1. This Privacy Policy sets out the rules for the processing of personal data obtained through the Coldwell Banker Residential website (hereinafter referred to as the ‘Website’).
2. Właścicielem Serwisu Internetowego i jednocześnie administratorem danych jest Coldwell Banker Residential SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ z siedzibą w Warszawie (00-124), Rondo ONZ 1, wpisana do rejestru przedsiębiorców Krajowego Rejestru Sądowego prowadzonego przez Sąd Rejonowy dla m.st. Warszawy w Warszawie, XII Wydział Gospodarczy Krajowego Rejestru Sądowego pod numerem KRS 0000680678, o kapitale zakładowym 5.000 PLN, NIP 5252713392, REGON 36743404000000, zwana dalej Coldwell Banker Residential sp. z o.o.
3. Personal data collected by Coldwell Banker Residential sp. z o.o. via the Website is processed in accordance with 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 (General Data Protection Regulation), also known as the GDPR.
4. Coldwell Banker Commercial sp. z o.o. takes special care to respect the privacy of Users visiting the Website.
§ 1 Type of data processed, purposes and legal basis
1. Coldwell Banker Residential sp. z o.o. collects information about natural persons performing legal transactions not directly related to their business activities, natural persons conducting business or professional activities on their own behalf, and natural persons representing legal persons or organisational units that are not legal persons but are granted legal capacity by law, hereinafter collectively referred to as Users.
2. Users’ personal data is collected in the following cases:
a) using the contact form service on the Website in order to perform a contract provided electronically. Legal basis: necessary for the performance of the contract for the provision of the contact form service (Article 6(1)(b) of the GDPR);
b) use of the post a review service for the performance of a contract for the provision of electronic services. Legal basis – necessary for the performance of the contract for the provision of the post a review service (Article 6(1)(b) of the GDPR).
3. In the case of Entrepreneurs, the above scope of data is additionally extended to include:
a) Entrepreneur’s company;
b) tax identification number (NIP).
4. When using the contact form service, the User provides the following data:
a) e-mail address;
b) first name and surname;
c) telephone number.
5. When using the review service, the User provides the following information:
a) e-mail address;
b) first name.
6. When using the Website, additional information may be collected, in particular: the IP address assigned to the User’s computer or the external IP address of the Internet provider, domain name, browser type, access time, operating system type.
7. Navigation data may also be collected from Users, including information about links and references they decide to click on or other activities undertaken on the Website. Legal basis – legitimate interest (Article 6(1)(f) of the GDPR), consisting in facilitating the use of services provided electronically and improving the functionality of those services.
8. For the purpose of establishing, pursuing and enforcing claims, certain personal data provided by the User when using the functionality of the Website may be processed, such as: first name, surname, data concerning the use of services, if the claims result from the manner in which the User uses the services, other data necessary to prove the existence of a claim, including the extent of the damage suffered. Legal basis – legitimate interest (Article 6(1)(f) of the GDPR), consisting in the establishment, investigation and enforcement of claims and defence against claims in proceedings before courts and other state authorities.
9. The transfer of personal data to Coldwell Banker Residential sp. z o.o. is voluntary.
§ 2 Who is the data disclosed or entrusted to, and how long is it stored?
1. The User’s personal data is transferred to service providers used by Coldwell Banker Residential sp. z o.o. in the operation of the Website. Depending on contractual arrangements and circumstances, service providers to whom personal data is transferred are either subject to Coldwell Banker Residential sp. z o.o.’s instructions regarding the purposes and methods of processing such data (processors), or independently determine the purposes and methods of processing (controllers).
a) Processors. Coldwell Banker Residential sp. z o.o. uses suppliers who process personal data solely on the instructions of Coldwell Banker Residential sp. z o.o. These include, among others, providers of hosting services, accounting services, marketing systems, systems for analysing traffic on the Website, and systems for analysing the effectiveness of marketing campaigns.
b) Administrators Coldwell Banker Residential sp. z o.o. uses suppliers who do not act solely on its instructions and who determine the purposes and means of using Users’ personal data themselves. They provide electronic payment and banking services.
2. Location. Service providers are mainly based in Poland and other countries of the European Economic Area (EEA). Some of the providers are based outside the EEA. In connection with the transfer of data outside the EEA, the Controller has ensured that the providers provide guarantees of a high level of personal data protection. These guarantees result in particular from the obligation to apply standard contractual clauses adopted by the Commission or participation in the Privacy Shield programme established by Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of the protection provided by the EU-US Privacy Shield.
