Warsaw Equity Group

Privacy Policy

PRIVACY POLICY OF WARSAW EQUITY MANAGEMENT S.A.

1. Who is the Administrator of my personal data?

The administrator of personal data is Warsaw Equity Management S.A. with its registered office in Warsaw at ul. Marszałkowska 126/134, 00-008 Warsaw, registered in the Register of Entrepreneurs of the National Court Register under KRS number: 449480 (“WEM”).

Given the scale of its operations, WEM has not appointed a Personal Data Inspector within its structures, and all obligations under the GDPR and other legal provisions are executed directly by WEM.

The purpose of the GDPR is to establish comprehensive rules for the protection of personal data of natural persons. The GDPR introduces a number of new issues in the field of the rights of natural persons. One of the purposes of the GDPR is to inform natural persons in detail about the processing of their personal data and the principles of their processing, as well as about the rights of a natural person to whom personal data relate.

2. What personal data are processed by the Administrator?

As the administrator of personal data within the meaning of the GDPR, WEM processes, in particular, the following personal data:

  • Personal data of contractors and their representatives(data of companies and contact persons – basic data used for issuing and posting invoices (company name, nip, registered office address, business address) and for contact (name, surname, company name, job position, business e-mail address, business phone number)
  • Personal data of persons who have subscribed to the Newsletter(e-mail address)
  • Personal data of persons who send inquiries via contact forms, e-mail and telephone (basic contact data: name, surname, e-mail address or telephone number), including personal data of persons sending Pitch Deck
  • Personal data of job candidates (data that candidates provide tothe administrator in connection with participation in recruitment processes – in particular data contained in the CV)

In addition to the data listed above, WEM may also obtain and process other personal data. In such situations, the rules for processing such data are described in the relevant information clauses given on the forms/other places, including those placed/indicated on the WEG Portal, from which your personal data are obtained.

3. On what terms does the Administrator process my personal data?

The principles of processing your personal data are presented below (in particular, it is explained who has access to them, how long they are stored and for what purposes and on what grounds they are processed).

  • Personal data of contractors and their representatives

Purposes and grounds for data processing: Personal data of contractors and their representatives (including, in particular, contractors’ employees and coworkers) shall be processed for the purposes of:

  • contact, including for the purpose of establishing and conducting business contacts and ensuring the execution of contracts concluded with Contractors (pursuant to art. 6 section 1 (f) of the GDPR – the justified interest of the data administrator, which is to ensure contact with the Contractor and to ensure the implementation of contracts concluded with the Contractors or pursuant to art. 6 section 1 (a) of GDPR – the consent you have given)
  • fulfillment of obligations resulting from applicable legal regulations (in particular those resulting from the Accounting Act and the VAT Act) (Pursuant to Art. 6 section 1 (c) of the GDPR – processing is necessary to fulfill a legal obligation of the Administrator)
  • defending against claims as well as determining and pursuing claims (pursuant to Art. 6 section 1 (f) of the GDPR – the justified interest of the data administrator, which is determining and pursuing claims and defending claims)
  • [in the event of granting appropriate consent] sending commercial information, including in the form of a Newsletter to the indicated e-mail address/telephone number (pursuant to art. 6 section 1 (a) of GDPR – the consent you have given)
  • [in case in which you are a party to the agreement] to take action before the conclusion of the agreement and its execution (pursuant to 6 sec. 1 (b) of the GDPR – processing is necessary for the performance of agreements to which you are a party]

Source of data origin | Voluntariness / obligation to provide data: Your personal data has been obtained directly from you or from your employer/client. In the event that data are obtained directly from you, the provision of such data is voluntary, but necessary for the conclusion/performance of the relevant agreement between us. Your personal data may also have been obtained from WEM partners if you have given your consent.

Recipients of data: These Data may be disclosed to entities authorized in compliance with the provisions of law. WEM’s IT service support entities and other entities supporting WEM in connection with the purposes described in the paragraph “Purposes and basis of data processing” (in particular, couriers, external auditors, lawyers, accountants) may also have access to the data on the basis of relevant contracts.

Automated decision making/ profiling: WEM does not make decisions based on automated processing, including profiling (in relation to the purposes of data processing described above).

Data storage period: Personal data of contractors’ representatives shall be stored until the purposes set out in the paragraph “Purposes and grounds for data processing” are achieved and then for the period required by law/until the claims are expired.

