Privacy policy
PRIVACY AND COOKIES POLICY
We fully respect your right to privacy and data protection. We have created this policy in order to explain the processing of the personal data that you provide. This policy is a demonstration of our concern for your rights and the security of the personal data we process.
We are hereby declaring our continuous commitment to ensuring the highest possible standard of privacy protection and we are therefore committed to complying with both the Policy and all legal requirements relating to the protection of your personal data.
POLICY RECIPIENTS
We direct the Policy to:
- Investors which are natural persons and representatives of the Investors who are legal persons or organisational units without legal personality
- Issuers which are natural persons and representatives of Issuers who are legal persons or organisational units without legal personality
- providers of products or services to us, including our subcontractors, as well as employees, associates and representatives of such entities designated for ongoing business relations or whose data is shared in connection with the performance of a contract with us
- our actual and potential customers other than the Issuers, as well as employees, associates and representatives of such entities designated for ongoing business contacts or whose data is shared in connection with the performance of a contract with us
- visitors to the Website
DEFINITIONS
In the interests of policy clarity, we have adopted the following definitions for the terms we use:
- Administrator, “we”, “us”, “our”, “Comcreo” – Comcreo Spółka Akcyjna (joint-stock company) with its registered office in Warsaw (postal code: 01-059) at 47/24 Okopowa Street, entered into the register of enterprirses kept by the District Court for the capital city of Warsaw, 13th Commercial Division of the National Court Register (Wydział Gospodarczy), under KRS No. (National Court Register No.) 0000898763, having initial capital of PLN 100,000.00 (paid in full), having NIP No. (Tax ID No.) 5272958004
- personal data – according to the GDPR – any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
- Issuer – a natural person, legal entity or organisational unit without legal personality that has entered into a tokenisation agreement with us
- Investor – a natural person, legal entity or organisational unit without legal personality having an active Account on the Platform in order to acquire tokens
- Account – individual and personalised account of the registered Investor on the Platform, enabling him to use the services made available to him by Comcreo
- third-country – means a country not belonging to the European Economic Area
- Platform – the Comcreo platform operating at comcreo.com
- Policy – this privacy and cookie policy
- Regulations – regulations for the provision of services under the platform “Comcreo”
- GDPR – Regulation 2016/679 – 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 (General Data Protection Regulation) (Official Journal of the EU L 119, p. 1)
- Website – our website at: www.comcreo.com
- Service – both Website and Platform
- Act on Electronic Services – Ustawa z dnia 18 lipca 2002 r. o świadczeniu usług drogą elektroniczną, Dz.U. 2002 nr 144 poz. 1204
- User – a person using the Platform or the Website
WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?
The Administrator of the personal data that you provide is Comcreo Spółka Akcyjna (joint-stock company) with its registered office in Warsaw (postal code: 01-059).
Details can be found in the “definitions” section above.
You can contact us if you have any questions about the processing of your personal data:
- by sending an e-mail to rodo@comcreo.com
- in writing by post to our address:
Comcreo S.A.
Okopowa street no 47/24
Warsaw, Poland 01-059
If you purchase tokens, your personal data may be administered by their Issuers. We are sharing your personal data with Issuers to the extent necessary for your use of the token you have purchased.
PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA
Below, we set out in a clear form both the purposes for which we process personal data and the legal basis for processing them.
