1. INTRODUCTION

    1. Data Processing

      By providing any personal or identification data to Investing Town, the User agrees to include such data in the Investing Town collection and to process them for the purpose of performing specific tasks, under the provisions hereof. Investing Town processes or may process Users' personal data, in accordance with the data provided, including in particular identification and contact data. The data Controller is Investing Town (referred to hereinafter as “the Controller”). The contact with the Controller is available at: office@investing-town.com.

      The Controller processes personal data in accordance with the requirements of applicable law. The User is liable for providing false personal data. By accepting the Privacy Policy, the User agrees to terms and conditions of collecting, processing and securing personal data regarding the use of the Website.

    2. Respect for Privacy

      The Controller makes every effort to ensure that personal data are processed with the greatest respect for the privacy of the data provider and with the utmost care for the security of the processed personal data, and in particular ensures to take all legal measures to safeguard the personal data collections.

    3. Protection Measures

      The Controller represents to apply technical and organizational measures to ensure protection of processed personal data appropriate for the risks and a category of protected data, and in particular to protect data against unauthorized sharing, processing as a violation of law and against their loss, damage or destruction.

    4. Processing Scope and Purpose

      The Controller processes personal data of the User with the purpose of:

      1)   fulfilling legal duties of Investing Town;
      2)   marketing and advertising services, as well as sending commercial information;
      3)   using ICT end devices and automatic trigger systems - for marketing purposes;

    5. Data Profiling

      Processing personal data includes profiling the Users according to their behavior, interests, credibility and preferences (including purchase preferences). Based on profiling, a specific content is conveyed to the Users, which potentially may interest them.

    6. Data Sharing

      To fulfill obligations, the Controller may disclose collected personal data with the entities including: employees, associates, delivery service, payment system operators, entities providing operating, legal, accounting and IT services for Investing Town, as well as entities personally or financially associated with Investing Town. In such cases the volume of disclosed information is limited to necessary minimum each time.

    7. Traffic Analysis

      The Controller represents that it is allowed to use tools designed to analyze traffic within the Website such as e.g., Google Analytics. In particular, the Controller has the right to collect information on the User's activity and behavior. The Controller uses the data to research the market and traffic on the Website, as well as to create statistics, in particular, to assess the interest in the posted content, as well as to improve the Website and fulfill obligations in the scope of counteracting money laundering and terrorist financing. The collected data shall be processed in an anonymous manner and used only for statistical purposes or to ensure proper use of the Website.

    8. Traffic Analysis

      The Controller shall comply with the following rules for the processing of personal data:

      1)   recording collected personal data only on such storage media that are protected against third party access;
      2)   reporting collections of personal data or appointing persons who shall perform the required duties as such;
      3)   performing personal data security surveillance throughout the whole term during which they are possessed to ensure in particular protection against unauthorized access, damage, destruction or loss;
      4)   sharing personal data to competent authorities under applicable law;
      5)   preserving the confidentiality of personal data.
      The personal data processed by the Controller are not shared in a form that allows User identification of any kind, unless the User has given a consent or if the obligation to disclose such information is based on applicable law.

    9. User Rights

      The Controller ensures that the applied rules of processing personal data comply with Users' rights under the applicable law, in particular the right to access, correct, update, remove, limit processing, transfer own data, to object, to withdraw the consent, to complain to the supervisory authority.

  2. COOKIES POLICY

    1. Cookies Types

      In terms of the Website functioning, the Controller is allowed to use the following types of Cookies:

      1)   temporary, which are removed after leaving the Website or after turning a web browser off;
      2)   permanent that are stored on the User's end device for unspecified period of time, or until the User manually deletes them;
      3)   statistical to track traffic on the Website;
      4)   functional, allowing personalization of the site in relation to the User;
      5)   advertising, which allow to provide the User with the content adjusted to his/her personal preferences;
      6)   obligatory and safety, which regard safety keeping rules within the Website and authentication rules.

    2. Purposes of Using

      The Controller uses Cookies for the following purposes:

      1)   optimization and increase in efficiency in terms of Investing Town activity;
      2)   correct feature configuration available within the Website;
      3)   personalizing displayed contents and adjust advertisements on the Website;
      4)   keeping safety and reliability of the Website;
      5)   collecting and using general and publicly available statical data through analytical tools.

    3. Purposes of Using

      To ensure the highest quality, Cookies are analyzed by the Controller to determine which subpages are visited the most, which browsers are used by visitors and whether the Website structure is free of errors.

