kontakt@5s.com.pl
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Bellevue Jelenia Góra
Hotel Szklarska
Nowoczesny pokój hotelowy w Elements Hotel & SPA w Świeradowie-Zdroju z szarą kanapą, telewizorem na ścianie i wyjściem na balkon.

Privacy Policy

In this Privacy Policy, you will find information about:

  • the principles governing the processing and protection of personal data by the data controller, including the information obligation;
  • the principles governing the provision of services by electronic means through the [5S Invest website];
  • the terms and conditions governing the use of the [5S Invest website].

This Privacy Policy is made available free of charge on the [5S Invest website] in a form that allows Users to save, store and reproduce its contents free of charge.

Information Obligation

  1. Data Controller
    The controller of your personal data processed through the website [5S Invest] is 5S Invest spółka z ograniczoną odpowiedzialnością, with its registered office in Warsaw (02-674), at 15 Marynarska Street, entered in the National Court Register (KRS) maintained by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS number 0001165294 (hereinafter referred to as the “Company” or the “Controller”). The Company places particular importance on the protection of personal data. Accordingly, all data of Portal users (hereinafter referred to as “Users” or a “User”) processed through the Portal is processed in accordance with the personal data protection laws applicable in the Republic of Poland. When processing your personal data, the Company fulfils its obligations under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter the “GDPR”), as well as applicable national laws. Access to personal data is granted exclusively to employees and other persons acting on behalf of the Company who have been authorised to process personal data and have undertaken to maintain confidentiality. As the Company operates within a group of undertakings within the meaning of Article 4(19) of the GDPR, your personal data may, where necessary, be processed for purposes determined by the group of undertakings. Such processing constitutes a legitimate interest of the Company within the meaning of Article 6(1)(f) of the GDPR. The Controller may use artificial intelligence tools to support data analysis, prepare reports and improve organisational processes. These tools are used solely in a supporting capacity and are not used to make automated decisions concerning you that produce legal effects or similarly significantly affect your rights or obligations.
  2. Contact
    If you have any questions or concerns regarding this Privacy Policy or the protection of your personal data, you may contact the Company, in particular, at the registered office address indicated above. You may also contact the Company regarding any matters related to the processing of your personal data, including for the purpose of exercising your rights, at: administratordanych@5s.com.pl.
  3. Purposes and Legal Bases for Processing Your Personal Data
    The Company processes your personal data for, among other things, the following purposes:
  • responding to your enquiries, including enabling contact regarding your interest in establishing cooperation, taking steps prior to entering into a contract, or performing an existing contract;
  • taking the necessary steps to enter into and perform a contract, including conducting commercial negotiations;
  • providing information about offers to purchase apartments or information about other investment projects and apartment sales offers, subject to obtaining your prior consent;
  • marketing the Company’s own products and services, as well as making them available to other entities within the group, subject to obtaining your prior consent;
  • sending newsletters to the email address provided by you;delivering personalised and targeted advertisements and online offers through social media platforms.
  • Depending on the purpose of processing, the legal basis for processing your personal data is:
    a) Article 6(1)(a) of the GDPR – the consent of the data subject (e.g. for receiving newsletters);
    b) Article 6(1)(b) of the GDPR – processing is necessary for the performance of a contract to which the data subject is a party (e.g. contact in connection with an interest in establishing cooperation and performing the contract);
    c) Article 6(1)(c) of the GDPR – processing is necessary for compliance with a legal obligation to which the Controller is subject;
    d) Article 6(1)(f) of the GDPR – processing is necessary for the purposes of the legitimate interests pursued by the Controller (e.g. marketing activities carried out through contact forms on the website and Meta and Google instant forms).
  • Contact Form
    The Portal provides a contact form service that allows the User to provide the Controller with their personal data, including contact details, in order to initiate contact with the Controller and receive an offer from the Controller or an entity affiliated with the Controller. The User may provide only an email address or a telephone number. The User may choose whether they wish to receive, at the provided email address or telephone number, only offers from the Controller or also commercial information about investments offered by companies belonging to the same group, by selecting the relevant checkboxes.
    The User should read the information on the processing of personal data by the Company, which is available via the link included in the statement accompanying each checkbox (this Privacy Policy). Selecting at least the first checkbox is required to initiate contact.
    The Company contacts the User for marketing purposes, including to present offers and commercial information, where the User has provided their email address or telephone number for this purpose and clicked the “Send” button. Until the “Send” button is clicked, the User may discontinue use of the form by leaving the Portal website or the subpage on which the form is located. Until that point, the User may also amend any information previously entered in the form.