| If you are or wish to become the Investor or if you are the representative of the Investor who is a legal person or organisational unit without legal personality | |
| Purpose of processing your personal data | Legal basis for processing your personal data |
| handling your participation as an active User of the Platform | your consent to the processing of your personal data in connection with your use of the Platform (art. 6(1)(a) of the GDPR) |
| if you are the Investor:
taking, at your request, all necessary steps prior to the conclusion of the contract for the electronic provision of services, with the provision of services to you, in particular, by allowing you to create an Account and to purchase tokens on the Platform |
if you are the Investor:
the necessity of processing your personal data for the performance of a contract for the electronic provision of services or in order to take action at your request prior to entering into such a contract, insofar as they concern you (Article 6(1)(b) of the GDPR) |
| complying with legal obligations imposed on us (e.g. providing explanations and answers to questions from the relevant authorities, bookkeeping) | the performance of obligations imposed on us by generally applicable legislation (Article 6(1)(c) of the GDPR) |
|
the pursuit of our legitimate interests to ensure the high quality of our services and the correct execution of the concluded contracts for the electronic provision of services (Article 6(1)(f) of the GDPR) |
| conducting direct marketing of our own products and services and those of the Issuers, including sending commercial information about tokens available for purchase, promotions, events, partner programs by means of electronic communication, including e-mail |
the pursuit of our legitimate interests to carry out direct marketing activities* (Article 6(1)(f) of the GDPR)
*commercial communications by means of electronic communication, including e-mail, subject to your consent for us to do so |
|
the pursuit of our legitimate interests consisting of: the right to assert or defend our rights in connection with claims made, debt recovery, litigation, mediation and arbitration (Article 6(1)(f) of the GDPR) |
| If you are a representative of an Investor which is a legal person or an organisational unit without legal personality:
performance and fulfilment of the contract for the provision of electronic services concluded by us with your contractor or employer which is an Investor, including maintaining business contact in connection with that contract |
If you are a representative of an Investor which is a legal person or an organisational unit without legal personality:
the proper performance and execution of the contract for the electronic provision of services with your employer or contractor and to maintain ongoing business relations and relevant communications (Article 6(1)(f) of the GDPR) |
The provision of your personal data is necessary for the conclusion of the contract for the electronic provision of services, including the creation of the Account on the Platform and the purchase of tokens. If you do not provide your personal data to us for the above purposes, you will not be able to create the Account and purchase tokens through the Platform.
| If you are, or wish to become, the Issuer or are a representative of an Issuer that is a legal person or an organisational unit without legal personality | |
| Purpose of processing your personal data | Legal basis for processing your personal data |
| if you are the Issuer:
taking, at your request, all necessary steps prior to the conclusion of the tokenisation cooperation contract with us and to perform the contract |
if you are the Issuer:
the necessity of processing your personal data for the performance of a tokenisation cooperation contract or to take action at your request prior to entering into such an contract insofar as they concern you (Article 6(1)(b) of the GDPR) |
| complying with legal obligations imposed on us (e.g. providing explanations and answers to questions from the relevant authorities, bookkeeping) | the performance of obligations imposed on us by generally applicable legislation (Article 6(1)(c) of the GDPR) |
|
the pursuit of our legitimate interests to ensure the high quality of our services and the correct execution of the concluded contracts (Article 6(1)(f) of the GDPR) |
| conducting direct marketing and sending commercial information by means of electronic communication, including e-mail |
the pursuit of our legitimate interests to carry out direct marketing activities* (Article of the 6(1)(f) of the GDPR)
*commercial communications by means of electronic communication, including e-mail, subject to your consent for us to do so |
|
the pursuit of our legitimate interests consisting of: the right to assert or defend our rights in connection with claims made, debt recovery, litigation, mediation and arbitration (Article 6(1)(f) of the GDPR) |
| If you are a representative of the Issuer which is a legal person or an organisational unit without legal personality:
the execution and performance of the tokenisation cooperation contract entered into by us with your conractor or employer which is the Investor, including the maintenance of the business relationship in connection with that contract |
If you are a representative of the Issuer which is a legal person or an organisational unit without legal personality:
the pursuit of our legitimate interests for the proper performance and execution of the tokenisation cooperation contract with your employer or contractor and to maintain ongoing business relations and relevant communications (Article 6(1)(f) of the GDPR) |
If your personal data has been obtained directly from you, providing the data is voluntary. However, failure to do so may prevent us from maintaining contact with you, as well as from establishing or maintaining a business relationship, including the conclusion, execution and performance of a tokenisation cooperation contract.
