📘 PRIVACY POLICY / PERSONAL DATA PROTECTION POLICY (GDPR)

Go Emc2 Sp. z o.o. – TriApart
(Full version including the check-in GDPR clause)

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1. Data Controller

The Controller of your personal data ("Controller") is:

Go Emc2 Sp. z o.o.
Słowackiego 69/38
80-257 Gdańsk, Poland
E-mail: info@triapart.pl

Phone: +48 795 462 934

The Controller operates short-term rental services under the brand TriApart.

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2. Categories of Personal Data We Process

We process the following categories of personal data, depending on the purpose:

2.1. Identification and contact data

• first and last name,

• telephone number,

• e-mail address,

• residence address (for invoicing),

• details of accompanying guests.

2.2. Booking and check-in data

• booking number and dates of stay,

• number of guests,

• identity document data (only when required by law or building policy).

2.3. Financial and settlement data

• payment identifiers,

• booking reference numbers,

• invoicing data.
  (We do not store full credit card numbers.)

2.4. Data collected via online check-in

• name and contact details,

• time and date of submission,

• IP address,

• consent preferences.

2.5. CCTV data (in common areas of buildings)

Recordings may include:

• entrances, corridors, parking areas, lifts.

CCTV is operated by the building administrator or community association, not by TriApart.

2.6. Correspondence and complaint data

• messages, attachments, internal notes.

2.7. Marketing data (when consent is given)

• e-mail, telephone number, user preferences and analytics.

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3. Purposes and Legal Bases for Processing Personal Data

3.1. Booking, stay and service provision

Legal basis: Article 6(1)(b) GDPR – performance of a contract.

We process data to:

• accept and manage bookings,

• prepare the apartment for your arrival,

• perform check-in and check-out procedures,

• send access codes and instructions,

• handle payments and invoices,

• communicate with you before and during your stay,

• manage issues, defects or technical requests.

Providing this data is necessary to provide accommodation services.

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3.2. Compliance with legal obligations

Legal basis: Article 6(1)(c) GDPR.

This includes:

• accounting and tax obligations,

• issuing invoices,

• maintaining required hotel/guest records (where applicable),

• archiving documentation.

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3.3. Legitimate interests pursued by the Controller

Legal basis: Article 6(1)(f) GDPR.

This includes:

• ensuring the safety of guests and property,

• preventing fraud and misuse,

• documenting communication and service provision,

• investigating complaints and pursuing legal claims,

• obtaining CCTV footage when necessary,

• analysing business performance and service quality.

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3.4. Voluntary consents

Legal basis: Article 6(1)(a) GDPR.

This applies to:

• newsletters,

• promotional messages,

• post-stay communication.

Consent may be withdrawn at any time, without affecting prior lawful processing.

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4. Sources of Personal Data

We obtain data from:

• the guest directly (booking, check-in form),

• booking platforms (Booking.com, Airbnb, etc.),

• persons booking on behalf of a guest,

• building administrators (CCTV footage when legally justified).

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5. Recipients of Personal Data

Your data may be shared with:

• cleaning and technical maintenance companies,

• IT service providers and reservation system operators,

• online payment operators,

• accounting services,

• legal advisors and debt-collection partners,

• building administrators and security services,

• marketing service providers (only with consent),

• public authorities, where required by applicable law.

We do not sell personal data.

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6. Transfer of Data Outside the European Economic Area

As a rule, we do not transfer personal data outside the EEA.

Should such a transfer occur (e.g., email marketing systems), it will only take place using:

• Standard Contractual Clauses (SCC),

• appropriate technical and organisational safeguards,

• providers compliant with GDPR.

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7. Data Retention Periods

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8. Data Subjects’ Rights

You have the right to:

• access your data,

• rectify incorrect data,

• erase data (“right to be forgotten”),

• restrict processing,

• transfer your data,

• object to processing based on legitimate interest,

• withdraw consent at any time (marketing),

• file a complaint with the Polish Data Protection Authority (UODO).

Contact for GDPR matters: info@triapart.pl

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9. Data Security Measures

We apply:

• SSL encrypted connections,

• strict access control to systems and data,

• secure access systems for apartments (codes, key safes),

• internal procedures protecting guest data,

• backup and data-loss protection systems,

• trained staff with confidentiality obligations.

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10. Cookies and Website Analytics

Our website uses cookies to:

• ensure technical functionality,

• analyse traffic and usage statistics,

• remember user preferences,

• conduct marketing activities (where consent is granted).

Users may adjust cookie settings directly in their browser.

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11. GDPR Information Clause for Check-in / Registration Forms

This clause is fully integrated into the overall policy, as requested.

Data provided in the check-in form are processed for:

• performance of accommodation services,

• fulfilment of legal obligations (e.g., tax, accounting, guest registry),

• ensuring the security of guests and property,

• communication related to the booking and stay,

• marketing — only with your explicit consent.

Providing check-in data is necessary to prepare and grant access to the apartment.
Without this data, we cannot complete the accommodation service.

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12. Automated Decision-Making and Profiling

We do not make automated decisions that produce legal or significant effects for guests.
We do not use profiling for such purposes.

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13. Updates to This Policy

This Privacy Policy may be updated due to:

• changes in the services we provide,

• updates in applicable law (including GDPR),

• implementation of new technologies,

• operational improvements in reservation or check-in processes.

The current version will always be available on www.triapart.pl