PRIVACY POLICY

PERSONAL DATA OF CUSTOMERS AND USERS OF THE SERVICES OSDW AZYMUT SP. Z O.O.

I. WHO IS THE CONTROLLER OF PERSONAL DATA OF OSDW AZIMUTH CUSTOMERS?

The administrator of customers' personal data, i.e. the entity responsible for ensuring the security of customers' personal data (the "Administrator"), is OSDW Azymut sp. z o.o ., with its registered office in Warsaw at ul. Gottlieb Daimlera 2, 02-460 Warsaw, entered in the register of entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, XIII Economic Department of the National Court Register, under KRS No. 0000030385, NIP: 525-21-05-994, share capital/called-up capital: PLN 24,634,382.00.

II. HOW TO CONTACT US?

If you have any questions or comments about data processing, please contact us:

• At e-mail: iod@azymut.pl
• By correspondence: 2 Gottlieb Daimler Street, 02-460 Warsaw.

Request for correction or deletion of personal data should be reported to us at: iod@azymut.pl

III. HOW TO CONTACT OUR DATA PROTECTION OFFICER?

The Data Controller has appointed a Data Protection Officer, who can be contacted at the above-mentioned e-mail address or mailing address, marked "IOD".

III. WHAT DATA DO WE COLLECT AND FOR WHAT PURPOSE?

(a) Personal data of persons to whom the Administrator makes an offer

If we make you an offer, your data is processed for:

• to make an offer that you have requested from us directly or indirectly, such as by publishing an inquiry - the legal basis for the processing is the necessity of the processing to take action at the request of the data subject before entering into a contract;
• for the purpose of possible establishment, investigation or defense against claims - the legal basis for processing is the legitimate interest of protecting our rights;
• for archival, statistical and analytical purposes - the legal basis for processing is the legitimate interest of archiving submitted offers, as well as for statistical and analytical purposes.

(b) Personal data of persons who have entered into a contract with the Administrator

If you have entered into a contract with the Administrator (e.g., for us to provide marketing or logistics services), we process your data for the purpose:

• performance of the contract (including consideration of possible complaints) - the legal basis for processing is the necessity of processing to perform the contract, while in the scope of data provided optionally, the legal basis for processing is consent;
• to carry out statutory obligations incumbent on the Administrator, arising in particular from tax and accounting regulations, consisting, among other things, of the need to issue an invoice or other accounting evidence and its archiving - the legal basis for processing is a legal obligation;
• possible establishment, investigation or defense against claims - the legal basis for processing is the legitimate interest of protecting our rights;
• analysis and statistics, including conducting customer satisfaction surveys - the legal basis for processing is the legitimate interest of continuous improvement of the services we offer;

(c) Personal data of persons who have been designated as so-called contact persons in contracts to which the Administrator is a party

If you have been designated by our contractors as so-called "contact persons" or persons responsible for the performance of the contract, we process your data for the performance of the contract on the basis of our legitimate interest in the proper performance of the subject matter of the contract.

We receive your data, the scope of which most often includes your name, business e-mail address and business telephone number, from our contractors, i.e. entities with whom we contract.

The data will be processed until the object of this agreement is realized.

(d) Newsletter

For users who have provided us with their e-mail address or telephone number for this purpose, we provide newsletter services, i.e. the delivery of commercial information regarding the products or services we offer. Providing this data is voluntary, but necessary for sending the newsletter.

Personal data is processed:

• in the case of directing marketing content to you as part of a newsletter - the legal basis for processing, is the legitimate interest in connection with the consent you have given,
• for possible establishment, investigation or defense against claims - the legal basis for processing is the legitimate interest of protecting our rights;
• for analytical and statistical purposes - the legal basis for processing is the legally justified interest of conducting analysis of users' activity on the site, in order to improve the applied functionalities and improve our offer.

