PRIVACY AND COOKIES POLICY
RONSON DEVELOPMENT MANAGEMENT SP. Z O.O.
AND RONSON GROUP COMPANIES

1. What does this policy describe?

This privacy policy ("Policy") provides information on the processing of personal data by Ronson Development Management sp. z o.o. and other companies within the Ronson Group, i.e., companies affiliated with Ronson Development SE based in Warsaw:

• It specifies the types of personal data we collect;
• It explains how and why we collect and use your personal data;
• It explains when and why we will share personal data with other entities; and
• It outlines your rights and choices regarding your personal data.

We want to make it clear whether this Policy also covers the rules for processing your personal data. The Policy applies if:

• You are a Candidate, i.e., participating in recruitment;
• You are a Potential Buyer of Property, i.e., using the website www.ronson.pl (the Website) and the forms contained on it, submitting inquiries through real estate portals, or contacting us regarding an offer in any way;
• You are a Buyer of Property, i.e., purchasing an apartment or property, or a Representative of a Buyer of Property, i.e., representing a Buyer of Property;
• You are a Contractor, i.e., providing us with any products or services, or a Representative of a Contractor, i.e., representing such an entity.

Your personal data will be processed in accordance with the General Data Protection Regulation of the European Union (2016/679) ("GDPR") and other applicable data protection laws that supplement and/or implement the GDPR.

2. Who is the controller of your personal data?

The controller of your data is Ronson Development Management sp. z o.o., based in Warsaw, at Al. Komisji Edukacji Narodowej 57, 02-797 Warsaw. If you are a Buyer of Property or a Representative of a Buyer, the controller of your data is also the Ronson Group company with which you enter into a development or property sale agreement (collectively referred to as "Admin," "Ronson," "we").

For matters related to the processing of personal data, you can contact us by mail or email.

To enhance the protection of personal data, we have appointed a Data Protection Officer. This role is filled by Paweł Latkowski. You can reach our DPO at the email address: iod@ronson.pl.

3. What information do we collect about you?

If you are a Candidate, we collect information contained in application documents, as well as information provided during interviews, email exchanges, and meetings. This includes, in particular, your first name, last name, contact details, information about your education, work experience, qualifications, language skills, and interests.

If you are a Potential Buyer of Property, we collect information provided through the forms on the Website and recorded during your use of the Website, as well as information provided through other forms of contact. This includes, in particular, your first name, last name, contact details such as email address or phone number, and IP address.
If you are a Buyer of Property or a Representative of a Buyer, we collect information provided in the documents you send us, during conversations, email exchanges, and meetings, including information necessary to conclude and execute the contract. This may include, in particular, your first name, last name, residential address, PESEL number, ID card number, and bank account number.

If you are a Contractor or a Representative of a Contractor, we collect information provided through contact forms, conversations, email exchanges, and meetings. This may include, in particular, your first name, last name, company address, NIP number, REGON number, contact details, position, information about the entity you represent, and data necessary to conclude a contract with that entity, if required. Your data may also be provided to us by the entity you represent, both before and during our collaboration.

4. For what purposes and on what basis do we process your data?

If you are a Candidate, we process your personal data:

1. Based on your consent (if it is a valid and effective basis for data processing) (Article 6(1)(a) GDPR) for purposes related to the recruitment process;
2. To fulfill legitimate interests of the data controller, such as internal administration, ensuring security, and handling legal claims (Article 6(1)(f) GDPR).

If you are a Potential Buyer of Property, we process your personal data:

1. Based on your consent (if it is a valid and effective basis for data processing) (Article 6(1)(a) GDPR) for purposes of direct marketing of our products and services, including those of entities within the Ronson Group;
2. To fulfill the legitimate interests of the data controller and other entities within the Ronson Group (Article 6(1)(f) GDPR), for example, in creating summaries, analyses, statistics, reports, market research, planning the development of offers or products, ensuring security, and where necessary for marketing activities not based on consent.

