Privacy policy.

This clause is addressed to individuals who intend to give or have given Nunatak Capital sp. z o.o. permission to process personal data for direct marketing purposes (hereinafter "you").

 

Direct marketing may be carried out by e-mail, incoming telephone calls or SMS/MMS messages.

​

In accordance with Articles 13 and 14 of 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 (hereinafter "RODO"), we would like to inform you that:

 

1. The administrator of your personal data is Nunatak Capital sp. z o.o. with its registered office in Warsaw, address: Plac Trzech Krzyży 10/14, 00-449 Warsaw, entered in the register of entrepreneurs kept by the District Court in Warsaw, XII Economic Department of the National Court Register under the number KRS 0000831336, having NIP number: 7010973908 and REGON number: 38566490200000, with the share capital of PLN 66,800, fully paid up (hereinafter "Administrator");

2. Your personal data will be processed:

   • on the basis of your consent (Article 6(1)(a) of the RODO) The Administrator processes your personal data for direct marketing purposes only on the basis of your explicit, voluntary and previously expressed consent. The lawfulness of such processing is based on your consent. Any consent given may be withdrawn at any time. This also applies to the withdrawal of consents that were given before the application of the RODO, i.e. before 25 May 2018. Please note that the withdrawal of consent is only effective for the future and does not affect the lawfulness of the processing that was carried out on the basis of consent before its withdrawal.

   • for purposes arising from the legitimate interests pursued by the Controller (Article 6(1)(f) of the RODO); Processing may be deemed necessary for the purposes of the Controller's or a third party's legitimate interests if it does not unduly affect your interests or fundamental rights and freedoms. When processing personal data on this basis, we always try to balance our legitimate interests with your privacy. For processing based on this legal basis, the Controller has analysed the risks of infringement of your rights or freedoms and the measures adopted to protect your personal data. Examples of such "legitimate interests" are the use of cookies and profiling for marketing purposes.

3. The Controller processes the following categories of your personal data:

   • the identification and contact details you provide on the marketing form, i.e. name, surname, email address and telephone number;

4. The purpose of processing your personal data is direct marketing of the products and services of Nunatak Capital and Nunatak Capital affiliates

5. If you withdraw your consent to the processing of your personal data for direct marketing purposes, your data will be deleted on a regular basis as soon as you withdraw your consent;

6. We will process your personal data for the purposes indicated below for the period specified below:

   • Name of purpose of processing Description of purpose of processing Legal basis for processing Period of processing

   • Direct marketing Conducting direct marketing by the Controller Consent of the data subject (Article 6(1)(a) RODO) Period for which the Controller processes personal data for other purposes or until consent is withdrawn

   • Marketing based on cookies Conducting direct marketing by the Administrator Legitimate interests of the Administrator (Article 6(1)(f) RODO) "Session" cookies are temporary files that are stored in the user's terminal equipment until the user logs out, leaves the website or switches off the software (web browser). "Permanent" cookies are stored on the user's end device for the time specified in the parameters of the cookies or until they are deleted by the user.

   • Marketing profiling Profiling of customers for marketing purposes

   • Legitimate interests of the Administrator (Article 6(1)(f) RODO) The period for which the Administrator processes personal data for other purposes or until you object

7. You are entitled to:

   • The right to request access to the content of your personal data,

   • The right to request data rectification,

   • The right to request erasure of your data,

   • The right to request restriction of data processing,

   • The right to request data portability,

   • The right to object to the processing of your data,

   • The right to withdraw consent to the processing at any time without affecting the legality of the processing performed on the basis of consent before its withdrawal.

   • You can exercise the above rights by sending an appropriate letter to the address of the Administrator's registered office or by using the contact e-mail displayed on the website https://nunatakcapital.com/

8. You have the right to lodge a complaint to the relevant supervisory authority (in Poland the authority is the President of the Office for Personal Data Protection) if you believe that the processing of personal data concerning you violates the provisions of RODO;

9. Providing your personal data collected by the Administrator for the purposes of direct marketing in electronic or telephonic form is voluntary. The consequence of failing to provide the required personal data is the Administrator's inability to conduct direct marketing to you.

10. The Administrator may use your personal data for automated decision-making, including profiling. As a result of such actions, however, the Administrator does not make decisions which are based solely on automated decision-making, including profiling, and which could produce legal effects or similarly affect you.

    • Profiling is the Administrator's process of automatically processing information about you, including personal data such as your age, gender, interests, home address or preferences regarding specific products or services that the Administrator is marketing. This process is used to build your profile and analyze it.

    • In connection with your participation in promotional campaigns of investments carried out by the Administrator and entities affiliated by capital with the Administrator, your personal data is profiled for marketing purposes. The purpose of these operations is to match the products or services offered by the Administrator to your needs in the best possible way. Profiling does not affect your legal situation.

    • For the purposes of profiling, the Administrator uses the data referred to in section 3 above, i.e. both the data provided by you directly and the data concerning, for instance, your activity on the website of a given investment, collected through cookies and data obtained from external sources, e.g. Facebook. The Administrator ensures that such data is collected and used without excessive interference with your privacy.

    • On the basis of the processed data the Administrator's employees learn about your preferences, adjust the offer of their products or services to them and make decisions on undertaking specific marketing actions towards you or personalize marketing messages, which they send with your separate consent. Personalizing marketing messages consists in particular in adjusting their content to a particular recipient, his/her interests and preferences. This also means that persons or groups of persons who are assigned to certain categories, based for example on age or gender data, may be provided with specific advertising messages adapted to their age or gender.

    • In addition, you may be targeted for remarketing activities, which will most often be based on statistical data that does not constitute personal information. This means that visitors to the Administrator's websites may be shown advertising content about the Administrator's investments while on other websites.

    • The Administrator has implemented appropriate measures to protect your rights, freedoms and legitimate interests. You have the right to obtain human intervention from the Administrator, the right to express your opinion and to contest the decisions taken in this way.

11. During your activity on the Administrator's website https://nunatakcapital.com/, cookie IDs generated by your devices, applications, tools, etc. are assigned to you. Based on these identifiers, the Administrator, in combination with other information obtained through web servers, can collect data about your activity, create profiles and identify you.

 

This clause was updated on 01 April 2021 and may be subject to further changes. If required by law, any information regarding future changes or additions to the processing of personal data described in this clause that may affect you will be communicated to you through the appropriate form of communication normally used by the Controller in its dealings with you.