HIGH CAPITAL MANAGEMENT
 PRIVACY POLICY

Last update: November 2023

This privacy policy applies to the following situations when your data is collected:  

1. visiting our website https://highcapital.pl/ (“Website”);
2. contacting us using our email or electronic contact form available on the Website or when we contact you by email.

CONTROLLER OF YOUR DATA

The controller of your personal data is High Capital Management (“HCM”)

Our corporate details are as follows: registered office in Warsaw at Wilcza 19/37, 00-544 Warsaw,
a company entered into the registry of entrepreneurs of the National Court Register under the number (KRS): 0000947005, registry documentation is kept by the District Court for the city of Warsaw, XII Commercial Division of the National Court Register Tax Identification Number (NIP): 6342820399, share capital: 1.055.000,00 PLN, fully paid.

CONTACT DETAILS 

If you have any questions about the use of your personal data or you want to exercise your rights regarding your personal data, please contact us using:

1. e-mail address: iodo.hcm@meld.pl;
2. our address indicated in Section I above;
3. electronic contact form available on our Website.

WEBSITE

When you use our Website, we process your personal data (including IP address or other identifiers and information collected through cookies or other similar technologies) for the following purposes:

• to provide services electronically in terms of providing users with access to content collected on the Website – the legal basis for the processing in the necessity of the legal basis for the processing in the necessity of the processing for the performance of the agreement for the provision of electronic services (Article 6(1)(b) GDPR);
• for analytical and statistical purposes – the legal basis for the processing is our legitimate interest (Article 6(1)(f) GDPR), involving analysis of user’s activities, as well as their preferences to improve the functionalities used and services provided.

CONTACT

On our Website you can find an electronic contact form to contact us about any issue.

1. Using the form requires providing the personal data necessary to respond to your question (name and e-mail address). Providing your name and e-mail address is voluntary, but failure to provide this data will result in the inability to provide you with the contact form service.
2. You may also provide other data to facilitate contact with you and process the request (data provided optionally).

You can also contact us, or we can contact you via our e-mail address and postal address indicated in Section II above.

When you contact us using our contact form that you can find our Website, by e-mail, or by post or in case we contact you by e-mail or by post, we process your personal data for the following purposes:

1. to identify you as a sender to handle your request sent via the electronic contact form – the legal basis for processing is the necessity of processing to perform the service contract (Article 6(1)(b) GDPR) and in case of data provided optionally – our legitimate interest of being able to provide an answer to a request concerning our activity (Article 6(1)(f) GDPR);
2. to contact you in order to handle your request sent via e-mail or post, to contact you in connection with our contract or other arrangements, to conduct further correspondence with you – the legal basis for processing is our legitimate interest of being able to provide an answer to request concerning our activity or other contact request from your side or conclusion or performance of a contract with a person or entity you represent (Article 6(1)(f) GDPR); in case we provide you with our correspondence or answer your correspondence in connection with an agreement to be concluded or that is concluded with you – the legal basis for processing is the necessity of processing for the performance of the agreement or necessity to take steps prior to entering into such an agreement at your request (Article 6(1)(b) GDPR);
3. in case of marketing e-mail correspondence, we process you data also to promote our Products or business activity – in such a case the legal basis for processing in our legitimate interest (Article 6(1)(f) GDPR) in connection with your consent to receive such
   a correspondence (we will send you marketing information by e-mail only after you give your consent for such a mailing).

 

SOCIAL MEDIA

We may process your personal data when you visit our social media profiles like at:

On our Website and on our social media or on the other sites you can find videos about our Products and Us from YouTube. Watching these videos causes our Website to collect cookies, which may contain your personal information (as described bellow)

When you enter our social media profiles or use other content provided by us via social media, we may process your data for the following purposes:

• to maintain our social media profile, to inform you about our activities and promote various events and our Products. The legal basis for processing of your personal data for this purpose is our legitimate interest (Article 6(1)(f) GDPR) involving promoting our own brand and products.

COOKIES

We inform you also what cookies we use at our Website.

Cookies are small text files installed on the device of a user browsing the Website Cookies collect information that facilitates the use of the Website – for example, by remembering your visits to the Website and the activities performed by you.