    To enable contact via the form, the User must provide their first name and selected contact details. Providing an email address is necessary for email correspondence or receiving offers by email, while providing a telephone number is necessary for telephone contact or receiving information about offers by phone.
    Failure to provide these details will make it impossible for the Company to contact the User by email or telephone, as applicable.
    The legal basis for processing personal data for the above purpose is the legitimate interest pursued by the Controller, pursuant to Article 6(1)(f) of the GDPR.
  • Contact: Email Correspondence
    The Company provides, among other things, contact details on the Portal that enable Users to contact it by electronic means of communication, including email.
    Contact may be initiated by clicking on a hyperlink on the Portal containing the Company’s email address, which may automatically redirect the User to their email application. Using this form of contact requires the disclosure of personal data necessary for the Company to respond to the User, in particular their email address. Failure to provide an email address will make it impossible for the Company to process the User’s enquiry. The User may also voluntarily provide other information for the purpose of identification, facilitating contact or handling the enquiry. The Company processes personal data on the same basis when you contact the Company by email by sending a message directly from your email account to the Company’s email address.
    The legal basis for processing personal data is the legitimate interest pursued by the Company, as referred to in Article 6(1)(f) of the GDPR, namely conducting correspondence with you. The Company processes personal data for the purpose of handling the correspondence received.
    Depending on the content of the message received from you, your personal data may also be processed for other purposes, such as taking steps prior to entering into a contract or entering into and performing a contract [Article 6(1)(b) of the GDPR].
    As a rule, personal data will be processed for as long as the purpose for which the correspondence is conducted continues to exist, unless another legal basis for processing applies, and also until the expiry of the applicable limitation period for claims or until you object to the processing of your personal data.
  • Telephone Contact
    You may contact the Company by telephone. The Company’s contact details are provided, among other places, on the Portal. The Company will request personal data from you during a telephone conversation only where this is necessary for the purpose of the call, including for the purpose of verifying your identity.
    Telephone calls may be recorded, in which case you will be informed of this each time before the conversation with a representative of the Company begins. You may refuse to have the call recorded. If you do not consent to the recording, you should terminate the call. Telephone calls are recorded for the purpose of monitoring the quality of services provided by the Company and for the purpose of defending against or pursuing claims, which constitutes the legitimate interest pursued by the Company referred to in Article 6(1)(f) of the GDPR.
    Providing personal data is generally voluntary, but the Company may require certain data depending on the purpose for which it is provided.
    Failure to provide personal data may, in such cases, make it impossible to fulfil your purpose, e.g. to obtain information about an individual offer.
    Personal data obtained in this manner will be processed in accordance with the principles applicable to the specific purpose of processing arising from the telephone conversation, and in any event no longer than until the expiry of the applicable limitation period for claims.
  • Social media
    The Portal contains links to external websites, including the Facebook social networking platform ([Facebook Privacy Policy]) and Instagram ([Instagram Privacy Policy]), where the Company operates its profiles (so-called fan pages). The Company also operates a profile on LinkedIn ([LinkedIn Privacy Policy]) and a YouTube channel ([Google Privacy Policy]). Personal data processed through social media platforms is administered by third parties. The processing of your personal data by these entities is governed by the laws applicable to the controller of the relevant service and by its internal regulations (e.g. the privacy policies referred to above). This Privacy Policy does not govern the processing of personal data by such entities. However, the Company may also act as an independent controller of personal data processed in connection with the operation of the Company’s fan pages, processing personal data on the following terms. The Company processes personal data on its fan pages on social media platforms for purposes constituting the Company’s legitimate interests [Article 6(1)(f) of the GDPR], namely:
  • for marketing purposes, including informing Users about the Company and its services through the fan page, including by sharing posts;
  • to respond to private messages sent using the social media platform’s functionality;
  • to conduct discussions in posts published on the fan page, within the social media platform or on websites that enable discussions using accounts created on the relevant social media platform;
  • to obtain and analyse statistical data – the Company may obtain from the social media platform operator statistical data concerning the fan page. Such data is generated based on the monitoring of your activity on the fan page by the operator of the relevant social media platform;
  • through the Company’s LinkedIn profile, occasionally for the purpose of responding to job applications (in which case the legal basis for processing is Article 6(1)(b) and (c) of the GDPR);
  • when subscribing to the Company’s YouTube channel (in which case the Company processes your personal data for the purpose of entering into and performing the subscription agreement, pursuant to Article 6(1)(b) of the GDPR).
