This is a courtesy English translation; the Polish version is legally binding.
1. Data controller
The controller of your personal data is Twins Real Estate, based in Phuket, Thailand, operating the website available at realestate-twins.com.
Contact for personal data protection matters: twins.realestate.monika@gmail.com
2. What data we collect and for what purpose
We collect personal data only when you voluntarily provide it - through the contact form on our website. This includes:
- First and last name - to identify you and respond personally
- Email address - to reply to your enquiry
- Phone number (optional) - to contact you by phone if you request it
- Message content - to answer your enquiry
Your data is not used for marketing purposes without your explicit consent.
3. Legal basis for processing
The legal basis for processing your data is:
- Art. 6(1)(a) GDPR - your voluntary consent given before submitting the form
- Art. 6(1)(b) GDPR - the need to take steps prior to entering into a contract (handling your enquiry)
- Art. 6(1)(f) GDPR - the legitimate interest of the controller (responding to your contact request)
4. Data retention period
We retain your personal data for the period necessary to fulfil the purpose for which it was collected - i.e. until our correspondence ends, and for a maximum of 24 months from the last contact, unless the law requires a longer retention period.
5. Sharing of data
Your personal data is not sold or shared with third parties for commercial purposes.
Data may be transferred only to:
- Technical service providers (hosting, email) - solely to the extent necessary to deliver their services, under data processing agreements
- State authorities - solely on the basis of applicable law
6. Your rights
Under the GDPR you have the following rights:
- Right of access - you may request information about what data of yours we process
- Right to rectification - you may request that inaccurate data be corrected
- Right to erasure - you may request the deletion of your data ("right to be forgotten")
- Right to restriction of processing - you may request that the processing of your data be restricted
- Right to data portability - you may receive your data in a structured format
- Right to withdraw consent - you may withdraw your consent to data processing at any time, which does not affect the lawfulness of processing carried out before the withdrawal
- Right to lodge a complaint - you may lodge a complaint with the competent supervisory authority for data protection
To exercise the above rights, please contact us: twins.realestate.monika@gmail.com
7. Cookies
The realestate-twins.com website may use cookies to ensure the site functions correctly. Cookies are text files stored on your device by your web browser.
We use the following types of cookies:
- Essential - necessary for the website to function properly
- Analytics - activated only after you give your consent: Google Analytics and our own analytics (described below)
7a. Our own visit analytics (first-party)
In addition to Google Analytics, we run our own internal visit analytics to better understand how you use the site and to improve our offering. We collect it only after you give your consent (the "Accept" button in the cookie banner) and store it only on our own server - this data is not shared with third parties.
As part of our own analytics we record: the pages you visit and the order in which you view them, the time spent on the site, the entry source (e.g. a search engine, a referring link, social media, a campaign), the type of device, browser and operating system, your approximate location (country/city), and interactions such as clicking a phone number, WhatsApp, an email address or submitting a form.
We do not store your IP address in plain text - it is processed only as an irreversible hash. To recognise returning visits we use an identifier stored in your browser (localStorage). The legal basis is your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time by clearing your browsing data / site storage in your browser settings.
You can manage cookies in your browser settings. Refusing consent or blocking cookies means that analytics (both Google Analytics and our own) will not be activated. Blocking cookies may affect the operation of some site features.
8. Data security
We apply appropriate technical and organisational measures to protect your personal data against unauthorised access, loss or destruction. The site uses the HTTPS protocol (SSL/TLS encryption).
9. Changes to this Privacy Policy
We reserve the right to amend this Privacy Policy. The current version is always available at realestate-twins.com/en/privacy-policy/. The date of the last update is shown at the top of the page.