Privacy Policy

1.

The data controller (hereinafter: “Data Controller”) of personal data collected on the webpage http://acclivity.digital/ is Pocket Ideas Sp.Z.oo, established and operating in accordance with the laws of the Republic of Poland, with its registration number KRS: 0001069121, ul. Piotrkowska 116, lok. 52, Łódź, 90-006, Republic of Poland.; electronic mail address: [email protected]. Company is entered also in Polish Register of Virtual Asset Service Providers under position RDWW-1033

2.

All capitalized terms used in this Privacy Policy have the meaning defined for them in the Terms of Services https://acclivity.digital/terms-of-service/  

3.

 Users personal data is processed on the basis of

a.

article 6 (1b) 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  (“GDPR”), i.e, processing is necessary for the performance of services provided by the Company – E-Services and Service Agreement within the meaning of the Terms of Services https://acclivity.digital/terms-of-service/ virtual currencies and means of (hereinafter: “Services”). The legal basis of processing is contractual necessity.

b.

article 6 (1c) of GDPR, i. e. processing is necessary for compliance with a legal obligation to which the Data Controller is subject; i.e. the data processing is necessary in order to comply with the Data Controller’s legal obligation, such as tax obligations or obligations under Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives 2009/138/EC and 2013/36/EU; Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC (text with EEA relevance), hereinafter the ‘AML Directive’, and the Polish Act of 26 October 2017 on the Prevention of Money Laundering and Terrorism Financing, hereinafter the Polish Act of 1st March 2018 on counteracting money laundering and financing terrorism (Polish Journal of Laws 2023, item. 1124 – consolidated text) – “Polish AML Act”;

c.

article 6(1f) of GDPR, i.e.  the Data Controller’s legitimate interest including, without limitation, improving the quality of services and adapting them to the needs of the Users, interested parties and visitors, responding to your requests, making the website and the services more effective, safeguarding the security of the Controller’s website, sending out the newsletter and marketing the Controller’s own Services;

d.

article 6(1a) GDPR i.e. freely given consent for data processing  concerning a request submitted via the contact form available at https://acclivity.digital/contact-us/ or using the contact data available at https://acclivity.digital, wherein making contact with the Data Controller along with providing Personal data is treated as an expression of the required consent;

4.

E-Services and the Service Agreement are not intended for persons younger than eighteen (18) years of age. Data Controller has no intention of processing their personal data. If User is younger than 18, he or she should not use the Data Controller’s E-Services and Services and should not send any information about him or herself.

5.

Users personal data will be processed for the necessary period of time. As a rule it will be necessary period for the proper performing od Services and the fulfillment of obligations of the Data Controller resulting from applicable laws. Users has been advised the Data Controller will be entitle to process Users personal data longer if such obligation arises from the law and in order to claim or defend against claims by third parties. Depending on the scope of personal data and the purposes of their processing, they may be stored for a different period. In any case, a longer period of process of personal data is applicable.

6.

User has the right to:

a.

access his/her personal data, and learn if personal data is being processed or shared with other entities;

b.

correct the incorrect data and complete the incomplete data;

c.

demand deleting his/her data;

d.

demand limiting processing of his/her personal data,

e.

raise objections to the processing of his/her personal data,

f.

transfer his/her personal data,

7.

Users can use the above rights and obtain detailed information about them by contact with Data Controller: [email protected]

8.

Based on Users personal data, the Data Controller will not make automated decisions, including decisions resulting from profiling.

9.

The recipients of Users personal data will be only entities authorized to obtain personal data on the basis of legal provisions, i.e. a provider of accounting and banking services, a provider of technology-related services (support of Data Controller’s websites), courier service providers, and printing and delivery of correspondence mail.

10.

The Data Controller makes every effort to ensure all means of physical, technical and organizational protection of personal data against their accidental or deliberate destruction, accidental loss, alteration, unauthorized disclosure, use or access in accordance with all applicable regulations.

11.

Users personal data is processed electronically and manually, in accordance with the methods and procedures related to the processing purposes referred to in point. 2 of this clause.

12.

The Data Controller may transfer personal data to third countries, i.e. countries located outside the European Economic Area. Users data may be transferred solely to third countries or third parties which were recognised by a decision of the European Commission as offering an adequate level of data protection. The list of countries confirmed by a decision of the European Commission to offer an adequate level of protection can be found at the link. If no decision of the European Commission confirming an adequate level of protection referred to in Article 45(3) of the GDPR has been issued, Users personal data may be transferred to a third country solely on the basis of: binding corporate rules, standard data protection clauses adopted by the European Commission, standard data protection clauses adopted by a Polish supervisory authority and approved by the Commission, an approved code of conduct, or an approved certification mechanism (Article 46 of the GDPR).
If no decision of the European Commission confirming an adequate level of protection referred to in Article 45(3) of the GDPR has been issued and in the absence of the safeguards listed in Article of the 46 of the GDPR, including binding corporate rules, Company will ask Users to grant his/her express consent for a transfer to a third country or international organisation after advising Users about the possible risks of such transfer pursuant to Article 49(1)(a) of the GDPR.
In connection with the transfer of Users data outside the EEA Users may request information about safeguards used in this respect, obtain a copy of such safeguards or information about the place in which they are shared by contacting the Data Controller.

13.

The Data Controller is allowed to amend this Privacy Policy at any time. User shall be notified of any amendments by publication of an updated, modified Privacy Policy on the Data Controller’s website. It is recommended to read through the contents of the Privacy Policy regularly.