  • Details of persons who have subscribed to the Newsletter

Purposes and grounds for data processing: Personal data shall be processed in order to:

  1. send cyclical messages to the indicated e-mail address regarding WEM and WEM portfolio companies, or their activities as part of the WEM newsletter (pursuant to art. 6 section 1 (f) of the GDPR – the justified interest of the data administrator, which is direct marketing, in connection with the consent granted to send the Newsletter/commercial information)
  2. demonstrate compliance with applicable law, which is the legitimate interest of the personal data administrator (art. 6 section 1 (f) of the GDPR)
  3. pursue and defend claims (pursuant to art. 6 section (1) (f) of the GDPR*– the justified interest of the data administrator to pursue and defend claims)

Recipients of data: These data may be made available to entities:

  • authorized in compliance with the legal regulations.
  • Data may also be accessed on the basis of relevant agreements by IT infrastructure and service providers (such as hosting companies or companies providing e-mail marketing solutions) processing data on behalf of WEM.

Data storage period: Your personal data shall be stored until the consent granted is revoked and then for the period necessary to demonstrate compliance with applicable law/making or defending claims.

Automated decision making/ profiling: WEM does not make decisions based on automated processing, including profiling (in relation to the purposes of data processing described above).

Voluntariness/ obligation to provide data: Providing personal data is voluntary, but necessary to subscribe to the Newsletter.

  • Persons submitting inquiries via contact forms (including Pitch Deck), e-mail and telephone

Purposes and grounds for data processing: Personal data shall be processed in order to:

  1. conduct current electronic correspondence and carry out actions taken at your request regarding Your inquiries about the possibility of contacting or presenting a potential investment/business activity (within the Pitch Deck) sent via the contact form (the basis for data processing is the justified interest of the data administrator, which is conducting electronic correspondence and carrying out actions taken at the request of persons such data relate to).
  2. [if the appropriate consent is granted] send commercial information to the indicated e-mail address/phone number (pursuant to Art. 6 section 1 (a) of the GDPR – the consent you have given)

Recipients of data: These data may be made available to entities:

  1. authorized in compliance with the legal regulations.
  2. Data may also be accessed on the basis of relevant agreements by IT infrastructure and service providers (such as hosting companies or companies providing e-mail marketing solutions) processing data on behalf of WEM.

Data storage period: Personal data processed by the administrator shall be stored for the period of conducting electronic correspondence and then for archiving purposes for the period specified in the administrator’s office manual. In case of granting consent to receive commercial information, personal data shall be stored until such consent is revoked.

WEM does not make decisions based on automated processing, including profiling (with respect to the purposes of data processing described above).

Voluntariness/ obligation to provide data: Providing personal data is voluntary, but necessary for the exchange of electronic correspondence or to carry out actions taken at your request. Giving consent to be contacted for the purpose of receiving commercial information is voluntary.

  • Personal data of job applicants

Purposes and bases of data processing: Your personal data shall be processed for the purposes of the recruitment process or also for the purposes of future recruitment processes in the event of your appropriate consent (the basis for the processing of these data are applicable legal regulations (in particular the Labour Code) and your consent), including recruitment processes carried out by WEM, including for the needs of its portfolio companies. In case of recruitment for a portfolio company, the personal data of the candidate shall be provided to such company after the candidate gives his consent.

Recipients of data: These Data may be disclosed to entities authorized in compliance with the provisions of law. Data may also be accessed under applicable agreements by entities supporting WEM in the recruitment process or in the provision of IT services and infrastructure, as well as by executives including members of the boards of directors of portfolio companies for whom WEM may recruit (if the candidate consents).

Data storage period: Personal data processed by the administrator shall be stored until the recruitment process is completed or until your consent is revoked in case of data processing for the purposes of future recruitment processes.

Automated decision making/ profiling: WEM does not make decisions based on automated processing, including profiling (in relation to the purposes of data processing described above).

Voluntariness/ obligation to provide data: Providing personal data to the extent required by law, in particular the Labour Code, is mandatory, in other cases it is voluntary.

4. What rights do I have in connection with the processing of my personal data by WEM?

You have the right, as appropriate, to:

  1. request access to your personal data, rectify, delete and limit its processing, as well as to transfer your personal data;
  2. withdraw granted consent at any time (if it has been granted). The withdrawal of consent shall not affect the lawfulness of processing based on consent given before its withdrawal;
  3. object to the processing of your personal data;
  4. file a complaint to the supervisory authority (PUODO – the President of the Personal Data Protection Office).

5. To whom do we transfer your personal data?

Your personal data shall be processed only by WEM and third parties which, on the basis of binding civil law contracts, provide services to WEM in connection with their business activities and they shall process personal data on behalf of WEM (“Processing Entities”). The Processing Entities acting on behalf of WEM shall be in particular: entities handling our ICT systems or providing WEM with ICT tools, entities providing WEM with consulting, advising, audit services, legal, tax and accounting support, recruitment services, etc.