| If you are a provider of products or services to us, including our subcontractor, or are an actual or potential customer of ours other than the Issuer, or are an employee, associate or other representative of such an entity designated to maintain an ongoing business relationship or whose data is shared in connection with the performance of a contract with us | |
| Purpose of processing your personal data | Legal basis for processing your personal data |
| the performance of a contract concluded with us to which you are a party or to take, at your request, all necessary steps prior to the conclusion of a contract with us (Article 6(1)(b) of the GDPR) | the necessity of processing your personal data for the performance of contract with us or to take action at your request prior to entering into such an contract insofar as they concern you (Article 6(1)(b) of the GDPR) |
| complying with legal obligations imposed on us (e.g. providing explanations and answers to questions from the relevant authorities, bookkeeping) | the performance of obligations imposed on us by generally applicable legislation (Article 6(1)(c) of the GDPR) |
| keeping in touch with you for the correct performance of the contract | the pursuit of our legitimate interests to ensure the high quality of our services and the correct performance of the contracts concluded (Article 6(1)(f) of the GDPR) |
| conducting direct marketing and sending commercial information by means of electronic communication, including e-mail |
the pursuit of our legitimate interests to carry out direct marketing activities* (Article of the 6(1)(f) of the GDPR)
*commercial communications by means of electronic communication, including e-mail, subject to your consent for us to do so |
|
the pursuit of our legitimate interests consisting of: the right to assert or defend our rights in connection with claims made, debt recovery, litigation, mediation and arbitration, the proper performance and execution of the contract, including maintenance of the business relationship in connection with that contract, the proper performance and execution of the contract with your contractor or employer (Article 6(1)(f) of the GDPR) |
If your personal data has been obtained directly from you, providing the data is voluntary. However, failure to do so may prevent us from maintaining contact with you, as well as from establishing or maintaining a business relationship.
| If you visit our Website | |
| Purpose of processing your personal data | Legal basis for processing your personal data |
|
|
Information about your activity on the Website is collected automatically.
WHAT PERSONAL DATA DO WE PROCESS?
Depending on which Policy recipients you belong to, we may process the following of your personal data:
If you are:
— the Investor or a representative of the Investor which is a legal person or an organisational unit without legal personality
— the Issuer or a representative of the Issuer being a legal person or an organisational unit without legal personality
In the case of a non-business person, we may process:
- name and surname
- phone number
- e-mail address
- PESEL number
- date and place of birth
- citizenship
- sex
- the number of the document confirming your identity
- residence address
In the case of a business person, we additionally process:
- NIP (Tax ID)
If you are:
— a provider of products or services to us, including our subcontractor or an employee, associate or representative of such entity, appointed for an ongoing business relationship or whose data is shared in connection with the contract with us
— an actual or potential customer of ours other than the Issuer, or else an employee, associate or representative of such, designated for ongoing business relationship, or whose data is shared in connection with a contract with us
We may process the following categories of your personal data:
- identification data (including full name, Tax ID (NIP) number)
- contact details (e.g. e-mail address, phone number)
- data on the function held (official position, title of your function, place in which the function/position is held, identification of the entity in which you work)
- other data disclosed to us for business and relationships purposes
If you are a visitor to the Website or use the Platform we may process the following categories of your personal data:
- information about your activity
- marks that identify you
- information that you are using electronically supplied services, the start time for the use of those services and the end time
- information that identifies the information system or telecommunications network you are using
- the data you provide to us within the contact form, if you use it
INFORMATION ON AUTOMATED DECISION-MAKING, INCLUDING PROFILING
In connection with the processing of personal data for marketing purposes, we perform profiling consisting of the analysis of information and activity on the Platform, in particular with regard to your purchase history on the Platform. The purpose of the profiling performed is to prepare an individualised offer tailored to your needs. In connection with profiling, we process the following data about you:
- your purchase history on the Platform
- sex
- age
- residence address
- potential interests
- your other activities on the Platform
HOW IS THE SECURITY OF YOUR DATA ENSURED?
As Administrators, we care about protecting your personal data. We use appropriate organisational and technical solutions to prevent interference in the User’s privacy by third parties. Our actions are aimed at guaranteeing the User a feeling of full security at a level appropriate to the applicable law, in particular the GDPR.
TO WHOM DO WE SHARE YOUR DATA?
