PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA AND YOUR RIGHTS
In case you are providing your personal data, we as a data controller
CHM 1 sp. z o.o., with its registered office in Warsaw, address: ul. Chmielna 71,00-801 Warsaw, entered
into the register of entrepreneurs of the National Court Register kept by the District Court for the capital
city of Warsaw in Warsaw, XIII Commercial Division of the National Court Register under the KRS
number 0000472864,
CHM 2 sp. z o.o., with its registered office in Warsaw, address: ul. Chmielna 71, 00-801 Warsaw,
entered into the register of entrepreneurs of the National Court Register kept by the District Court for
the capital city of Warsaw in Warsaw, XIII Commercial Division of the National Court Register under the
KRS number 0000468464,
Polcom Investment VI sp. z o.o., with its registered office in Warsaw, address: ul. Chmielna 71, 00-
801 Warsaw, entered into the register of entrepreneurs of the National Court Register kept by the District
Court for the capital city of Warsaw in Warsaw, XIII Commercial Division of the National Court Register
under the KRS number 0000393791,
(hereinafter reffered to as the HB Reavis or we), would like to inform you about the processing of
your personal data and of your rights related to the said processing.
HB Reavis is part of the HB Reavis Group, which consists of all entities consolidated under the group
holding HB Reavis Holding S.A. with its headquarters in Luxembourg due to which the reference to HB
Reavis Group may be found in the Privacy Notice
This notice applies to current and former employees, tenants, visitors and contractors. This notice does
not form part of any contract of employment or other contract to provide services. This Privacy Notice
may be updated from time to time. We encourage you to periodically review this Privacy Notice for the
latest information on our privacy practices. Your continued use of our services after the posting of
changes to this Privacy Notice will mean that you accept those changes.
It is important that you read and retain this notice, together with any other privacy notice we may provide
on specific occasions when we are collecting or processing personal information about you, so that you
are aware of how and why we are using that information and what your rights are under the data
protection legislation.
If you are in our construction site or building, in their immediate vicinity (as a visitor, employee, contractors and subcontractor or their employees or for any other purpose) or visit websites or social media related to our building, your personal data may be processed for the following purposes:
1. Ensuring the safety of visitors and contractors working at the construction site and property
What is our purpose for and legitimate interest in processing your personal data?
The protection of our buildings and the safety of the people entering the construction site are the key
elements and the number one priority in our business activities. For us to be able to ensure the proper
level of protection and safety, we installed a video monitoring system (CCTV). When entering the
construction site the CCTV might record you. If you enter the construction site we will process your
personal data to produce your visual images by means of an installed CCTV camera system, which
records the construction site area and part of the area outside the construction site.
What is our legal basis for the processing of your personal data?
We process your personal data based on the legitimate interests under Article 6 (1) (f) of GDPR for
the protection of our rights and interests and for ensuring security at our premises.
What kind of personal data do we process?
A visual image of you.
How long do we store your personal data?
We store your personal data captured by cameras located at the construction site for 15 days.
2. Administration of control days
What is our purpose for and legitimate interest in processing your personal data?
At most of our constructions, we organize regular control days, which serve for many purposes
including marketing, safety, administration and others. People attending these control days are
mostly journalists, politicians, state or local controllers, general public and internal stakeholders.
From each control day a control day report is created which contains personal data of the persons
involved.
What is our legal basis for the processing of your personal data?
We process your personal data on the basis of legitimate interests under Article 6 (1) (f) of GDPR.
What kind of personal data do we process?
Name, surname, phone number and e-mail.
How long do we store your personal data?
As soon as we no longer need your personal data for the processing purposes for which the
personal data have been collected, we will delete them unless the statute-barred period applies.
3. Administration of construction visitors
What is our purpose for and legitimate interest in processing your personal data?
There are many visitors to our construction site on daily basis. Each visitor must be put into evidence
so we can ensure the safety at our construction site and protect the people and the property.
What is our legal basis for the processing of your personal data?
We process your personal data on the basis of legitimate interests under Article 6 (1) (f) of GDPR.
What kind of personal data do we process?
Name, surname, phone number and e-mail.
How long do we store your personal data?
As soon as we no longer need your personal data for the processing purposes for which the
personal data have been collected, we will delete them unless the statute-barred period applies.
4. Administration of suppliers phone book
What is our purpose for and legitimate interest in processing your personal data?
As we have numerous contractors working at our construction site, we need to keep contact details
to ensure effective communication. For this purpose, we have created a phone book filled with
contact details of all contractors that had worked at any of our previous constructions/fit out or that
are working for any of our present constructions/fit out.
What is our legal basis for the processing of your personal data?
We process your personal data on the basis of legitimate interests under Article 6 (1) (f) of GDPR.
What kind of personal data do we process?
Name, surname, phone number, e-mail and contact details of the contractor
How long do we store your personal data?
We store your personal until you unsubscribe from our database / or until the contact is relevant to
us.
5. Administration of proposals from suppliers
What is our purpose for and legitimate interest in processing your personal data?
