Legal

Privacy Policy

Last updated: 16 June 2026 · Henry Luxury Estates sp. z o.o.

This translation is provided for convenience. The Polish version is the legally binding document.

This Privacy Policy sets out the rules for processing personal data by Henry Luxury Estates sp. z o.o. (the "Controller") in connection with the operation of the henryestates.pl website and the provision of the virtual office service. This document has been prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and the Polish Personal Data Protection Act of 10 May 2018.

1. Data Controller

The controller of personal data processed in connection with the use of this website and the services provided by us is:

Henry Luxury Estates Spółka z ograniczoną odpowiedzialnością
Al. Jerozolimskie 133/2, 02-304 Warsaw, Poland
KRS: 0001224245 · NIP: 1133193984 · REGON: 544008990

Contact regarding personal data protection: info@henryestates.pl.

2. Purposes and Legal Bases of Processing

We process personal data for the following purposes and on the following legal bases:

  • Performance of a contract (Art. 6(1)(b) GDPR) — provision of virtual office services, mail handling, invoicing, and operation of the Client Panel.
  • Legal obligation (Art. 6(1)(c) GDPR) — fulfilment of obligations under tax law, accounting law, and the Polish Act of 1 March 2018 on counteracting money laundering and terrorist financing (AML).
  • Legitimate interest (Art. 6(1)(f) GDPR) — handling inquiries, preventing abuse, asserting or defending claims, and improving our services.
  • Consent (Art. 6(1)(a) GDPR) — analytics and marketing measurement using cookies and similar technologies (Google, Meta Pixel), only where you have given prior consent via the cookie banner; consent can be withdrawn at any time.

3. Categories of Data Processed

We process the following categories of personal data:

  • Identification data — first name, last name, ID document type and number.
  • Contact data — email address, phone number.
  • Contract data — company name, NIP/KRS number, country of seat, selected service package.
  • Correspondence data — sender details and contents of mail handled under the virtual office service.
  • Transaction data — order details and payment references (we do not store payment card numbers).

4. Data Recipients

We share personal data only with parties to whom we are obliged to disclose it or who support the provision of our services:

  • IT and hosting provider (Hetzner Online GmbH) — servers on which the application and data are stored.
  • Payment processor (Stripe Inc.) — processing of payment transactions.
  • Email service provider (Resend Inc.) — delivery of transactional emails.
  • Public authorities — on request and within the scope required by applicable law.
  • Analytics and advertising providers (Google Ireland Ltd., Meta Platforms Ireland Ltd.) — only with your consent; analysis of site usage and measurement of advertising via Google Tag Manager/Google Analytics and the Meta Pixel.

We do not sell personal data to third parties.

5. Data Retention Period

We retain personal data for the duration of the virtual office service agreement and thereafter for the period required by applicable law:

  • 5 years after termination of the contract — tax and accounting obligations (Polish Accounting Act).
  • 5 years from the establishment of the business relationship — obligations under the Polish AML Act.

Data processed solely on the basis of legitimate interest is deleted promptly after that interest ceases or after an objection is upheld.

6. Rights of the Data Subject

Under the GDPR you have the following rights:

  • Right of access — to obtain information about the data processed and a copy of that data.
  • Right to rectification — to correct inaccurate or complete incomplete data.
  • Right to erasure — to request deletion of data in cases provided for by law.
  • Right to restriction of processing — to limit operations on data in specific situations.
  • Right to object — to object to processing based on legitimate interest.
  • Right to data portability — to receive data in a structured, commonly used format.
  • Right to lodge a complaint — with the President of the Polish Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw.

To exercise these rights, please contact: info@henryestates.pl. We respond within 30 days of receiving the request.

7. Transfer of Data Outside the European Economic Area

Some of our service providers — in particular Stripe Inc. (payment processor) and, where you have consented to analytics and marketing cookies, Google and Meta — may process personal data in the United States, outside the European Economic Area. Such transfers take place on the basis of Standard Contractual Clauses (SCC) approved by the European Commission and, where applicable, the EU–U.S. Data Privacy Framework, ensuring an adequate level of data protection.

8. Cookies

We use necessary and functional cookies for the proper functioning of the website and — only with your consent — analytics and marketing cookies (Google, Meta Pixel) to analyse usage and measure advertising. Detailed information about the cookies used, their categories, the consent mechanism, and how to manage or withdraw consent is available in our Cookie Policy.

9. Data Security

The Controller applies technical and organisational measures appropriate to the risk, in particular:

  • encryption of connections (HTTPS/TLS) and of data at rest on servers;
  • password hashing using bcrypt — user passwords are not stored in plaintext and are never known to the Controller;
  • role-based access control (RBAC) — access to client data is limited to authorised staff to the extent necessary for their duties;
  • logging and monitoring of system activity;
  • regular software updates and security reviews.

We do not store payment card numbers — full card data is handled by Stripe Inc. in accordance with the PCI DSS Level 1 standard.

10. Automated Decision-Making and Profiling

The Controller does not take decisions in a fully automated manner that produce legal effects concerning you or similarly significantly affect you, within the meaning of Art. 22 GDPR.

During the order process, we apply an automated check of the declared citizenship and country of residence against EU sanctions lists and the requirements of the Polish AML Act. The result of this check may lead to a refusal to complete the order in the self-service flow; in such a case we always make a manual review available upon contacting info@henryestates.pl.

Where you consent to marketing cookies, Google and Meta may use the data collected through their tags and the Meta Pixel to build advertising profiles and show you relevant ads on their platforms. This profiling does not produce legal effects concerning you, is based on your consent (Art. 6(1)(a) GDPR), and can be withdrawn at any time via the "Cookie settings" link in the website footer. If you do not consent to marketing cookies, we do not carry out profiling for advertising purposes.

11. Source of Data

Personal data is provided to us directly by you — when placing an order, signing the agreement, using the Client Panel, and contacting our support. In the course of handling correspondence, we also process the personal data of senders of letters addressed to your registered address, to the extent indicated on the envelope or in the contents of the mail.

12. Changes to the Privacy Policy

The Controller reserves the right to amend this privacy policy in the event of changes in legislation, changes in the scope of the services provided, or for other justified reasons. The current version of the privacy policy is always available on this page. The date of the last update is shown at the top of the document.