As the Administrator, we take the utmost care to ensure the confidentiality of your personal data. Your personal data is processed by a limited circle of persons, including our employees and associates to the extent necessary for them to perform their work in connection with the provision of services to you. Your personal data may also be transferred to third parties as mentioned below. Due to the need to fulfil contractual obligations and to ensure the correct performance of the services we offer, your personal data may be transferred to:
- service providers who provide us with technical and organisational solutions enabling us to manage our organisation, including entities operating ICT systems or providing us with ICT tools (in particular ICT service providers, accountants, hosting, courier and postal companies)
- providers of legal and advisory services and others who assist us in the recovery of outstanding claims (in particular law firms)
- other entities and authorities to which we are obliged or authorised to provide personal data under generally applicable legislation
Additionally, if you are the Investor, your data may be transferred:
- to the Issuers whose tokens you have purchased
- online payment companies (online payment operators)
In case of necessity to share your personal data with third parties, we require them to maintain the confidentiality and security of your information and to use your personal data only for the proper performance of the relevant Service. We have entered into appropriate data processing entrustment agreements with the entities to which we entrust personal data.
We are also obliged to make it available at the request of entities entitled to do so under other provisions of law, e.g. courts or law enforcement agencies. However, such access will be granted only if they make a request to us indicating the legal basis which allows them to do so.
TRANSFER OF PERSONAL DATA TO A THIRD-COUNTRY
Your personal data may be provided by us to a third-country, i.e. outside the European Economic Area (“EEA”). We will not transfer your personal data to international organisations.
The possible transfer of your data outside the EEA may take place both to third-countries for which the European Commission has issued an adequacy decision and to countries for which no such decision has been issued. In such a situation, the transfer of your personal data outside the EEA will take place on the basis that appropriate safeguards are provided:
- the standard contractual clauses on data protection adopted by the European Commission
- an approved certification mechanism
In the absence of an appropriate decision by the European Commission or the lack of adequate safeguards referred to above, the transfer of your personal data to a third-country may only take place provided that:
- you give your explicit consent to the transfer after we provide information on the possible risks connected to the protection of personal data, that the proposed transfer to a third-country may entail for you
- the transfer is necessary for the performance of a contract with you or the implementation of measures taken at your request prior to entering into contract
- the transfer is necessary for the conclusion or performance of a contract between us and another natural or legal person in your interest
- transmission is necessary for the establishment, exercise or defence of claims
In the absence of the relevant safeguards or grounds referred to above, your personal data will not be transferred to third countries.
CONTACT FORM
On our Website, we give you the opportunity to contact us using an electronic contact form. This requires you to provide personal data necessary for us to make contact and respond to your enquiry. Providing data marked as mandatory is necessary for us to respond to your enquiry, and failure to provide such data makes it impossible to process the enquiry. Other personal data is provided on a voluntary basis.
The purpose of processing the personal data provided to us via the contact form is to respond to your enquiry and to communicate with you. Alternatively, to provide you with information about our or the Issuers’ products and services, provided you have given your consent.
The legal bases for processing personal data submitted via the contact form are:
- the necessity of processing your personal data for the performance of a contract or to take action at your request prior to entering into such contract (Article 6(1)(b) of the GDPR)
- the pursuit of our legitimate interests to carry out direct marketing activities and to communicate with you and answer your questions (Article 6(1)(f) of the GDPR)
- your consent for processing any additional personal data that you provide (Article 6(1)(a) of the GDPR)
INFORMATION ON HOW WE GOT YOUR PERSONAL DATA
We collect most of your personal data processed by us directly from you. If you do not provide personal data directly to the Administrator, your personal data has been provided to us by an entity:
- on whose behalf you are acting
- who has provided us with your personal data as necessary to maintain an official or business relationship with that entity
- who has provided your personal data in connection with the performance of a contract with us
INFORMATION ON THE USE OF SOCIAL MEDIA PLUG-INS
We currently use the following social media plugins: Facebook, Twitter, YouTube, LinkedIn, Telegram, Instagram. In doing so, we use a so-called double-click solution.
This means that when you visit our Website, no personal user data is transmitted to the plug-in providers by default. You can recognise the plug-in provider by the box above its initial letter or logo. We provide the option of communicating directly with the plug-in provider via a button.
The plugins provided on our Website enable your internet browser to retrieve content from the providers of the aforementioned plugins and to transmit personal data to the aforementioned providers for this purpose.
Your personal data is processed by us and the providers of the above-mentioned plugins, i.e. Facebook Ireland Ltd., Twitter International Company, Google Ireland Limited, LinkedIn Ireland Unlimited Company, Telegram Messenger Inc. as co-administrators with respect to the collection of personal data and its disclosure by transmission.
