ARIA PRIVATE EQUITY privacy policy

ARIA PRIVATE EQUITY attaches great importance to protecting the confidentiality and privacy of information entrusted to us. One of the basic obligations of ARIA PRIVATE EQUITY is to ensure adequate protection and proper use of personal data. Our goal is also to properly inform you about matters related to the processing of personal data, especially with regard to the content of new provisions on personal data protection, including the Regulation of the European Parliament and of the Council (EU) 2016/679 of 27.04.2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“GDPR”). For this reason, in this document we inform you about the legal basis for the processing of personal data, how to collect and use it, as well as about the rights of data subjects related to it. Please read this Privacy Policy (“Privacy Policy”) to find out how we collect, use and protect your personal information.

1. What is personal data and what does processing mean?

Personal data means information about an identified or identifiable natural person. The processing of personal data is basically any activity on personal data, regardless of whether it is performed in an automated manner or not, e.g. collecting, storing, recording, organizing, modifying, viewing, using, sharing, limiting, deleting or destroying. ARIA PRIVATE EQUITY processes personal data for various purposes, and depending on the purpose, different collection methods, legal grounds for processing, use, disclosure and storage periods may apply.

2. Privacy policy and personal data controller?

This privacy policy applies to all cases where ARIA PRIVATE EQUITY is the controller of personal data and processes personal data. This applies to cases in which ARIA PRIVATE EQUITY processes personal data obtained directly from the data subject, as well as cases in which we obtained personal data from other sources. ARIA PRIVATE EQUITY carries out its information obligations in both of the above cases, as specified in art. 13 and art. 14 of GDPR in accordance with these provisions. Below we show the full details of ARIA PRIVATE EQUITY as a personal data controller:

ARIA PRIVATE EQUITY S.A. (Joint Stock Company) with its registered office in Warsaw at Rondo Organizacji Narodów Zjednoczonych 1, 00-124 Warszawa, entered into the Register of Companies of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Department of the National Court Register under the number KRS (National Court Register) number 0000693580, NIP (Tax Identification) number 5223099794, REGON (Statistical) number 368231036.

3. Purposes and legal basis for processing personal data

Our goal is to maintain transparency regarding the methods and legal grounds for processing personal data, as well as the purposes for which ARIA PRIVATE EQUITY processes personal data. We make every effort to indicate the necessary information in this regard to each person whose personal data we process as a data controller. Below we present the legal grounds for processing and categories of operations carried out in the field of data processing together with their description.

Objectives:

We process personal data obtained from customers, potential customers, suppliers, collaborators or potential collaborators or other third parties as well as natural persons who are their representatives or cooperating with us on their behalf in the scope necessary to provide services related to the broadly understood implementation of construction projects (consulting, training, design, implementation of construction services, development cooperation), as well as processes preceding the implementation of construction projects, i.e. communication and marketing of our services. This scope includes, but is not limited to:

1) Processing of personal data of visitors to websites maintained by ARIA PRIVATE EQUITY;

2) Processing of personal data of persons contacting ARIA PRIVATE EQUITY in order to obtain information about the offer or share comments regarding ARIA PRIVATE EQUITY services or products, as well as contacting in order to conclude a contract with ARIA PRIVATE EQUITY.

Legal grounds for processing

 The processing of personal data of natural persons who are our clients/associates is based on:

– legitimate interest of ARIA PRIVATE EQUITY as a data controller (e.g. in the field of database creation, analytical and profiling activities, including activities regarding the analysis of product use, direct marketing of own products, securing documentation for the purposes of defense against possible claims or for the purpose of pursuing claims)

– consent (including in particular consent to e-mail marketing or telemarketing)

– performance of the concluded contract

– Obligations arising from law (e.g. tax law or accounting regulations).

The processing of personal data of natural persons who are potential clients/potential collaborators is based on:

– legitimate interest of ARIA PRIVATE EQUITY as a data controller (e.g. in database creation, direct marketing of own products)

– consent (including in particular consent to e-mail marketing or telemarketing)

4. Voluntary choice

The standard version of the ARIA PRIVATE EQUITY website does not require you to provide personal data, however, ARIA PRIVATE EQUITY may require you to submit certain data if you want to get additional information about our services or activities. Expressing consent and choosing the preferred form of contact are completely voluntary. However, in order to be able to provide you with information through the selected communication channel, we need the data marked as mandatory in the contact form. All information regarding users’ rights in relation to data processing can be found in point 9 of this Privacy Policy.

5. Automatic collection of information

In some cases, ARIA PRIVATE EQUITY uses or plans to use tools for the automatic collection of information such as cookies, web beacons and other technologies to automatically collect certain types of information during users’ visits to our website. Such activities will allow us to improve the offer, website functionality and the efficiency of our marketing activities. As of the last update of this Privacy Policy, ARIA PRIVATE EQUITY applies the solutions described in the following. If a new solution is applied, the Privacy Policy will be updated.

It should be noted that the information collected in this way is not always personal data as in some cases it allows us to identify a specific user, but this can happen, for example, when it is possible to associate the IP address or location information with a specific user’s email address.

IP addresses

An IP address is an individual number assigned to a user’s computer during an Internet connection that enables communication between the given computer and the server. The IP addresses of users visiting the site may be recorded, inter alia, to ensure the security of the IT system and for diagnostic purposes. This information may also be used in aggregate form to analyze Internet trends and evaluate the operation of the website.

Location tools

ARIA PRIVATE EQUITY may collect and use data about the geographical location of a user’s computer or mobile device. Location data are collected to provide users with information about services that we think may be of interest to them because of their location. They are also collected to improve our products and services based on geolocation solutions.

