Privacy Policy

Privacy Policy of FRU Concept

Introduction

Information about the Data Controller

FRU Concept, with its registered office at Aleja Solidarności 153/108, 00-877 Warsaw, Tax Idintificatios Number 5542516607 the data controller of personal data of clients using services provided under the High Life Aparts brand.

Purpose of Data Processing

Personal data of clients is processed for the following purposes:

• Execution of reservation services,
• Ensuring proper customer service,
• Compliance with legal obligations imposed on the data controller,
• Verification of clients’ identity and age of majority.

Scope of Processed Data

The processed data includes information necessary for making reservations and providing services, such as:

• Full name
• Contact details (email address, phone number)
• Payment information
• Date of birth (for age verification)
• Data from an identity document (series and document number – solely for verifying the guest’s identity)
• Other data voluntarily provided by the client during the reservation process

Legal Basis for Processing

Personal data is processed based on:

• Article 6(1)(b) of the GDPR – processing necessary for the performance of a contract to which the client is a party,
• Article 6(1)(c) of the GDPR – compliance with a legal obligation to which the data controller is subject,
• Article 6(1)(f) of the GDPR – legitimate interests pursued by the controller, such as pursuing claims.

Recipients of Data

Personal data may be shared with:

• Entities cooperating with FRU Concept in providing services (e.g., reservation system providers),
• Entities authorized under legal regulations.

Reservation System and Data Processing Security

The reservation system on the High Life Aparts website is operated by KAJWARE Spółka z Ograniczoną Odpowiedzialnością, which is responsible for processing personal data related to reservation services.

Service Provider Details:

• KAJWARE Sp. z o.o.
• KRS: 0000825731
• NIP: 6772450574
• REGON: 385399570
• Address: Zbożowa 3, 30-002 Kraków, Poland
• Legal Form: Limited Liability Company

Security Measures Implemented by KAJWARE Sp. z o.o. in KWHotel Software:

• The system is designed following privacy-by-design and privacy-by-default principles, ensuring data protection from the outset of system design.
• Full encryption of data transmission.
• Regular penetration testing and implementation of recommendations from these tests.
• Periodic backups to ensure data continuity.
• Access control system and version control.
• User account verification mechanisms.
• Data storage on servers located in the European Economic Area (EEA), meeting stringent security standards.
• Auditing of cooperating entities to ensure appropriate security measures and operational continuity.
• Logging of user actions, ensuring full accountability.
• Antivirus protections, firewalls, and IDS/IPS systems to guard against cybersecurity threats.

KAJWARE Sp. z o.o. commits to applying technical and organizational measures in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and national regulations on personal data protection.

Data Retention Period

Personal data will be stored for the period necessary to fulfill the purposes for which they were collected, as well as for the duration required by law or until the expiration of claims.

Clients’ Rights

Clients have the following rights:

• Access to their data
• Correction of data
• Erasure of data
• Restriction of processing
• Data portability
• Objection to processing
• Filing a complaint with a supervisory authority

Contact for Data Processing Matters

To exercise your rights or obtain further information regarding personal data processing, please contact us:

• Email address: Kontakt@HighLifeAparts.com
• Mailing address: FRU Concept, Aleja Solidarności 153/108, 00-877 Warsaw, Poland

Changes to the Privacy Policy

FRU Concept reserves the right to make changes to this Privacy Policy. Clients will be informed of any significant changes in advance.

Final Provisions

Using the services provided by FRU Concept implies acceptance of this Privacy Policy.