We collect the following cookies on the Website:

 

FUNCTIONAL COOKIES

COOKIE NAME	PLACED BY	DESCRIPTION	EXPIRATION TIME
cookie_consent	HCM	This cookie is used to track users’ consent to the use of cookies on our website.	1 year
HSID	Google	Security cookie to confirm visitor authenticity, prevent fraudulent use of login data and protect user data from unauthorized access.	2 years
SIDCC	Google	Security cookie to confirm visitor authenticity, prevent fraudulent use of login data and protect visitor data from unauthorized access.	3 months
Cookie-agreed	HCM	This cookie is set when a visitor agrees to the cookie terms. This is used to not show the banner again after the visitor has consented.	3 months

 

ADVERTISING COOKIES

COOKIE NAME	PLACED BY	DESCRIPTION	EXPIRATION TIME
APISID	Google	Personalizes Google ads on websites based on recent searches and interactions.	2 years
SSID	Google	Google collects visitor information for videos hosted by YouTube on maps integrated with Google Maps.	persistent
__Secure-1PSID	Google	Targeting cookie. Used by for targeting purposes to build a profile of the website visitor’s interests to show relevant & personalized Google advertising.	2 years
__Secure-3PSIDCC	Google	Targeting cookie. Used by for targeting purposes to build a profile of the website visitor’s interests to show relevant & personalized Google advertising.	2 years
__Secure-3PAPISID	Google	Builds a profile of website visitor interests to show relevant and personalized ads through retargeting.	2 years
__Secure-3PSID	Google	Builds a profile of website visitor interests to show relevant and personalized ads through retargeting.	2 years
__Secure-1PAPISID	Google	Targeting cookie. Used by for targeting purposes to build a profile of the website visitor’s interests to show relevant & personalized Google advertising.	2 years

 

STATISTICAL COOKIES

COOKIE NAME	PLACED BY	DESCRIPTION	EXPIRATION TIME
_gac_UA-XXXYYYZZZ-1	Google Analytics	Contains campaign related information for the user. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out.	3 months
_ga	Google Analytics	This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.	2 years
_gid	Google Analytics	This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form.	1 day
__utmc	Google Analytics	The cookie is set by Google Analytics and is deleted when the user closes the browser. The cookie is not used by ga.js. The cookie is used to enable interoperability with urchin.js which is an older version of Google analytics and used in conjunction with the __utmb cookie to determine new sessions/visits.	Expires on session end
__utmz	Google Analytics	This cookie is set by Google analytics and is used to store the traffic source or campaign through which the visitor reached your site.	5 months
__utmb	Google Analytics	The cookie is set by Google Analytics. The cookie is used to determine new sessions/visits. The cookie is created when the JavaScript library executes and there are no existing __utma cookies. The cookie is updated every time data is sent to Google Analytics.	30 minutes
__utma	Google Analytics	This cookie is set by Google Analytics and is used to distinguish users and sessions. The cookie is created when the JavaScript library executes and there are no existing __utma cookies. The cookie is updated every time data is sent to Google Analytics.	2 years

The use of cookies for the purpose of collecting data through them, including gaining access to data stored on your device, requires your consent. This consent may be withdrawn at any time.

Permission is not required only for cookies, the use of which is necessary for the provision of telecommunications service (data transmission to display content).

Withdrawal of consent for the use of cookies is possible via browser settings. Detailed information on this subject can be found at the following links: 

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Opera
• Safari

You may at any time verify the status of your current privacy settings for your browser using the tool available at the link https://optout.aboutads.info/?c=2&lang=EN  

ANALYTICAL AND MARKETING TOOLS USED BY OUR PARTNERS 

We and our partners use various solutions and tools used for analytics and marketing purposes. Below you will find basic information about these tools. For more detailed information in this regard, please instead refer to the privacy policy of the respective partner. 

NEWSLETTER

If you would like to subscribe to our Newsletter, you need to provide us with your e-mail address. Providing your e-mail address is voluntary, bur failure to provide it will result in the inability to provide you with our Newsletter.

When you subscribe to our Newsletter, we process your personal data (name, e-mail address) for the following purposes:

• to provide the Newsletter to you, including to promote out Products and business activity – the legal basis for processing is our legitimate interest (Article 6(1)(f) GDPR) in connection with your consent to receive such a Newsletter;
• to create analysis and statistics – the legal basis of the processing in our legitimate interest (Article 6(1)(f) GDPR), involving conducting analyses of users’ activity on the Website to improve the applied functionalities.

GOOGLE ANALYTICS  

Google Analytics cookies are files used by Google to analyze how the user uses the Website, to create statistics and reports on the functioning of the Website. Google does not use the collected data to identify the user, nor does it combine this information to enable identification. Detailed information about the scope and principles of data collection in connection with this service can be found here.

