Document

Privacy Policy

Working draft of 13 October 2026. In case of discrepancies the Polish version prevails confirm which version prevails.

Template awaiting approval by GAPLI. Items marked like this must be completed or decided by the owner before sign-ups go live. Until approved, this document is not final.

1. Data controller

The controller of the personal data collected on aderlo.city is GAPLI GLOBAL LTD, 590 Kingston Road, London SW20 8DN, United Kingdom, a company registered in England and Wales under number 16429382.

For anything related to personal data, write to contact@aderlo.city.

Controller's representative in the European Union (Article 27 GDPR): name, address and email of the EU representative — to be completed.

2. What data we collect and why

Waitlist. When you join the waitlist, we process your email address to send you news about the launch of Aderlo City. The legal basis is your consent (Article 6(1)(a) GDPR). Joining requires confirmation via a link sent to the address you provide (double opt-in).

Together with your request and confirmation we store the date, IP address, browser information and the wording of the consent you gave — solely to be able to demonstrate that consent was given (Article 6(1)(f) GDPR, our legitimate interest).

Unit reservation (brands and operators). When you send the “Reserve a unit” form, we process your full name, company or brand name, work email, phone number (if provided), industry, unit type of interest, whether you are a GAPLI operator, and your message. We do this to contact you about a unit in Aderlo City — based on your consent (Article 6(1)(a) GDPR) and, where the conversation concerns entering into a contract, to take steps prior to entering into it (Article 6(1)(b) GDPR).

Security. To protect the forms against abuse, we keep the IP address and time of submission for 24 hours (Article 6(1)(f) GDPR). The server also keeps standard technical logs server log retention period — to be completed.

Providing data is voluntary, but without an email address we cannot add you to the list, and without the reservation form data we cannot reply to your request.

3. How long we keep data

Unconfirmed waitlist requests — deleted automatically after 7 days.
Confirmed waitlist entries — until you withdraw consent or until communication about the launch of Aderlo City ends maximum period — to be decided.
Unit reservation requests — until you withdraw consent, for no longer than e.g. 24 months, unless we enter into a contract.
Proof of consent — for the limitation period of any potential claims.

4. Who we share data with

We entrust data only to providers who help us run the website and send messages, under data processing agreements:

website and email hosting provider: entity name — to be completed (servers in the European Union, Germany);
email sending tool provider (NetSendo): entity operating the instance — to be completed;
GAPLI group companies handling communication and the Aderlo City offer: to be completed, if applicable.

We do not sell data and do not share it for other companies' marketing.

5. Transfers outside the European Economic Area

The controller is based in the United Kingdom. Data is transferred to the United Kingdom on the basis of a European Commission decision finding an adequate level of data protection confirm that the decision is current and the legal basis — legal review.

6. Your rights

You have the right to access your data, rectify it, erase it, restrict its processing, port it, and object to processing based on legitimate interest. You can withdraw your consent at any time — without affecting the lawfulness of processing before withdrawal — by clicking the unsubscribe link in a message or by writing to contact@aderlo.city.

You also have the right to lodge a complaint with a supervisory authority — in Poland the President of the Personal Data Protection Office (UODO, ul. Stawki 2, 00-193 Warszawa), in the United Kingdom the Information Commissioner’s Office (ICO).

7. Profiling and cookies

We do not make automated decisions about you and do not profile you. The website does not use cookies — see the Cookie Policy.

8. Changes to this policy

We will announce material changes to this policy on this page, and notify people on the waitlist by email as well.