3. Users’ personal data is stored:
a) Where the basis for the processing of personal data is consent, the User’s personal data shall be processed by Coldwell Banker Residential sp. z o.o. until such consent is revoked, and after revocation of consent, for a period corresponding to the limitation period for claims that may be raised by Coldwell Banker Residential sp. z o.o. and which may be raised against it. Unless a specific provision provides otherwise, the limitation period is six years, and for claims for periodic benefits and claims related to business activity – three years.
b) If the basis for data processing is the performance of a contract, the User’s personal data is processed by Coldwell Banker Residential sp. z o.o. for as long as it is necessary to perform the contract, and after that time for a period corresponding to the limitation period for claims. Unless otherwise provided by a specific provision, the limitation period is six years, and for claims for periodic benefits and claims related to business activities – three years.
4. Navigation data may be used to provide Users with better service, analyse statistical data, tailor the Website to Users’ preferences, and administer the Website.
5. In the event of a request, Coldwell Banker Residential sp. z o.o. shall disclose personal data to authorised state authorities, in particular to organisational units of the Public Prosecutor’s Office, the Police, the President of the Personal Data Protection Office, the President of the Office of Competition and Consumer Protection or the President of the Office of Electronic Communications.
§ 3 Cookies mechanism, IP address
1. The Website uses small files called cookies. They are saved by Coldwell Banker Residential sp. z o.o. on the end device of the person visiting the Website, if the web browser allows it. A cookie usually contains the name of the domain from which it originates, its ‘expiry time’ and an individual, randomly selected number identifying the file. The information collected using these types of files helps Coldwell Banker Residential sp. z o.o. tailor its products to the individual preferences and actual needs of visitors to the Website. They also enable the compilation of general statistics on visits to the products presented on the Website.
2. Coldwell Banker Residential sp. z o.o. uses two types of cookies:
a) Session cookies: after the end of a given browser session or after turning off the computer, the stored information is deleted from the device’s memory. The session cookie mechanism does not allow the collection of any personal data or confidential information from Users’ computers.
b) Persistent cookies: these are stored in the memory of the User’s end device and remain there until they are deleted or expire. The persistent cookie mechanism does not allow any personal data or confidential information to be downloaded from the User’s computer.
3. Coldwell Banker Residential sp. z o.o. uses its own cookies for the following purposes:
a) analyses and research, as well as audience audits, in particular to create anonymous statistics that help understand how Users use the Website, which enables improving its structure and content.
4. Coldwell Banker Residential sp. z o.o. uses external cookies for the following purposes:
a) promoting the Website via Instagram (external cookie administrator: Instagram LLC. based in the USA);
b) promoting the Website via the social networking site facebook.com, including: displaying advertisements; creating interest profiles for the purpose of displaying advertisements; displaying advertisements tailored to user profiles; optimising the Administrator’s services, portals, websites and applications; creating interest profiles based on user behaviour within the services, portals, websites and applications operated by the Administrators or based on data collected by the Administrator (external cookie administrator: Facebook Inc. based in the USA or Facebook Ireland based in Ireland);
c) promoting the website via LinkedIn.com social media (external cookie administrator: LinkedIn Ireland Limited, based in Ireland);
d) collecting general and anonymous statistical data via Gemius Traffic analytical tools, including: for the purpose of statistical measurements, Trusted Partners place special codes on end devices that enable the collection of data used to compile statistics and optimise our services (external cookie administrator: Gemius S.A. with its registered office in Warsaw);
e) presenting multimedia content on the Website’s pages, which is downloaded from an external website www.youtube.com (external cookie administrator: Google Inc. based in the USA);
f) collecting general and anonymous statistical data via Google Analytics analytical tools, including: for the purpose of statistical measurements, Trusted Partners place special codes on end devices that enable the collection of data used to compile statistics and optimise our services (external cookie administrator Google LLC based in the USA);
g) researching the behaviour of visitors to the Website using the Hotjar tool, including: optimising the services, portals, websites and applications operated by the Administrator by recording data on user behaviour such as navigation, scrolling, cursor movement and creating interest profiles based on user behaviour within the services, portals, websites and applications operated by the Administrator or based on data collected by the Administrator (external cookie administrator: Hotjar Ltd. based in Malta);
h) presentation of the Reliable Terms and Conditions Certificate via the rzetelnyregulamin.pl website (external cookie administrator: Rzetelna Grupa sp. z o.o. with its registered office in Warsaw).