    4. Cookies Configuration

      Cookies stored on the User's end device may be used by other entities that affect the quality via the Website. The User may change own Cookie settings at any time by specifying the conditions of storing and granting access to Cookies on the User's device. The User is allowed to change the settings referred hereinabove by using the settings of the web browser or by configuring a service or services. These settings may be changed in a way to block automatic Cookies activity in a web browser or to inform the User of placing a Cookie on the User's device.

    5. User's Rights

      The User is allowed to remove Cookies at any time by using the settings available in the used web browser. Restricting or blocking Cookies via the web browser shall not make it impossible for the User to browse the content posted via the Website, however, this may cause difficulties or irregularities in the Website operation. It is recommended to use software that enables Cookies operation.

  3. ADDITIONAL PROVISIONS

    1. Technical Requirements

      To use the Website, the User shall meet the following technical requirements:

      1)   having a device enabling the use of the Internet;
      2)   the Internet connection;
      3)   having a browser that allows to display websites, e.g., Google Chrome.

      Investing Town represents that it makes every effort to ensure constant access to the Website, however, it does not guarantee that the use of the Website is free of errors and technical breaks. In addition, Investing Town reserves the right to change the above minimum requirements for using the Website at any time without prior notice to the User.

      Investing Town shall ensure the operation of the ICT system in a form of the Website, in such a way as to prevent unauthorized access to the content, in particular using cryptographic techniques.

    2. Copyright and intellectual property

      All rights to the Platform, including copyrights to the Platform, as well as to its respective parts, in particular to the text, graphics, multimedia and programming elements, including industrial property rights and any other derivative rights, with the exception of content provided by payment operators, belong to Investing Town.

      Upon use of the Platform and acceptance of the Terms and Conditions by the User, Investing Town grants the User a non-exclusive license to use the Platform. The license is non-transferable and is granted for the duration of the User's use of the Platform for its intended purpose and in accordance with the Terms and Conditions. The non-exclusive license granted to the User does not entitle the User to grant any further licenses. Transfer of the content of the Website to third parties is permitted only with the use of tools contained in the Website and intended for this purpose.

      The User is not authorized to reproduce, sell or otherwise market or distribute the source code of the Platform, in whole or in part, in particular to transmit or make it available in computer systems and networks, mobile application distribution systems or any other ICT systems.

    3. Technical Breaks

      Investing Town reserves the right to temporarily or permanently terminate or limit activity of the Website. In particular, Investing Town entitled to conduct maintenance work of the Website to restore security and stability of the ICT system. Accordingly, the User acknowledges and accepts that he/she has no claims regarding such interruptions or restrictions of access to the Website.

    4. Other Websites of Third Parties

      Investing Town exercises due diligence to specify unambiguously and identify pages and websites managed by third parties that offer separate services or a service, not related to the activities of Investing Town, pursuant hereto. However, Investing Town is not liable for the content, subject and the relationship established with another entity by the User. In such a situation, the User should each time exercise due diligence to determine with which entity the possible relationship is being established and to which website of the third party the User has been redirected using the Website.

  4. FINAL PROVISIONS

    1. Terms and Conditions Enters into Force

      The Terms and Conditions shall enter into force on April 30, 2022. Investing Town has the right to amend hereto at any time.

    2. Additions and Information Included Herein

      No legal basis or incompleteness of any of the provisions contained herein does not mean that the entire Terms and Conditions is legally void. Such provisions shall be amended to the ones that best reflect their meaning and purpose.

    3. Transformation or Transfer of Rights

      The User acknowledges and accepts that the Investing Town may transfer the rights and obligations resulting from the implementation of the provisions hereof to another entity, person or third parties, including transferring the rights and obligations to another, newly established company as a result of the transformation.

    4. Disputes

      All parties to the disputes that may arise in connection herewith shall be settled amicably in the first place, by mutual arrangements between the User and Investing Town. The User acknowledges and accepts that the amicable resolution of a dispute procedure is a condition precedent that shall be met prior to commencing any legal proceedings. In such a situation, the User is obliged to contact Investing Town pursuant to paragraph 5 hereof.

      If the above provisions are met, as well as in the absence of an amicable solution to the dispute, the provisions hereof shall be settled by the court competent for the current place of a registered office of Investing Town. At the same time, the User acknowledges and accepts that disputes arising herefrom may only be considered on the basis of an individual case of the User. In no way is Investing Town obliged to settle disputes as collective cases or collective actions.