6. How we protect your personal data?

WEM shall provide appropriate technological, physical, administrative and procedural data protection measures, adequate to the scope of WEM’s business activities and the extent of personal data processing, to protect and ensure the confidentiality, correctness and availability of personal data processed, as well as to protect against unauthorized use of or unauthorized access to personal data and to protect against security breaches of personal data.

7. Will your personal data be transferred outside the European Economic Area (EEA)?

We currently have no plans to transfer your data outside the EEA (which includes the European Union, Norway, Liechtenstein and Iceland). However, we may choose to transfer data outside the EEA as part of our business activities only to the extent that we are permitted to do so by law or by your consent.

8. What is profiling? Will there be automated decisions, including profiling, that have a significant effect on you?1. Your personal data shall not be profiled by WEM. The processing of personal data in order to tailor the offer, services or goods to your interests and needs is considered profiling. WEM shall not automatically make decisions that have a significant impact on you.

9. Who can I contact regarding questions about the processing of my personal data and the exercise of my rights?

All inquiries and statements regarding the aforementioned rights should be addressed to the following contact data:

Contact details of the data administrator: Warsaw Equity Management Spółka Akcyjna with its registered office in Warsaw, ul. Marszałkowska 126/134, 00-008 Warszawa, e-mail address: office@warsawequity.com; phone no +48 22 166 29 60.

10. Information on cookies

Cookies: The website www.warsawequity.com (“Website”) uses cookies. By starting to use the Site without changing the settings of the device and software used to use the Site in a way that prevents the receipt of cookies, the person using the Site (“User”) agrees to receive unique cookies, which will be stored in the memory of his/her computer or other device in order to ensure the correct operation of the Site and the further purposes of their use. Cookies may be generated and stored in the memory of the device used by the User, both by the Website and related systems of third parties. Cookies are used for the following purposes:

  • Marketing – displaying advertisements adapted to preferences of the users (pursuant to art. 6 section (1)(f) of the RODO – the data controller’s legitimate interest in direct marketing – if consent to use cookies is granted)
  • Optimization – make it easier to use the website (e.g. remembering to deselect messages displayed on the website);
  • Analytical – to create statistics on the basis of which the website is able to better tailor its content to the preferences of its users (visitors to the website).

Cookies store information necessary for the proper functioning of websites, in particular those that use authorization mechanisms. The purpose of such files is to ensure the proper functioning of the Website.

Cookies enable the analysis of Users’ activity on the Website.

Cookies may be of the following nature:

  1. session (present in your browser and device until you leave the Site) or
  2. permanent (remain in the browser and device according to the file parameters or until manually deleted and can be generated or updated at each visit to the Website).

If you do not agree to the saving of cookies on your device, please change the setting of your web browser and/or block the operation of external cookies as described below. Restricting the use of Cookies may affect some of the functionalities available at www.warsawequity.com

The website uses Piwik PRO Analytics Suite website/application analysis software and consent management tool. Through this software, WEM collects data about Users on the basis of cookies. The collected information may include the visitor’s IP address, operating system, browser ID, browsing activity, and other information. In the following link you can check the scope of data collected by Piwik PRO Analytics Suite.

Through Piwik PRO Analytics Suite, we calculate metrics such as rejection rates, page views, sessions, etc. to understand how our Website is being used. We may also create visitors profiles based on your browsing history to analyze the Users’s behavior, display personalized content, and conduct online campaigns.

Piwik PRO Analytics Suite hosts its solution on the Microsoft Azure platform in Germany/Netherlands/United States/Singapore/ElastX in Sweden, and the data are stored for 14/25 months. Piwik PRO does not transfer User data to any other subcontractors or third parties and does not use it for its own purposes. For more information, please refer to the Piwik PRO Privacy Policy.

Purpose of data processing: analytics and conversion tracking based on consent.

Legal basis: art. 6 section 1 (a) of the GDPR.

Privacy settings

This page allows you to manage your privacy settings and consents. We ask for certain data in order to continuously improve your experience on our website. We shall only collect and use the data for the stated purposes you have agreed to. For more information, visit the settings page.

Requests for the exercise of rights in the field of personal data protection

Please select below the type of data protection request along with any additional inquiries in the body of the message. We shall make every effort to fulfill them. Your email address is required to contact you regarding your request. We shall not use your email address for any purpose other than processing your request.

Type of application

Access to data
Access to data
Delete data
Data correction

Message to site administrator