If you are a Buyer of Property or a Representative of a Buyer, we process your personal data:

1. To conclude and execute the contract (Article 6(1)(b) GDPR);
2. To fulfill legal obligations imposed on the data controller (Article 6(1)(c) GDPR);
3. To fulfill the legitimate interests of the data controller and other entities within the Ronson Group (Article 6(1)(f) GDPR), such as in relation to the conclusion and execution of the contract, handling claims, administrative, statistical, reporting purposes, and direct marketing of products and services of the data controller and Ronson Group companies.

If you are a Contractor or a Representative of a Contractor, we process your personal data:

1. To conclude and execute the contract (Article 6(1)(b) GDPR);
2. To fulfill legal obligations imposed on the data controller (Article 6(1)(c) GDPR);
3. To fulfill the legitimate interests of the data controller and other entities within the Ronson Group (Article 6(1)(f) GDPR), such as in relation to the conclusion and execution of the contract, handling claims, and for administrative, statistical, and reporting purposes.

5. To whom do we disclose your data?

When necessary to achieve the purposes for which we process your data, we may disclose it to:

1. Entities authorized to receive it under the law (e.g., law enforcement agencies, supervisory authorities, etc.);
2. Data processors acting on our behalf, i.e., companies providing specific services for us that involve data processing, such as subcontractors, entities managing our IT systems or providing IT tools, entities offering accounting, advisory, consulting, marketing, or recruitment services;
3. Other entities within the Ronson Group, to which we belong, i.e., entities affiliated with Ronson Development SE based in Warsaw.

6. How long do we keep your data?

We retain information about you for as long as necessary to fulfill the purposes outlined in this privacy policy and in accordance with our data retention policies (unless a longer period is required by applicable law). Our data retention policies are based on current legal regulations. We will retain and use information about you as necessary to meet legal requirements (e.g., if we are required to keep information for tax purposes), resolve disputes, execute contracts, reach settlements, or for the purposes specified in this privacy policy.

If you are a Candidate, we retain your data until the end of the recruitment process, and if you have consented to its processing for future recruitment processes, for up to the withdrawal of your consent.

If you are a Potential Buyer of Property, we retain your data as long as it is useful for marketing purposes, up to the withdrawal of your consent or objection to data processing.

If you are a Buyer of Property or a Representative of a Buyer, we retain your data as long as required by law and for the period specified by laws on the limitation of claims.

If you are a Contractor or a Representative of a Contractor, we retain your data as long as required by law and for the period specified by laws on the limitation of claims.

7. What rights do you have?

In exercising your rights related to personal data processing, you can make the following requests:

1. If we process your personal data based on your consent, you can withdraw that consent at any time. However, please note that withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
2. You can request access to your personal data and obtain a copy of it.
3. You can exercise the right to data portability, i.e., request that we provide your data in a structured, commonly used, and machine-readable format, and request that we send this data directly to another controller if we process it in an automated manner based on your prior consent.
4. You can request correction of your personal data if it is inaccurate or incomplete.
5. In relation to your particular situation, you can object to the processing of your personal data if we process it based on our legitimate interests. You can also object to the processing of your data for direct marketing purposes.
6. In cases specified by law, e.g., if your data is outdated, unnecessary, processed unlawfully, or if you have withdrawn your consent to its processing (when consent was the basis for such processing) or effectively objected to the processing of your personal data, you can request the deletion of your personal data.
7. You can also request the restriction of data processing while we address your objection or request regarding the accuracy of your data, the lawfulness of processing, or our legitimate interests, and if the data is needed to establish, pursue, or defend claims.

To exercise these rights, contact us by mail or email at marketing@ronson.pl. You may also contact our Data Protection Officer at iod@ronson.pl.

In any case where you believe that our processing of your personal data violates GDPR regulations, you also have the right to file a complaint with the President of the Personal Data Protection Office.

8. Do you have to provide us with your data?

If you are a Candidate, providing your data is entirely voluntary; however, without it, we will not be able to consider your application in the recruitment process.