Your personal data gathered for the purpose of collection and disclosure by transmission to providers of social plug-ins mentioned above is processed by us on the basis of Article 6(1)(f) of the GDPR in order to pursue our legitimate interest for optimising the advertising of Platform products and services by making them more visible on the social networks as Facebook, Instagram, Twitter, LinkedIn, Telegram, Youtube. For the processing of personal data for the purpose of collection and disclosure by transmission to providers of social plugins Facebook, Twitter, YouTube, Telegram, Instagram, LinkedIn, all provisions of this Policy apply. For the processing of your personal data by the co-administrators – providers of the above plug-ins – the principles provided for in the privacy policies of these co-administrators shall apply.
WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?
You have associated rights in connection with the processing of your personal data. Your ability to exercise the following rights depends on the legal basis for processing your personal data.
Right to access the data
You have the right to obtain confirmation from us as to whether we are processing your personal data, and if this is the case, you have the right to:
- gain access to your personal data
- receive information about the purposes of the processing of the data, the kind of personal data being processed, the recipients or categories of recipients of the data, the intended period of storage of your data or the criteria for determining that period, your rights under the GDPR, including the right to lodge a complaint with a supervisory authority, the source of that data, about automated decision-making, including profiling – if applicable, and the safeguards applied in relation to the transfer of your personal data to a third-country
- obtain a copy of your personal data
Right to rectify the data
You have the right to correct and complete the personal data you have provided. You have the right to request us to correct this data (if it is incorrect) and to complete it (if it is incomplete).
Right to erasure of the data (right to be forgotten)
If you believe that there are no grounds for us to process your personal data, you can request deletion. You have the right to request deletion of your personal data if:
- you have withdrawn your consent about processing the personal data we processed on the basis of your consent
- your personal data is no longer necessary for the purposes for which it was collected or processed
- you have objected to the use of your personal data for marketing purposes
- you have objected to the use of your personal data for reasons relating to your particular situation and there are no overriding legitimate grounds for our processing
- your personal data must be deleted in order to comply with a legal obligation under European Union or Polish law
- your personal data is being processed unlawfully
Despite your request to delete your personal data, due to filing an objection or withdrawing consent, we may retain certain personal data to the extent necessary for the purposes of establishing, asserting or defending claims. This applies in particular to Investors’ personal data including: name, surname, email address and purchase history via the Platform, which we retain for the purpose of dealing with complaints and claims relating to the use of our services.
We may also be required to continue to store your personal data by generally applicable law.
Right to restrict data processing
You have the right to request the restriction of the use of your personal data in the following cases:
- if you contest the accuracy of your personal data, in which case we will limit the use of that data for the time needed for us to check the accuracy of your data
- if the processing of your personal data is unlawful and you request for the restriction of its use instead of erasure
- if your personal data is no longer necessary for the purpose for which we collected or used it, but is needed by you to establish, exercise or defend a claim
- if you have objected to the processing of your data, in which case the restriction shall apply for the period necessary to consider whether, on account of your particular situation, the protection of your interests, rights and freedoms outweighs the interests we are pursuing by processing your personal data
Right to object on the grounds of your particular situation
If we process your personal data on the basis of our legitimate interest you have the right to object to the processing of your personal data on grounds relating to your particular situation (Article 21 (1, 4-5) of the GDPR). When lodging an objection, you should indicate the particular situation which, in your opinion, justifies the cessation of the processing of personal data covered by the objection. We will cease to process your personal data for the purpose set out above unless we can demonstrate that there are valid legitimate grounds for the processing which override your rights and freedoms, or that your data are necessary for us to establish, assert or defend claims.
Right to object to processing concerning direct marketing
If we process your personal data for direct marketing purposes, you may object at any time to the processing of your personal data for such marketing, including profiling, to the extent that the processing carried out by us is related to such direct marketing. If you exercise this right, we will immediately stop processing your personal data for this purpose.
Right to data portability
You have the right to receive from us in structurised, commonly used machine-readable format, e.g. CSV, personal data that you have provided to us and we process based on your consent or on the basis of a contract with you, and the processing itself is carried out by automated means. You may also instruct us to send this data directly to another entity, provided that this is technically possible.
Right of withdrawal of consent
If we process your personal data on the basis of your consent, you have the right to withdraw it at any time without affecting the lawfulness of the processing carried out on the basis of your consent before its withdrawal.