OTHER PROCESSING PURPOSES

We may also process your personal data for the following purposes:

1. to comply with legal obligations imposed on HCM, such as provision on information and documents required by public administration authorities – the legal basis for processing is necessity to comply with a legal obligation to which the controller is subject (Article 6(1)(c) GDPR);
2. to establish or seek claims or to defense against claims – the legal basis for processing in our legitimate interest (Article 6(1)(f) GDPR) involving protection of rights.

PERIOD OF PROCESSING YOUR PERSONAL DATA

We will not use or store personal data for longer than is necessary to achieve the above-mentioned purposes and will delete the collected personal data after the expiration of the period necessary to achieve the purposes described herein or to fulfill contractual obligations or to the extent permitted or required under applicable law. The specific retention periods for personal data are indicated with each of the listed processing purposes are as follows:

1. in case we process your data to perform the agreement (e.g., to provide you with Website content, to enable you to use contact form, or to conduct e-mail correspondence connected with the contract you concluded with us) – your data will be processed for the duration of the agreement and after this period for a period no longer than the period of the possible statute of limitations for claims;
2. in case we process your data on the basis of your consent – your data will be processed no longer than necessary to realize purpose for which your consent is granted and no longer than until the moment you withdraw your consent;
3. in case we process your data to comply with our legal duties – your data will be processed not longer than the term of these legal duties;
4. in case we process your data based on our legitimate interest – your data will be processed until our interest is realized (for example for the duration of correspondence) no longer than until the moment you object to the processing of your data for such purposes. In case we process your data to establish or seek claims or to defend against claims your data will be processed for the duration of the proceedings and optional the period of limitation of claims.

SOURCE OF DATA

In general, we collect your data directly from you. However, there are situations in which we receive your data directly from a third party for the purpose of providing you support services. In this case, we receive such data as – your identification data that will allow us to contact you and the data you included in the problem report.

Also, if you are an employee or representative of our contractor, we may receive your identifying information (such as name, surname, email address, position) from him.

YOUR RIGHTS

In connection with the processing of your personal data, you have the right to:

1. object to the processing of your data, if the basis for processing is our legitimate interest in accordance with Article 6(1)(f) of the GDPR. In this case, we will no longer process this personal data, unless we prove the existence of valid, overriding, legitimate grounds for processing, or grounds for establishing, investigating, or defending claims;
2. withdraw consent to the processing of personal data (given by you) at any time. This withdrawal does not affect the compliance of the processing which was carried out based on consent before its withdrawal.

Remember that you can also at any time withdraw your consent on marketing content. In this case, we will longer process your personal data for this purpose.

1. access your personal data;
2. require us to correct your data;
3. require us to delete your data to the extent provided for by law;
4. require us to limit the processing of your data to the extent provided for by law;
5. require us to transfer your data, if the processing is carried out by automated means and if the data is processed in connection with a contract;
6. lodge a complaint with the local supervisory authority – in Poland President of the Data Protection Authority (ul. Stawki 2, 00-193 Warszawa, more information: https://uodo.gov.pl/en/484 )

RECIPIENTS OF YOUR DATA

HCM does not and will not sell personal information about our customers. We only disclose your data as authorized in this statement. We may share information with the types of third parties described below and always ensure, when sharing information, such third parties adhere to the same principles.

In respect of the data processing for the purpose specified in this Policy, the recipients of your personal data may be the following:

1. our authorized personnel, as well as the authorized personnel of our subcontractors;
2. entities services to us, i.e. operating our IT systems, website management hosting, advertising agencies, entities providing consulting, legal, debt collection, accounting and auditing services, in particular:
3. provider of our email system – Microsoft Ireland Operations Limited – if we correspond by e-mail;
4. other HCM companies and its personnel;
5. providers of social media;

We reserve the right to disclose selected information concerning you to the competent authorities of to third parties who request such information on an appropriate legal basis and in accordance with applicable law.

TRANSFER OUTSIDE EEA

The level of personal data protection outside the European Economic Area (EEA) differs from that provided by European law. For this reason, we transfer personal data outside the EEA only when necessary and with an adequate level of protection. Transfers outside the EEA occur in particular:

1. if our subcontractor is located outside the EEA – transfers are made most often under standard contractual clauses approved by the European Commission or based on a decision of the European Commission finding a sufficient level of protection of personal data in each country.

To obtain a copy of the European Commission’s decision or standard contractual clause, you can contact us using the data indicated in Section II.

SAFETY OF YOUR DATA

HCM is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure.

HCM takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction.

The servers on which your personal information is stored are kept in a controlled environment with limited access. While we take reasonable efforts to guard personal information, we knowingly collect directly from you, no security system is impenetrable.