GENERAL PROVISIONS

1. In order to secure the privacy rights of Innova Service users and to comply with applicable legal requirements, Innova hereby provides the Service’s Users with this Privacy Policy, wherein Innova explains and informs them of the manner in which users’ personal data is processed and secured.

2. Innova processes personal data in accordance with all applicable laws, including the GDPR.

3. Before beginning to use the Innova Service, Users should carefully read this Privacy Policy.

DEFINITIONS

The capitalized terms used in this Policy shall have the following meanings:

Policy – this Privacy Policy

Innova – Innova Capital sp. z o.o. sp. k., with its registered office in Warsaw (00-124), Rondo ONZ 1.

User – a natural person whose personal data is processed by Innova in connection with their use of the Innova Service.

GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

Service – the website https://innovacap.com/

COLLECTION AND PROCESSING OF DATA BY INNOVA

4. Innova is the controller of personal data provided by Users when using the Service.

5. Innova ensures that Users can use its Service anonymously, however, in order to receive a newsletter, it is necessary for them to provide data in the form of an e-mail address.

6. With regards to business communications, the provision of personal data is voluntary, but it may be necessary in order to conclude and perform a contract (with respect to the personal data of sole traders).

PURPOSES AND LEGAL BASIS FOR DATA PROCESSING

7. Innova processes the personal data of the Service’s Users for the following purposes:

a. sending newsletters
Innova sends a free newsletter as well as other messages with information concerning Innova

The legal basis for processing is Article 6(1)(a) of the GDPR (the User's consent to receive correspondence from Innova).

b. ensuring the Service’s security and functionality
Innova processes personal data if necessary to ensure that Innova’s information processing is secure and to manage the Service.

The legal basis for processing is Article 6(1)(f) of the GDPR (fulfilment of Innova's legitimate interest, i.e. ensuring that the Service is operational).

c. pursuit of or protection against possible claims
In the event of possible claims against Users, or the necessity of protecting against such claims, Innova may process Users’ data obtained through the Service.

The legal basis for processing is Article 6(1)(f) of the GDPR (fulfilment of Innova's legitimate interest, i.e. protection against or pursuit of claims).

d. processing personal data for business purposes
Innova processes the personal data of the persons representing, or designated as contacts for, contractors, as well as the data of other persons for the purpose of business communications.

The legal basis for processing is:

- Article 6(1)(f) of the GDPR (fulfilment of Innova's legitimate interest, i.e. the ability to enter into or perform a contract with a contractor, protection against or pursuit of claims);

- Article 6(1)(b) of the GDPR (conclusion and performance of a contract – with respect to the data of sole traders).

SOURCE OF PERSONAL DATA

8. In the case of business communications, if the data was not provided by the data subject, the source of the personal data may be other employees/contractors of the entity with which Innova is about to enter into or has entered into a contract, or the personal data may have been obtained from a publicly available register (e.g. the National Court Register).

SHARING OF PERSONAL DATA

9. Access to Users’ data may be granted to Innova’s authorized employees and contractors, as well as entities whose services are used by Innova (e.g. IT service providers). In such cases, Innova has concluded agreements with said entities aimed at protecting the Users' data from unauthorized access.

USER’S PRIVACY RIGHTS

10. The User has the following rights in relation to their personal data processed by Innova as part of the Service:

a. right of access to personal data
b. right to rectify personal data
c. right to withdraw consent
d. right to the erasure of personal data
e. right to restrict the processing of personal data
f. right to request a transfer of personal data
g. right to object to the processing of personal data

11. To exercise any of these rights, Users may contact Innova via email at: mail@innovacap.com.

12. If a breach of the regulations on the protection of personal is found to have occurred, the User has the right to lodge a complaint with the President of the Personal Data Protection Office.

DATA RETENTION PERIOD

13. Innova stores Users' personal data only for the period of time necessary to achieve the purposes for which the data was collected. After this time, the data is either deleted or anonymized in such a way as to render it impossible to establish a User’s identity.

14. Personal data may be stored for longer periods of time if such a duty arises under law or is necessary in order to defend or enforce Innova’s claims against Users.

15. Data processed on the basis of consent will be processed until consent is withdrawn.

COOKIES

16. Cookies used on the Innova Service can be managed through one’s browser settings. For example:

(i) on Internet Explorer, Cookies can be disabled though the following settings: Tools/Internet Options/Privacy/Block All Cookies,

(ii) on Firefox, Cookies can be disabled through the following settings: Tools/Options/Privacy.

17. Blocking certain Cookies may impact the Service’s functionalities.

18. The Innova Service use several types of Cookies, including:

a. Session Cookies
Session Cookies are essential, enabling movement within the website and the use of its basic functions. They are used only within a single session. Session Cookies are anonymous and are used to: optimise and improve the Service’s performance.

b. Persistent Cookies
Unlike Session Cookies, persistent Cookies are reactivated whenever a User returns to the same website and remain in the browser’s subfolder until they expire (usually after 12 months). These Cookies collect information about the website’s use, including data on the pages visited by Users and potential errors.

c. Third-party Cookies
Third-party Cookies enable system cooperation with external companies or services. Third-party Cookies are used to:

- connect with social networking sites,

- provide research companies with data about site traffic.

LINKS TO OTHER SITES

19. This Policy only applies to the Service, the administrator of which is Innova. Innova is not responsible for links placed on the Service which enable Users to directly navigate to sites which Innova does not administer. We encourage Users to read the privacy notices available on the sites which links lead to.

CONTACT DETAILS AND THE RIGHT TO LODGE A COMPLAINT

20. Questions, conclusions and comments concerning the privacy policy and Innova’s processing of User data should be sent via email to the following e-mail address: mail@innovacap.com, or in writing to: Innova Capital sp. z o. o. sp. k., with its registered office in Warsaw (00-124), Rondo ONZ 1.