5. The cookie mechanism is safe for the computers of Website Users. In particular, it is not possible for viruses or other unwanted software or malware to enter Users’ computers in this way. Nevertheless, Users have the option of restricting or disabling access to cookies on their computers in their browsers. If this option is used, it will still be possible to use the Website, except for functions that by their nature require cookies.
6. Below we present how you can change the settings of popular web browsers regarding the use of cookies:
a) Chrome and Chrome Mobile browsers;
b) Facebook in-app browser;
c) Internet Explorer browser;
d) Microsoft EDGE browser;
e) przeglądarka Mozilla Firefox;
f) Opera browser;
g) Safari and Safari Mobile browsers;
h) Samsung Browser.
7. Coldwell Banker Residential sp. z o.o. may collect Users’ IP addresses. An IP address is a number assigned to a visitor’s computer by their internet service provider. The IP number enables access to the Internet. In most cases, it is assigned to a computer dynamically, i.e. it changes with each connection to the Internet. The IP address is used by Coldwell Banker Residential sp. z o.o. to diagnose technical problems with the server, create statistical analyses (e.g. to determine which regions generate the most visits), as information useful for administering and improving the Website, as well as for security purposes and the possible identification of unwanted automatic programmes for browsing the content of the Website that burden the server.
8. The Website contains links and references to other websites. Coldwell Banker Residential sp. z o.o. is not responsible for the privacy policies applicable to those websites.
§ 4 Rights of data subjects
1. Right to withdraw consent – legal basis: Article 7(3) of the GDPR.
a) The user has the right to withdraw any consent given to Coldwell Banker Residential Limited Liability Company.
b) Withdrawal of consent takes effect from the moment consent is withdrawn.
c) Withdrawal of consent does not affect processing carried out by Coldwell Banker Residential sp. z o.o. in accordance with the law prior to its withdrawal.
d) Withdrawal of consent does not entail any negative consequences for the User, but may prevent further use of services or functionalities which, in accordance with the law, Coldwell Banker Residential sp. z o.o. may only provide with consent.
2. Right to object to data processing – legal basis: Article 21 of the GDPR.
a) The user has the right to object at any time, on grounds relating to his or her particular situation, to the processing of his or her personal data, including profiling, if Coldwell Banker Residential sp. z o.o. processes his or her data on the basis of a legitimate interest, e.g. marketing of Coldwell Banker Residential sp. z o.o. products and services, keeping statistics on the use of individual functionalities of the Website and facilitating the use of the Website, as well as conducting satisfaction surveys.
b) Opting out of receiving marketing communications about products or services by email will mean that the User objects to the processing of their personal data, including profiling for these purposes.
c) If the User’s objection proves justified and Coldwell Banker Residential sp. z o.o. has no other legal basis for processing personal data, the User’s personal data will be deleted, the processing of which the User has objected to.
3. Right to erasure (‘right to be forgotten’) – legal basis: Article 17 of the GDPR.
a) The user has the right to request the deletion of all or some personal data.
b) The user has the right to request the deletion of personal data if:
a. the personal data is no longer necessary for the purposes for which it was collected or processed;
b. withdrew specific consent, to the extent that personal data was processed on the basis of his or her consent;
c. objected to the use of his data for marketing purposes;
d. personal data is being processed unlawfully;
e. personal data must be erased for compliance with a legal obligation in Union or Member State law to which Coldwell Banker Residential sp. z o.o. is subject;
f. personal data has been collected in connection with the provision of information society services.
c) Despite a request to delete personal data, in connection with an objection or withdrawal of consent, Coldwell Banker Residential sp. z o.o. may retain certain personal data to the extent that processing is necessary to establish, investigate or defend claims, as well as to comply with a legal obligation requiring processing under Union law or the law of a Member State to which Coldwell Banker Residential sp. z o.o. is subject. This applies in particular to personal data including: first name, surname, e-mail address, which are retained for the purpose of handling complaints and claims related to the use of Coldwell Banker Residential sp. z o.o. services, or additionally the address of residence/correspondence address, order number, which are retained for the purpose of handling complaints and claims related to concluded sales contracts or the provision of services.
4. Right to restrict data processing – legal basis: Article 18 of the GDPR.
a) The user has the right to request the restriction of the processing of their personal data. Until the request is considered, it prevents the use of certain functionalities or services, the use of which will involve the processing of data covered by the request. Coldwell Banker Residential sp. z o.o. will also not send any communications, including marketing communications.
b) The user has the right to request the restriction of the use of personal data in the following cases:
a. if they question the accuracy of their personal data – in which case Coldwell Banker Residential sp. z o.o. will restrict its use for the time necessary to verify the accuracy of the data, but for no longer than 7 days;
b. when the processing of data is unlawful and, instead of erasure, the User requests restriction of use;
c. when personal data is no longer necessary for the purposes for which it was collected or used, but is needed by the User to establish, pursue or defend legal claims;
d. when he/she has objected to the use of his/her data – in this case, the restriction applies for the time necessary to consider whether, due to the specific situation, the protection of the User’s interests, rights and freedoms outweighs the interests pursued by the Controller in processing the User’s personal data.