    Providing personal data is voluntary. In the event of any form of communication with the Company through the above-mentioned social media platforms, the Company will automatically receive the data indicated in your account profile, such as your first name, surname or username, as well as your profile picture and other publicly available information. You may stop following the Company’s fan page and delete comments posted by you at any time. In the case of YouTube, you may also unsubscribe from the Company’s channel at any time. The Company points out that publishing posts on the Company’s fan page will result in your personal data being made available to other users of the social media platform and to its operator, in accordance with the rules applicable to the relevant platform.
  • Data Processed for the Purpose of Negotiating, Entering into and Performing Contracts
    The Company processes personal data in connection with the negotiation, conclusion and performance of contracts with other entities. This applies to you where you are a party to a contract as a natural person or where you represent the other party to a contract (e.g. as a member of the management board, attorney-in-fact or contact person). In such cases, personal data is processed:
  • for the purpose of taking steps to enter into a contract and for the purpose of performing a contract with the data subject [Article 6(1)(b) of the GDPR], or with an entity represented by the data subject [Article 6(1)(f) of the GDPR];
  • for purposes arising from the legitimate interests pursued by the Company, namely pursuing or defending against claims, direct marketing and archiving [Article 6(1)(f) of the GDPR];
  • for the purpose of complying with legal obligations imposed on the Company by law, in particular tax and accounting obligations [Article 6(1)(c) of the GDPR].
    Providing personal data is generally voluntary, but the Company requires such data where it is necessary to enter into and perform a contract. Failure to provide the required data may make it impossible to enter into or perform the contract. Where the data is required to enter into a contract in the form of a notarial deed, the scope of the required data is determined by applicable law, and failure to provide such data will make it impossible to conclude the contract before a notary. Where personal data is processed for the purpose of fulfilling tax and accounting obligations, providing such data may be mandatory (e.g. for the issuance of a VAT invoice), as required by generally applicable law. In conducting its real estate brokerage activities, the Company uses the services of real estate intermediaries. In such cases, the Company may receive your personal data from such intermediaries, who are required to inform you of their intention to transfer your personal data to the Company. Personal data is retained for the duration of the contract and the legal relationships arising from it (e.g. co-ownership of real estate), as well as until the expiry of the applicable limitation period for claims.
  • Use of AI Tools
  • The Controller may use artificial intelligence tools to improve internal processes and prepare analyses, reports and statistical summaries. Such tools are used solely in a supporting capacity. As a result, the Controller does not use these tools to make decisions concerning data subjects that produce legal effects or similarly significantly affect them within the meaning of Article 22 of the GDPR (profiling).
  • The Controller has implemented appropriate organisational and technical measures to ensure the security of data processed using AI tools.
  1. Data Retention Period
    The Company does not retain personal data for longer than is necessary to fulfil the specific purpose for which it is processed. The period for which the Company processes your personal data depends on the type of service provided and the purpose of the processing. The applicable data retention period is specified for each individual processing activity described in this Privacy Policy. Where the processing of personal data is necessary to establish and pursue potential claims or defend against claims, the data will be processed until the expiry of the applicable limitation period for such claims. Personal data processed for the purpose of fulfilling legal obligations imposed on the Company is processed for the period required under generally applicable law (e.g. the statutory retention period for accounting documents). Where personal data is processed on the basis of the Company’s legitimate interest, the data will be processed for as long as necessary to pursue that interest or until you effectively object to the processing of your personal data.
  2. Data Recipients
    Depending on the purpose of processing, your personal data may be disclosed to entities providing specific services to the Company. The scope of the data disclosed will not exceed what is necessary in view of the nature of such services. Data recipients may include postal and courier service providers, where the use of traditional correspondence is necessary. Any data processed electronically may be disclosed to entities responsible for the Company’s IT services or providing IT solutions (e.g. software). Where data is processed for email marketing purposes, it may be disclosed to entities providing mass mailing services. Personal data may also be disclosed to entities operating within the same group of undertakings as the Company, as part of their cooperation with the Company. Personal data may also be disclosed to competent public authorities where required by applicable law.
  3. Transfer of Personal Data to Third Countries
    As a general rule, the Company does not transfer personal data to third countries (i.e. countries outside the European Economic Area – EEA). However, if it is necessary to transfer personal data outside the EEA, the Company will inform you of this at the time your personal data is collected. The Company will make every effort to ensure that the processing of personal data outside the EEA is carried out in accordance with the highest standards, in particular by:
  • using the services of data processors located in third countries for which the European Commission has issued an adequacy decision confirming an adequate level of protection for personal data;
  • applying standard contractual clauses approved by the European Commission;
  • applying binding corporate rules approved by the competent supervisory authority.
    A limited transfer of data may be necessary, for example, when the Company uses certain IT solutions.

