as well as the right to object at any time in the case of processing data for direct marketing purposes.
9. In cases of processing personal data based on the provided consent, we inform about the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
10. We inform about the right to lodge a complaint regarding the processing of personal data with the supervisory authority, which is the President of the Personal Data Protection Office.
11. Providing personal data for the following purposes:
a) Fulfillment of the agreement is a condition for concluding the agreement, and failure to provide data may result in the inability to conclude or properly execute the agreement,
b) Handling complaints and pursuing potential claims is necessary to properly handle any complaints or pursue claims by the Company,
c) Compliance with legal requirements is mandatory based on the aforementioned legal provisions,
d) In other cases, it is voluntary.