Social media widgets and applications

There may be functions on ARIA PRIVATE EQUITY websites that allow you to share content using third-party social media applications (Facebook, Twitter). All personal data provided by users through such social media applications can be collected and used by other users of the above social media applications, and the interactions carried out through them are subject to the privacy policies of the companies that are the providers of the applications. We have no influence and take no responsibility for the above companies and their use of user data.

6. Time of data processing

The time for which we can process personal data depends on the legal basis which is the legal condition for the processing of personal data:

1) in the event that ARIA PRIVATE EQUITY processes personal data on the basis of consent, the processing period lasts until the consent is withdrawn by the user;

2) in the event that ARIA PRIVATE EQUITY processes personal data on the basis of the legitimate interest of the data controller, the processing period lasts until the above-mentioned interest (e.g. limitation period for civil law claims) or until such time as the data subject opposes further processing in situations where such an objection is in accordance with the law;

3) the case when ARIA PRIVATE EQUITY processes personal data because it is necessary due to applicable laws, the periods of data processing for this purpose are determined by these provisions;

4) in the absence of specific legal or contractual requirements, the basic period of data storage in the case of records and other documentary evidence drawn up during the performance of the contract is no longer than 10 years.

7. Sharing data with third parties

We only transfer personal data to others when permitted by law. In this case, in an appropriate contract with a third party, we provide security provisions and mechanisms to protect data and maintain the highest standards in the field of data protection, confidentiality and security. Agreements of this type are agreements for entrusting the processing of personal data and specify how and to what extent the entity entrusted with the processing of certain categories of personal data by ARIA PRIVATE EQUITY processes these data. However, we point out that the recipients of personal data that ARIA PRIVATE EQUITY processes as the personal data controller can be:

1) entities processing personal data under contracts entrusting the processing of personal data;

2) hosting service providers;

3) providers of accounting and computer software services;

4) entities implementing marketing or sales campaigns;

5) contractors and subcontractors cooperating with ARIA PRIVATE EQUITY as part of the core business;

6) entities providing survey research services;

7) auditors and statutory auditors, legal advisors, tax advisors;

8) debt collection companies;

At the same time, we inform you that we transfer personal data only to the extent that it is actually necessary to achieve a given purpose and in accordance with the mandatory provisions of law.

8. Transfer of personal data of non-EU/EEA countries

Personal data are processed only within the European Union or the European Economic Area.

9. Rights apply to data subjects and the manner of their implementation.

Natural persons have specific rights regarding their personal data, and ARIA PRIVATE EQUITY as the data controller is responsible for the implementation of these rights in accordance with applicable law. For all questions and requests regarding the scope and exercise of rights, as well as to contact us precisely in order to use specific rights in the field of personal data protection please contact us at the email address: office@ariafund.com.

We reserve the right to exercise the following rights after having successfully verified the identity of the person applying for the activity.

Access to personal data

Individuals have the right to access data that we store as a data controller. This right can be exercised by sending an email to: office@ariafund.com. 

Change of personal data

Changes, including the update of your personal data, which are processed by ARIA PRIVATE EQUITY, can be made by sending an email to the following email address: office@ariafund.com or, if applicable, contacting us via the appropriate registration page or changing personal data stored in relevant applications in which registration has been made.

Withdrawal of consent

In the case of processing personal data on the basis of consent, natural persons have the right to withdraw this consent at any time. We inform you about it almost at any time when collecting consents and allow you to withdraw your consent as easily as it was given. In the absence of other information, i.e. if we have not provided another address or contact number to withdraw consent, please send us an email to office@ariafund.com.

The right to limit processing or object to the processing of personal data

Natural persons have the right to limit the processing or object to the processing of their personal data at any time, due to their special situation, unless the processing is required by law.

An individual may object to the processing of their personal data when:

– the processing of personal data is based on a legitimate interest or for statistical purposes, and the opposition is justified by the particular situation in which they find themselves,

– personal data are processed for the purposes of direct marketing, including being profiled for this purpose.

You can exercise your right of objection from May 25th, 2018.

In turn, with regard to the request for limitation of data processing, we inform you that it applies, e.g. when a person notices that their data are incorrect. Then it may request that your data be restricted for a period of time that allows us to check that the data is correct.

The right to request deletion of data and the right to transfer data

If you wish to exercise these rights, please send an email to: office@ariafund.com.

The right to delete data can be used, e.g. when the data of a natural person are no longer necessary for the purposes for which they were collected by ARIA PRIVATE EQUITY or when a natural person withdraws their consent for data processing by ARIA PRIVATE EQUITY. In addition, if a natural person objects to the processing of their data or if their data will be processed unlawfully. The data should also be deleted in order to fulfill the obligation arising from the provision of law.

In turn, the right to transfer data is granted when the processing of a person’s data takes place on the basis of the consent of a natural person or a contract concluded with them and when the processing is carried out automatically.

All other questions, doubts and complaints

Any questions, reservations or doubts regarding the content of this Privacy Policy or the way we process personal data, as well as complaints regarding these issues, please send an email with detailed information about the complaint to : office@ariafund.com. All complaints received will be considered and we will respond to them without reasonable delay. Persons whose personal data are processed by ARIA PRIVATE EQUITY also have the right to lodge a complaint to the supervisory body, which is the Inspector General for Personal Data Protection (address: Inspector General for Personal Data Protection, ul. Stawki 2, 00-193 Warszawa) (art. 77 of GDPR) .

10. Changes to the Privacy Policy

We undertake to regularly review this Privacy Policy and its changes when it proves necessary or desirable due to changes in mandatory legal provisions, guidelines of supervisory authorities or our own actions taken in connection with improving personal data protection and organizational changes regarding the administration of data.

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