If you are a Potential Buyer of Property, providing your data is entirely voluntary; however, without it, you will not be able to use the marketing contact form, receive an offer, or participate in other marketing activities.

If you are a Buyer of Property or a Representative of a Buyer, providing your data is necessary for concluding and maintaining the contractual and business relationship. If, as a Representative of a Buyer, you did not provide your data personally, it may have been provided by the entity you represent or obtained from publicly available sources.

If you are a Contractor or a Representative of a Contractor, providing your data is necessary for concluding and maintaining the contractual and business relationship. If, as a Representative of a Contractor, you did not provide your data personally, it may have been provided by the entity you represent or obtained from publicly available sources.

COOKIE POLICY

1. Cookies and Other Tracking Technologies: Definition

A "cookie" is a text file that a website sends to a visitor's computer or other internet-connected device to identify the visitor's browser or to store information or settings in the web browser. A cookie typically includes the domain name from which it was sent, the "lifetime" of the cookie, and a randomly generated unique identifier.

We may use other technologies, including web beacons and JavaScript, which in some cases work with cookies and other methods on our site to enable the identification of your device. These other technologies allow us to activate certain features on our site. We may also use specific technologies to determine if an email we sent was opened or if a link within it was clicked.

2. How We Use Cookies

While using our online services, both we and other parties (such as advertising networks) may collect information about users' web usage, including time spent on the web and visits to third-party sites.

We use cookies for various purposes. For example, we monitor the total number of visitors to our site on an anonymous and aggregated basis. We may also use cookies to remember you on subsequent visits to the site and to personalize the site according to your preferences. In this case, the cookie may be linked to certain information about you, which may constitute personal data.

Tracking technologies can be either persistent (i.e., the files remain on your computer or device until you delete them) or session-based (i.e., the files are kept only until you close your browser).

Our site uses the following types of cookies in particular:

• Necessary Cookies: These cookies are essential for providing services and ensuring the functionality you specifically request. We may use cookies and tracking technologies to prevent abuse, improve security, administer the system, or enable you to use payment processing functions. We are not required to obtain your consent for cookies that are necessary for their intended purpose.
• Performance and Analytics Cookies: We may use cookies to assess the performance of our site, including analytical activities aimed at improving the quality of the content provided through the site.
• Advertising Cookies: Both we and external advertisers may use cookies to present you with the most relevant products, offers, and advertisements. Advertising cookies allow us to show you promotional content tailored to your individual interests and preferences.

3. Cookie Settings and Removal

You can adjust your web browser settings to block cookies or to alert you each time a cookie is sent. However, keep in mind that completely blocking cookies may prevent you from using all the features of our website.

Below are links to resources showing how to manage cookie settings for popular web browsers:

• Firefox
• Chrome
• Internet Explorer
• Opera
• Safari

Alternatively, you can visit http://jakwylaczyccookie.pl/jak-wylaczyc-pliki-cookies/ for comprehensive information on disabling cookies in your browser or device, as well as general information about cookies. Information on deleting cookies from mobile phones can typically be found in the phone’s user manual. You can also opt out of receiving cookies.

Keep in mind that restricting cookies may affect the functionality of the website. Due to the variety of technological solutions, it is not possible to provide precise instructions for managing cookies on all available telecommunication devices and installed software. However, in most cases, you should look for the “Tools” or “Settings” option and locate the section for cookie management or privacy settings. Detailed instructions are usually provided by the device or browser manufacturer in their user manual or on their website.

4. Server Logs

Certain user behaviors are logged at the server level. This data is used solely for administering the service and ensuring efficient hosting service.

Resources accessed are identified by URL addresses. Additionally, the following information may be logged:

• The time of request arrival
• The time of response dispatch
• Client station name – identified by the HTTP protocol
• Information about errors occurring during HTTP transactions
• URL of the previously visited page (referrer link) – if the visit was through a link
• Information about the user’s browser
• IP address

This data is not linked to specific individuals visiting the site and is used solely for server administration purposes.