Your Rights
You have the right to:

  • to request access to your personal data;
  • to request rectification of your personal data;
  • to request erasure of your personal data;
  • to request restriction of the processing of your personal data;
  • to request the transfer of your personal data to another controller, where the personal data was provided by you and is processed by automated means on the basis of your consent pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR, or on the basis of a contract pursuant to Article 6(1)(b) of the GDPR;
  • to object to the processing of your personal data for the purposes of direct marketing;
  • to object to the processing of your personal data pursuant to Article 6(1)(f) of the GDPR, i.e. where the processing is necessary for the purposes of the legitimate interests pursued by the Company;
  • to lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office (Polish: Prezes Urzędu Ochrony Danych Osobowych).
    You may withdraw any consent you have given at any time. Withdrawal of consent will not affect the lawfulness of processing carried out on the basis of your consent before its withdrawal.
  • General Rules for Using the Portal
    Use of the Portal is free of charge, voluntary and available to all Users with access to the Internet.
    The Portal allows Users to use the contact form, through which they may express their wish to receive marketing information, including commercial information about investments offered by entities within the 5S Invest group or investments offered by the Controller itself.
    The technical requirements necessary to interact with the IT system used by the Company are as follows: (1) a computer, laptop or other multimedia device with Internet access; (2) access to email, where using functionalities that rely on email (e.g. newsletters, reservations or email contact); (3) a properly configured web browser compliant with the standards of Microsoft Internet Explorer version 5.5 or later, Opera version 7.x or later, Firefox version 1.x or later, or Chrome; (4) a minimum screen resolution of [800 × 600].
    Users of the Portal are required to use the Portal in accordance with applicable law and generally accepted standards of conduct, while respecting personal rights, copyrights and intellectual property rights of the Company and third parties. Users are required to enter accurate information in the appropriate form fields. It is prohibited to provide any unlawful content.
    The Company makes every reasonable effort to secure your data and protect it against third-party access. For this reason, the connection to the Portal is established using the encrypted HTTPS protocol. This helps prevent the interception or alteration of transmitted data. By clicking the padlock symbol displayed in the address bar, you can obtain information about the Portal’s security certificate and, depending on the browser you use, may also be able to view detailed information about cookies stored on your device. However, the measures implemented by the Company may prove insufficient if you do not follow general security practices when using the Portal.
    Complaints concerning the provision of electronic services by the Company, as well as other complaints relating to the operation of the Portal, may be submitted, for example:
  • in writing to the Company’s registered office address;
  • electronically by email to the email address indicated in Section 2.
    When submitting a complaint, it is recommended that you provide: (1) information and circumstances relating to the subject matter of the complaint, in particular the type and date of the irregularity; (2) the remedy or action requested; and (3) the complainant’s contact details. Providing this information will facilitate and expedite the handling of the complaint. The requirements set out above are recommendations only and do not affect the validity or effectiveness of complaints submitted without the recommended information.
    The Company will respond to the complaint received and inform you of the outcome of its review, in particular in writing or by email, if you have provided an email address for this purpose.
  • Privacy Policy Updates
    This Privacy Policy was updated on 1 September 2026 and may be subject to further changes. Where required by law, you will be informed of any future changes or additions to the processing of personal data described in this Privacy Policy that may affect you, using the appropriate form of communication normally used by the Company to contact you.