How to exercise your rights
You can exercise your rights as set out above by making a request:
- by sending an email to: rodo@comcreo.com
- in writing by post to our address provided above
If you make a request, we will make reasonable efforts to deal with it as soon as possible. Not all of the above rights are absolute, which means that you will not be entitled to all processing activities. For example, you may not be able to exercise your right to erasure if we are obliged to keep your personal data under laws that oblige us to do so. The only right you will always have (regardless of the basis of processing) is the right to lodge a complaint with the relevant supervisory authority if you believe that our processing of your personal data breaches the law.
Right to lodge a complaint with a supervisory authority
If you believe that we are processing your personal data unlawfully, you can lodge a complaint with the supervisory authority, the President of the Office for Personal Data Protection (Stawki Street no. 2, Warsaw, Poland 00-193). Detailed information in this regard can be found on the Website of the Office for Personal Data Protection (https://uodo.gov.pl).
HOW LONG DO WE KEEP YOUR DATA?
The storage period for your personal data depends on which category of recipients of the Policy you belong to and the type of Service provided and the purpose of its processing. We would like to emphasise that often the period for which we keep your personal data is a direct result of the law, if we process your personal data on the basis of that law. If we process your personal data on the basis of our legitimate interest, then your data will be processed for the period that allows us to pursue this interest or until you object to the processing.
On the other hand, if we process your data on the basis of your consent, we will keep it until you withdraw your consent. Insofar as the basis for processing your personal data is that it is necessary for the conclusion and performance of a contract, the data are processed until the contract expires. After this time, we keep your personal data for the period necessary to secure our claims or to defend against claims.
Please note that in addition our Website collects anonymous data on visits to our Website, such as number of visits, country, browser, time of visit, etc. We analyse the collected data using a third party solution. Currently, we use Google Analytics. This tool uses cookies and does not provide personally identifiable information.
Please read the details of the Google Analytics privacy policy.
COOKIE POLICY
WHAT ARE COOKIES?
This Website uses cookies. For technical reasons, your consent to the installation of a cookie may be required for the proper operation of certain features of the Website. A cookie is a small text file that a Website stores in the browser cache on your computer’s (or other end device’s) hard drive so that the Website can remember you. A cookie typically contains the name of a Website, the length of time the file is stored, and a value, usually a randomly generated unique number.
This helps us to provide a more efficient use of the Website. We also use an analytics tool in the form of Google Analytics, provided by Google LLC, which is a third party.
The Google Analytics tool automatically collects information about your use of our Website. If you would like to find out more about the details of Google’s use of data from websites and applications that use Google’s services you can find them at https://policies.google.com/technologies/partnersites.
How does the Website use cookies?
We process personal data via cookies for the following purposes:
- adapting the content of Website to User preferences and optimising the use of Website; in particular, data collected using cookies allow for recognition of User’s device and appropriate display of Website, adapted to individual needs
- creating statistics which help to understand how Users of the Service use other websites, which enables improving their structure and content
- memorising interactions
- conducting analytical and statistical activities
The legal basis for processing the personal data of the User of the Service is our legitimate interests to provide a high quality service and ensure the security of the service (Article 6(1)(f) of the GDPR).
Period for use of cookies
- Session cookies – remain on your device only during the usage of the Website
- Permanent cookies – remain on your device as long as they have a set lifetime or until you delete them. We do not share collected cookies with unauthorised persons and no third parties have access to cookies
DECLINE TO ACCEPT COOKIES
You can always refuse to accept cookies. Regardless of which browser you use, you have the option to disable cookies both for a specific site and for all sites you visit. Information on how to do this can be found from your browser manufacturer (Opera, Firefox, Internet Explorer, Chrome, Safari). However, if you choose to remain on the Website without disabling cookies, you consent to their collection. More information on cookies can be found at: https://wszystkoociasteczkach.pl
POLICY CHANGES
In the interest of full compliance with the law and for the highest security of your data, we reserve the right to make changes to this Policy. Changes will be made available to the Users by posting the updated Policy on the Website (to Investors within the Platform, to visitors to our Website – on the Website). Previous versions of the Policy will be posted on our Website with an indication of the date of the changes.
Last update to the Policy: 09.05.2022