5. Right of access to data – legal basis: Article 15 of the GDPR.
a) Użytkownik ma prawo uzyskać od Administratora potwierdzenie, czy przetwarza dane osobowe, a jeżeli ma to miejsce, Użytkownik ma prawo:
a. access your personal data;
b. obtain information about the purposes of processing, categories of personal data being processed, recipients or categories of recipients of such data, the planned period of storage of the User’s data or the criteria for determining that period (when it is not possible to specify the planned period of data processing), about the rights of the User under the GDPR and the right to lodge a complaint with a supervisory authority, about the source of the data, about automated decision-making, including profiling, and about the safeguards applied in connection with the transfer of the data outside the European Union;
c. obtain a copy of your personal data.
6. Right to rectification – legal basis: Article 16 of the GDPR.
a) The User has the right to request the Administrator to immediately rectify any personal data concerning him/her that is incorrect. Taking into account the purposes of processing, the User whose data is concerned has the right to request the completion of incomplete personal data, including by submitting an additional statement, by sending a request to the e-mail address in accordance with §6 of the Privacy Policy.
7. Right to data portability – legal basis: Article 20 of the GDPR.
a) The User has the right to receive their personal data that they have provided to the Administrator and then send it to another personal data administrator of their choice. The User also has the right to request that the personal data be sent by the Administrator directly to such an administrator, if technically possible. In such a case, the Administrator will send the User’s personal data in the form of a csv file, which is a commonly used format, suitable for machine reading and allowing the received data to be sent to another personal data administrator.
8. If the User exercises their rights under the above provisions, Coldwell Banker Residential sp. z o.o. shall comply with the request or refuse to comply with it immediately, but no later than within one month of receiving it. However, if, due to the complex nature of the request or the number of requests, Coldwell Banker Residential sp. z o.o. is unable to comply with the request within one month, it shall comply with it within the next two months, informing the User in advance, within one month of receiving the request, of the intended extension of the deadline and the reasons for it.
9. The user may submit complaints, enquiries and requests to the Administrator concerning the processing of their personal data and the exercise of their rights.
10. The user has the right to request Coldwell Banker Residential sp. z o.o. to provide a copy of the standard contractual clauses by sending an enquiry in the manner specified in §6 of the Privacy Policy.
11. The user has the right to lodge a complaint with the President of the Personal Data Protection Office regarding the violation of their rights to personal data protection or other rights granted under the GDPR.
§ 5 Services tailored to preferences and interests (profiling)
1. Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
2. Users’ personal data may be processed in an automated manner (profiling), but this will not have any legal effects on them or similarly significantly affect the situation of Users.
3. The profiling of personal data by Coldwell Banker Residential sp. z o.o. consists in the automated and manual processing of Users’ data, using it to evaluate certain information about the User, in particular to analyse or predict their personal preferences and interests.
4. In order to reach the User with marketing messages outside the Website, Coldwell Banker Residential sp. z o.o. uses the services of external providers. These services consist of displaying marketing messages on websites other than the Website. For this purpose, external providers install, for example, an appropriate code or pixel to collect information about the User’s activity on the Website. Details on the cookies used can be found in §3. Legal basis – legitimate interest (Article 6(1)(f) of the GDPR), consisting in tailoring marketing messages to preferences and interests.
5. In order to reach the User with marketing messages via the Website, Coldwell Banker Residential sp. z o.o. uses the services of external providers. These services consist of displaying marketing messages on the Website. For this purpose, external providers install, for example, an appropriate code or pixel to collect information about the User’s activity on the Website. Details on the cookies used can be found in §3. Legal basis – legitimate interest (Article 6(1)(f) of the GDPR), consisting in tailoring marketing messages to preferences and interests.
§ 6 Amendments to the Privacy Policy
1. The Privacy Policy may be subject to change, of which Coldwell Banker Residential sp. z o.o. will inform Users 7 days in advance.
2. Please direct any questions regarding the Privacy Policy to: biuro@coldwellbanker.pl
3. Date of last modification: 26 January 2026.
