Privacy policy

This Privacy Policy is intended to help you understand what data we collect, for what purpose, and how we use it. This information is important, so please read this document carefully.

When using the services (hereinafter collectively the “Services” or “Services of Circle REI sp. z o.o.”, and individually a “Service”), you entrust Circle REI sp. z o.o. with your information.

For the purposes of this Privacy Policy, Circle REI sp. z o.o. (hereinafter: “Circle REI”) means Circle REI sp. z o.o. with its registered office in Warsaw and all related and dependent entities (personally and financially), directly or indirectly through other entities (hereinafter: “Subsidiaries”).

It may also happen that you entrust this information to our trusted partners, i.e., third parties operating within the environment of our Services. We cooperate with them to provide Services at the highest level, as well as to conduct marketing activities, including entities that directly or indirectly commission us to conduct marketing activities within the environment of our Services (hereinafter: “Clients”).

What data do we process?

We process data that you provide, leave behind, or to which we can gain access in connection with your use of the Services, Circle REI websites or applications, websites and applications of our Trusted Partners, and other locations on the Internet, including data resulting from your browsing of websites and applications.

We process data necessary to provide you with accounts or profiles on the Services, e.g.: e-mail address, first name, last name, age, gender, city, date of birth—provided by you, e.g. via forms or windows available in our Services, as well as surveys, questionnaires, or research.

We also process data that you leave while navigating our Services (including data stored in cookies), data about visited websites, applications and content that interests you (including advertisements), your searches, your clicks, how you use our Services, as well as data from the websites of our Clients and Trusted Partners, including your purchase history—especially purchases made after clicking advertisements delivered to you within the environment of our Services.

We process data about your activity within the services, portals, websites and applications of Circle REI, our Trusted Partners and other locations on the Internet, as well as information stored on the end devices you use, including browser information and data about your precise geographic location.

We process your personal data stored, among others, in cookie files installed on our websites and applications, as well as on the websites of our Trusted Partners and in other locations on the Internet, i.e., outside the services, portals and websites of Circle REI. Information on the processing of personal data in such locations can be found at the relevant link.

Targeting and profiling

The advertisements and editorial materials displayed to you will be targeted and profiled using your data.

Targeting is the process of selecting an audience most interested in a given editorial or advertising material.
Profiling is the automated processing of your data consisting of using your data to evaluate certain factors specific to you, in particular to analyze or forecast your interests or other behavior, e.g. online reliability, location, movement, consumer preferences, worldview, or profession.

The displayed advertisements and editorial materials will be targeted and profiled using, in particular, the following data and criteria:

  • your activity within the services, portals, websites and applications of Circle REI and our Trusted Partners, including the editorial materials you use;

  • your activity and interactions with advertising materials;

  • your location and the size of the city you come from;

  • information stored on your end devices, in particular: device type, browser type, operating system, and the language settings of the operating system.

Information about your profile may be used to profile advertisements and content in the services, portals, websites and applications of Circle REI and our Trusted Partners, as well as in other locations on the Internet, i.e. outside the services, portals and websites of Circle REI.

This particularly applies to advertising networks that collect and broker advertising. Such networks may collect data about users from all websites cooperating with these networks and then use it to display advertisements best suited to you.

Why do we process your data?

Processing of the data you provide, leave behind, or to which we can gain access in connection with your use of the Services, websites or Circle REI applications is necessary for us to provide Services by electronic means—particularly due to the need to tailor content to your interests and to enable you to use our Services safely and optimally.

We also process data that you enter into Services provided by us under the so-called “Hosting” model—in such cases, our processing is limited to providing you with virtual space in which you place data yourself using the IT tools available in our Services.

The scope of data processed in individual Circle REI Services may vary. Information in this regard can be found in the panel associated with a given Circle REI Service. You may also contact our Data Protection Officer (contact details below).

What rights do you have?

You have the following rights in connection with the processing of your personal data by us:

  • the right to access your data, including obtaining a copy;

  • the right to request rectification of data;

  • the right to delete data (in certain situations);

  • the right to lodge a complaint with the supervisory authority responsible for personal data protection;

  • the right to restrict processing.

If your data is processed on the basis of consent, you additionally have:

  • the right to withdraw consent to the extent your data is processed on that basis. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Consent is voluntary. You may grant consent using the functionality of the consent-management platform and withdraw it at any time using the advanced settings of that platform.

Circle REI enables you to give and withdraw consent using a platform registered and verified by IAB. Our Transparency & Consent Framework registration number is 72.

If your data is processed on the basis of consent or as part of a provided service (i.e., the data is necessary to provide the service), you additionally have:

  • the right to data portability, i.e. to receive your personal data from the controller in a structured, commonly used, machine-readable format and to transmit it to another controller.

If your data is processed on the basis of the legitimate interest of the controller, you additionally have:

  • the right to object to processing for reasons related to your particular situation.

After an effective objection, your data will no longer be processed unless there are valid legally justified grounds for processing overriding your interests, rights and freedoms, or grounds for establishing, pursuing, or defending claims. Your data will not be processed for direct marketing purposes after an objection is raised.

If your data is processed based on the legitimate interest of Circle REI, you may object by contacting the Data Protection Officer:

Correspondence address: Circle REI sp. z o.o., Trakt Lubelski 155B, Warszawa 04-766
E-mail: kontakt@circlerei.pl

To exercise the rights described above, please contact the controller or the Data Protection Officer using the details above.

Cookies and similar technologies

Circle REI and Trusted Partners place information in the form of cookies (so-called “cookies”) and other similar technologies on end devices (e.g. computer, laptop, smartphone, Smart TV) and gain access to information collected using cookies and other device-identifying technologies.

Cookies are IT data, in particular text files, stored on the end device of the user of the Services, including portals and websites or applications. Cookies typically contain the name of the domain they originate from, the storage time on the end device, and a unique identifier. Cookies store information often necessary for the proper functioning of a website. Cookies may store a unique number identifying the user’s device; however, the user’s identity is not determined on this basis.

A website may place a cookie in the browser if the browser allows it. Importantly, the browser allows a website to access only cookies placed by that website and not cookies placed by other websites.