The process of administration of proposals from suppliers is a critical, structured phase within the
procurement life cycle and it is an integral part of every fit-out or construction project. Its primary
function is to manage all aspects of supplier submissions (often in response to an RFP, RFQ, or
RFT) from the moment they are received until the preferred supplier is selected and negotiations
begin.
This process ensures fairness, transparency, and objective evaluation, typically involving the
following key steps: (i) Sending of requests for proposals to potential suppliers; (ii) Receipt of
proposals from potential suppliers; (iii) Comparison of proposals; (iv) Selection of suppliers.
What is our legal basis for the processing of your personal data?
We process your personal data based on the legitimate interests under Article 6 (1) (f) of GDPR for
ensuring the procurement process.
What kind of personal data do we process?
Name and surname , E-mail , Phone number , Company
How long do we store your personal data?
We store your personal data 7 years from the end of a calendar year when a particular interaction
took place.
6. Hand-over of the fit-out project
What is our purpose for and legitimate interest in processing your personal data?
The handover process for a Fit-out project is the final, crucial phase that formally transfers the
completed space from HB Reavis to the tenant. It is a highly structured procedure designed to ensure
all contractual and regulatory obligations are met, and the tenant is fully equipped to operate and
maintain the new space.
The process is typically divided into three main stages: (i) Hand-over of the fit-out project to the
tenant; (ii) Creation of hand-over protocol; (iii) Signing and archivation of the hand-over protocol.
What is our legal basis for the processing of your personal data?
We process your personal data based on the legitimate interests under Article 6 (1) (f) of GDPR for
the protection of our rights and interests.
What kind of personal data do we process?
Name and surname, Company, Job position
How long do we store your personal data?
We store your personal data 7 years from the end of a calendar year when the last interaction based
on a particular contractual relationship took place
7. Management of health and safety at construction/Fit out sites
What is our purpose for and legitimate interest in processing your personal data?
Training of persons with access to the construction site in the area of health and safety. Evidence of
all persons with access to the construction site and their health and safety trainings. Creation of a
daily report with evidence of all constructions workers for purposes of health and and safety.
Documentation of health and safety violations and accidents.Creation of incident logs from incidents
that resulted in injuries or property damage during the course of construction. Identification of the
aggrieved person. Reporting of this incident to the responsible departments and insurance
companies.
What is our legal basis for the processing of your personal data?
We process your personal data based on the legitimate interests under Article 6 (1) (f) of GDPR for
the protection of our rights and interests and under Article 6 (1) (c) processing is necessary for
compliance with legal obligation to which HB Reavis is a subject
What kind of personal data do we process?
Name and surname, Date of birth, Photograph, Work permit, Construction qualification
How long do we store your personal data?
We store your personal data 10 years.
General provisions
Once we no longer need your personal data for the purposes for which we processed it, we will delete
your personal data or archive it for the period of time specified by law or the archiving plan.
With whom do we share your personal data?
We may also share your personal data with companies within the HB Reavis Group. We may also be
obliged to disclose your personal data to state authorities and public authorities, (courts and law
enforcement authorities i.e. (police and prosecutor), and only to the extent necessary as required by
applicable and effective law to exercise their power.
Based on several agreements with third parties, which act as our intermediaries or independent
operators, we may provide your personal data, to these companies, to the extent necessary to ensure
the provision of services specified for individual companies. In addition to these companies, we use the
following categories of intermediaries: data centres, hosting – marketing tools – analysis and tracking
tools – business operations / management tools – task management and communication tools.
From whom do we get the personal data?
We get the personal data from you, your employer or third party.
Do we use automated individual decision-making?
No, we do not use automated individual decision-making.
Do we transfer your personal data to third countries?
Your personal data are processed within the territory of Poland and other states of the European Union.
Your personal data can be processed by a country outside of European Union if this third country has
been confirmed by the European Commission as a country with adequate level of data protection or if
other appropriate data protection safeguards exist (for example, binding corporate privacy rules or EU
standard data protection clauses).
What are your rights?
Your rights as a data subject are stated below. Please note that the exact conditions to exercise these
rights are set out in detail in Chapter III of GDPR, while in a particular circumstance not all rights may
be exercised. You have following rights:
How can you exercise your rights?
Electronically: dataprivacy@hbreavis.com
In writing to the address: Polcom Investment VI sp. z o.o., ul. Chmielna 71 00-801 Warsaw, Poland, at
hands of legal department or at HB Reavis Group a.s., at hands of compliance department Mlynské nivy
5, 821 09 Bratislava, Slovak Republic.
We strive to protect your privacy as much as possible and therefore we process your personal data in
compliance with GDPR and all other relevant laws. However, if you disagree with the way we handle
your personal data, you can exercise your rights via our Data Protection Officer at: HB Reavis Group a.
s., Mlynské nivy 5, 821 09 Bratislava, Slovak Republic, email: dataprivacy@hbreavis.com
Or you can file a complaint in supervising authority regarding the processing of your personal data. Your
local supervisory authority may be found at: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm