Privacy Policy

1. General Provisions

This Privacy Policy sets out the rules for processing personal data by Anna Domeredzka Doradztwo, based in Warsaw, Poland, 00-033, ul. Górskiego 1/19, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).

2. Data Administrator

The data Administrator is Anna Domeredzka Doradztwo, based in Warsaw, Poland, 00-033, ul. Górskiego 1/19, contact: privacy@neviacapital.com.

3. Purposes and Legal Basis for Data Processing

Personal data is processed for the following purposes:

• provision of services by the company, performance of a contract, or taking actions aimed at concluding a contract (Article 6(1)(b) GDPR),
• fulfillment of legal obligations imposed on the Administrator (Article 6(1)(c) GDPR),
• the legitimate interest of the Administrator in maintaining business relationships, analyzing website visits to tailor its functionality to user preferences, as well as pursuing claims and defending against claims (Article 6(1)(f) GDPR),
• recruitment (Article 6(1)(a), (c), and (f) GDPR),
• direct marketing (Article 6(1)(f) GDPR),
• processing data based on the user’s consent in specific cases, e.g., subscription to a newsletter or the use of cookies (Article 6(1)(a) GDPR).

4. Data Recipients

Data may be transferred to entities cooperating with the Administrator, such as hosting providers, email service providers, cloud solutions, external entities providing other services on our behalf, including IT service providers, law firms, accounting firms, and other entities that provide services to the Administrator and for whom data processing is necessary to perform these services.

5. Data Retention Period

Personal data is stored for the period necessary to achieve the purposes for which it was collected, and thereafter for the period required by law or until any claims become time-barred, including:

• Contractor data – for the duration of the contract and until the limitation period for claims expires,
• Marketing data – until consent is withdrawn or an objection is raised,
• Job applicant data – for six months after the end of the recruitment process unless the applicant consents to future recruitment.

6. Rights of Data Subjects

Individuals whose data is processed have the right to:

• access their data,
• rectify their data,
• erase their data,
• restrict data processing,
• data portability,
• object to data processing,
• lodge a complaint with the President of the Personal Data Protection Office.

To exercise the above rights, please contact us via email at privacy@neviacapital.com.

7. Voluntary Provision of Data

We ensure that we process your personal data only to the extent necessary to achieve the purpose for which it was collected. Providing personal data is voluntary but necessary for the provision of services. Failure to provide data may result in the inability to conclude or perform a contract.

8. Data Security

The Administrator applies appropriate technical and organizational measures to ensure the protection of personal data against unauthorized access, loss, destruction, or unauthorized disclosure.

9. Cookies and Profiling

• The website may use cookies to ensure its proper functioning and analyze website traffic. Detailed information can be found in the Cookie Policy available on the website.
• The Administrator may use profiling for marketing purposes, such as personalizing offer content. The user has the right to object to such processing.

10. Transfer of Personal Data to Third Countries

As the Administrator uses external service providers such as Google, the User’s data may be transferred outside the European Union to third countries, such as the United States of America (USA). Personal data will only be transferred to recipients who ensure the highest level of data protection and security, for example, by implementing security mechanisms provided for under the GDPR or by applying standard contractual clauses.

11. Changes to the Privacy Policy

The Privacy Policy may be updated periodically. The current version of the document is available on the website www.neviacapital.com.

Should you have any questions regarding the processing of personal data, please contact us at privacy@neviacapital.com.