Personal data protection – AIDEN users

INFORMATION ON PERSONAL DATA PROTECTION for AIDEN users

In accordance with Article 13(1) 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 (the “GDPR”), we hereby provide the following information:

ABOUT AIDEN

Aiden is software that enables automated communication between residents and property managers via WhatsApp, email, and telephone, in multiple languages. Additionally, Aiden supports property managers in automating issue resolution to respond to inquiries more quickly and deliver higher quality service to residents.

The provider of the Aiden software on your behalf is the property manager, namely Leach & McGuire Sp. z o.o., with its registered office in Warsaw, ul. Kazimierza Brodzińskiego 27, 01-557 Warsaw (KRS 0000660114). For matters related to the functioning of the software and the processing of personal data by Leach & McGuire Sp. z o.o., please contact this entity directly.

As Aiden is used for communication regarding your lease agreement, we provide the following information concerning the processing of personal data by entities of the Van der Vorm group, with whom you have concluded a lease agreement.

Who is the Controller of Your Personal Data?

The controller of your personal data is:

  1. If you have entered into a lease agreement for premises at ul. Radzymińska in Warsaw – VAN DER VORM POLAND Sp. z o.o., based in Kraków, ul. Kącik 4, 30-549 Kraków, registered with the National Court Register maintained by the District Court for Kraków – Śródmieście in Kraków, XI Commercial Division of the National Court Register, KRS No. 0000637242, NIP: 5223071695, REGON: 365434419.
  2. If you have entered into a lease agreement for premises at ul. Siennicka in Warsaw – VAN DER VORM POLAND RESIDENTIAL 3 Sp. z o.o., based in Kraków, ul. Kącik 4, 30-549 Kraków, KRS No. 0001064551, REGON: 526711395, NIP: 6793280309.

You may contact the controller regarding personal data:

  • By post or in person at: ul. Kącik 4, 30-549 Kraków, or
  • By email: rodo@kwkr.pl

For What Purposes and on What Legal Basis Are Your Personal Data Processed?

Purpose of Processing Legal Basis
Execution and settlement of the lease agreement Necessity for the performance of a contract (Art. 6(1)(b) GDPR)
Responding to questions, reported issues, complaints, providing requested information, handling related communication Legitimate interest of the controller (Art. 6(1)(f) GDPR)
Archiving and creating data backups due to the controller’s legal obligation to protect data Legitimate interest of the controller (Art. 6(1)(f) GDPR)
Pursuing and defending legal claims in and out of court Legitimate interest of the controller (Art. 6(1)(f) GDPR)

What Categories of Personal Data Do We Process?

When contacting the Controller regarding the lease (including via Aiden), the following personal data may be processed:

  1. Identification and address data (e.g. salutation including gender, title, name, surname, address),
  2. Photos (e.g. WhatsApp profile picture),
  3. Contact details (e.g. email address, phone number),
  4. Lease agreement data (e.g. customer ID, lease agreement number),
  5. Utility usage data (e.g. energy and heat consumption),
  6. Communication data through various channels (phone, email, WhatsApp),
  7. Scheduling and availability information,
  8. Order details (e.g. delivery and billing address),
  9. Payment and invoicing data (including account information),
  10. Any other data provided during communication.

To Whom Do We Disclose Your Personal Data?

We exercise due diligence in selecting entities to which we disclose your data, requiring them to protect your data with appropriate technical and organizational measures. Your data may be disclosed to:

  1. Third parties providing services necessary to achieve the purposes for which we process your data (e.g. IT services, electronic communications, telecommunications, data hosting, property management, accounting, consulting, especially legal services),
  2. Recipients to whom disclosure is required by law or a court or authority order (e.g. tax office),
  3. Other recipients with your consent or where necessary to protect your or others’ vital interests.

How Long Will We Store Your Personal Data?

Your data will be processed for the duration necessary to perform and settle the lease agreement, including the period for asserting claims and retaining documentation as required by law. When data are processed based on the legitimate interests of the controller, we will process them no longer than until a valid objection is raised.

Do We Transfer Your Personal Data Outside the EEA?

We generally process your personal data within the European Economic Area (EEA), and our processors operate within the EEA. Should your data be transferred outside the EEA to countries that do not offer the same level of protection, we will ensure such transfer is based on a valid legal basis and appropriate safeguards.

Please note that when you use WhatsApp for communication, personal data is obtained from that service provider. We have no control over the type and scope of data processed by WhatsApp as a data controller, nor over the data’s use or transfer to third countries (particularly outside the EEA). For more information, please consult WhatsApp’s privacy policy: www.whatsapp.com/legal/

What Rights Do You Have in Relation to Your Personal Data?

You have the following rights, which you may exercise using the contact details provided in point 1:

  1. Right of access and to receive a copy – You can request access to your personal data at any time. One copy is free; we may charge a fee for additional copies.
  2. Right to rectification – You can request corrections to inaccurate or incomplete data.
  3. Right to data portability – You may request your data in a structured, commonly used, machine-readable format and request it be sent to another controller, where the processing is based on consent.
  4. Right to erasure and restriction of processing – You may request deletion or restriction of your data under the conditions specified by data protection laws. This right is not absolute.
  5. Right to object – You may object to further processing of your data where the legal basis is our legitimate interest unless we can demonstrate compelling legitimate grounds.
  6. Right to lodge a complaint with a supervisory authority – Generally, this will be the President of the Personal Data Protection Office in Poland.
  7. Right to withdraw consent – Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing before the withdrawal.

Will Your Data Be Subject to Automated Decision-Making?

No. You will not be subject to decisions based solely on automated processing, including profiling, that produces legal effects or similarly significantly affects you.

Is Providing Personal Data Mandatory?

Providing your data is generally voluntary. However, properly handling your inquiries or fully using Aiden for communication regarding your lease may only be possible if you provide the required data. Failure to do so may prevent processing your requests or the proper performance of the lease agreement.