Information 

TWJ Sp. z o.o. with its registered office in Żory for entities cooperating with and sending correspondence to the company

(RODO information clause) 

Dear Sirs,  

TWJ Sp. z o.o. with its registered office in Żory, which manages AdriatiCoast Holiday Apartments, presents below information on the principles of processing personal data of persons cooperating with TWJ Sp. z o.o., in particular persons concluding agreements with TWJ Sp. z o.o. within the scope of their business activity, persons acting on behalf of business entities which are not natural persons and which conclude agreements with TWJ Sp. z o.o., persons contacting TWJ Sp. z o.o. in connection with the intention to establish cooperation or designated to be contacted in connection with the performance of the aforementioned agreements, as well as persons addressing correspondence to TWJ Sp. z o.o.. 

Pursuant to Articles 13(1)-(2) and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (General Data Protection Regulation) (Official Journal of the EU L 119, p. 1) - hereafter: "RODO" - we inform you that: 

I. Personal data controller 

The controller of the personal data is TWJ Sp. z o.o. with its registered office in Żory, NIP: 646 265 11 43 (hereinafter also as: "Administrator"). 

Administrator's contact details: TWJ Sp. z o.o. ul. Sąsiedzka 10 44-240 Żory Tel: +48 513 104 056

Email: office@adriaticoast.com     

For matters concerning personal data, please contact us at the above-mentioned e-mail address.

II. Aims and basis of processing

When processing personal data, the Controller may invoke one or more of the following legal bases, depending on the circumstances: 

1. Article 6(1)(b) RODO - processing of data for the purpose of concluding and performing a contract, or for taking appropriate steps at the request of the data subject prior to the conclusion of a contract, 
2. Article 6(1)(f) RODO - processing of data to the extent necessary for the cooperation or performance of the concluded contract, in order to realise the legitimate interest of the Administrator in facilitating the cooperation or performance of the contract, as well as to the extent necessary to establish and assert possible claims or to defend against claims related in particular to the concluded contract, 
3. Article 6(1)(c) RODO - processing of data to the extent necessary for the Administrator to fulfil his/her obligation to keep records of concluded contracts, in order to fulfil the Administrator's legal obligation under the relevant legislation, 
4. Article 6(1)(b) or (c) RODO - processing of data to the extent necessary to respond to enquiries, requests and applications addressed to the Administrator in relation to the Administrator's business and to conduct further correspondence in this regard, 
5. Article 6(1)(f) of the DPA - processing of data comprising the image as part of the monitoring in the public areas of the Administrator's premises for the purpose of ensuring the security of persons and property, 
6. Article 6(1)(a) RODO - processing may also be based on the consent given by the data subject, in all those cases where such consent is required for the processing of personal data.

III. Data retention period 

1. In the case of personal data processed in connection with the conclusion and performance of a contract, the Administrator will process the personal data for the time necessary for the performance of that contract and will keep the personal data for the period required by the legal provisions on compulsory archiving and the time necessary for the settlement of any mutual claims (until the claim is time-barred or the dispute is concluded). 
2. If the conclusion of a contract is not reached within the period for which the offer was made or through negotiations, bargaining, etc., the personal data obtained in the course of negotiations, bargaining, pre-contractual discussions will be processed until it is useful for mutual contacts. 
3. Data processed in connection with ongoing correspondence will be processed for the period of usefulness for mutual contacts or for the time necessary to defend against claims, if the correspondence concerns claims made against the Administrator.
4. The data comprising the image captured by the monitoring is automatically overwritten and stored for a period of up to 3 months, after which it is deleted, subject to situations requiring investigations due to incidents of violation of the security of persons and property. For such exceptional situations, the processing of the surveillance data will take place according to the circumstances and legal requirements. 
5. Where processing is based on consent, data will be stored until consent to processing is withdrawn, unless it becomes unnecessary for the purpose for which it was processed sooner.

IV. Recipients of the data 

The anticipated recipients of the personal data are: 

1. employees and associates of the Controller who are authorised to process personal data in connection with the performance of their duties, 
2. the Administrator's external service providers to the extent necessary for the fulfilment of the purposes set out in point II., i.e. in particular entities providing legal services, accounting services, consultancy services, postal and courier companies (in connection with the handling of correspondence), providers of technical and organisational services (in particular providers and entities specialised in the provision of technical support for ICT systems),
3. entities authorised by law.

V. Rights of data subjects 

Individuals whose data is processed by the Controller have the following rights: 

1. The right of access to the content of their data and the right to rectify inaccurate data,
2. the right to supplement incomplete data, 
3. The right to delete data - after the expiry of the legally required retention period, 
4. The right to restrict processing and the right to data portability - where justified, 
5. The right to object to the processing, where the basis for the processing is the legitimate interest of the Controller (Article 6(1)(f) RODO), 
6. the right to withdraw consent to processing, where processing is based on consent, where the withdrawal of consent does not affect the lawfulness of processing until consent is withdrawn, 
7. The right to lodge a complaint with the supervisory authority (President of the Office for Personal Data Protection).

VI. Information on data requirements/voluntariness 

The provision of personal data in connection with the conclusion of a contract is voluntary, but necessary for the conclusion and performance of the contract with the Administrator. 

The provision of personal data in connection with correspondence is voluntary, but failure to provide data necessary for a response will preclude a response. 

VII. Automated decision-making 

The controller does not make decisions by automated means (without human involvement). Personal data will also not be used for profiling without prior consent. 

VIII. Transfer of personal data to a third country or international organisation 

The controller does not transfer personal data to recipients located outside the European Economic Area (countries of the European Union and Iceland, Norway and Liechtenstein).

IX. Minimisation of the scope of personal data 

The Controller shall take adequate measures to limit the personal data that he processes to only those personal data that are necessary for the purposes indicated in this notice. In particular, the Administrator processes the following data: 

-in the case of natural persons concluding contracts with the Controller in the framework of the

business activity - name, company name, address, NIP, bank account number, 

-in the case of natural persons who are representatives, agents or contact persons for the performance of a contract concluded with the Controller - name and surname, position held, if any, and contact details: e-mail address, telephone number,

-in the case of natural persons corresponding/contacting the Administrator- name, contact details (address or e-mail address), identity card or passport number, telephone number if applicable.

X. Remarks

In the event of difficulties of interpretation, the Polish text of this trilingual document is binding.