(e) Registration and participation in the event

In the case of people who are participants in online events for which you can sign up on our services, we inform you that your personal data will be processed for the purpose:

• to carry out the event (including confirmation of participation, contact on technical matters, handling of complaints) - the legal basis for processing is the necessity of processing to perform the contract;
• in order to identify persons authorized to participate in the event - the legal basis for processing is the legitimate interest, consisting in the proper implementation of the subject matter of the contract;
• for the purpose of possible establishment, investigation or defense against claims - the legal basis for processing is the legitimate interest of protecting our rights.

f) Data of users of social media profiles

Our profile on Facebook and LinkedIn is public. When you visit our profile, you provide us with your personal information (e.g., your account name, comments, likes, Internet IDs, and the IP address of the device you are using).

This data is processed in order to: (i) enabling us to effectively run our profile in connection with our promotion of various events, services and products and (ii) communicating with users. The legal basis for the processing of personal data is our legitimate interest in promoting our brand, improving the quality of our services and ongoing communication with fanpage users. We also process data for the purpose of claiming and defending against claims.

NOTE: the above information does not apply to the processing of your personal data by the Facebook administrator.

g) Creating an account on the Website

If you create an account on the Virtual Warehouse website, you are asked to provide the necessary data for the operation of the account and orders placed, i.e. e-mail address, name, phone number, payer and shipping data.

Provision of data marked as mandatory is necessary to set up an account and their failure to do so will result in the inability to set up an account with Virtual Warehouse. Provision of other data is optional.

Personal data is processed:

in order to provide services related to the maintenance and operation of an account on the Website - the legal basis for processing is the necessity of processing to perform the contract, while in the scope of data provided optionally - the legal basis for processing is consent;

• in order to provide services related to the maintenance and operation of an account on the Website - the legal basis for processing is the necessity of processing to perform the contract, while in the scope of data provided optionally - the legal basis for processing is consent;
• for the purpose of possible establishment, investigation or defense against claims - the legal basis for processing is the legitimate interest of protecting our rights;
• for analytical and statistical purposes - the legal basis for processing is the legally justified interest, consisting in conducting analyses of Users' activity on the Website and the way they use their account, as well as their preferences, in order to improve the functionalities used.

(h) Personal data of others

In connection with our business, we may process the personal data of others, for example, people who contact us via e-mail or people who are our potential subcontractors.

In this case, we only process data that you have provided to us yourself or that we have obtained from publicly available sources in connection with your business.

We process this data for purposes arising from our legitimate interests, which include responding to inquiries or seeking subcontractors.

IV. HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

The period of data processing depends on the type of service provided and the purpose of processing. As a rule, data are processed:

• for the time necessary to perform the contract and make settlements;
• Until an effective objection is raised, or
• Until the data is successfully requested to be deleted.

The period of data processing may be extended in case the processing is necessary for the establishment, investigation or defense against possible claims, and thereafter, only if and to the extent required by law. For example, data contained in documents constituting tax evidence may be kept for a period of 5 years from the end of the year in which they were issued, in connection with the obligation to archive such documents.

V. WHAT RIGHTS DO USERS HAVE?

We guarantee the realization of all the rights of those whose data we process, including the law:

SHOULD YOU WISH TO EXERCISE YOUR RIGHTS, PLEASE CONTACT US IN THE FIRST INSTANCE.

VI. TO WHOM DO WE SHARE THE PERSONAL INFORMATION YOU GIVE US?

Personal data on the basis of an appropriate agreement may be transferred to entities that process data on behalf of the Administrator, including but not limited to IT service providers, marketing agencies, customer satisfaction survey companies, etc. Such entities shall process the data only in accordance with our instructions, while maintaining its confidentiality and security. We have the right to control how the data entrusted by you are processed.

In other cases, personal data may be disclosed to entities authorized only by law.

VII. TRANSFER OF DATA OUTSIDE THE EEA AREA

We do not transfer Users' personal data outside the EEA, subject to data from social media plug-ins, as stated in Section X. SOCIAL MEDIA.

VIII. PROFILING

Personal data of persons using our service may be processed, if separate consent is given, in an automated manner, i.e. in the form of profiling. The consequence of profiling is the assignment of a profile to a given person in order to make decisions concerning him or her, or to analyze or predict his or her preferences, behavior and attitudes.

Based on profiling, we perform analyses that result in:

• Optimization of the site (including appearance, content, offers), in terms of user preferences:
• Recommending service content consistent with the activity profile;
• The broadcast of advertisements targeting designated audiences.

These data are not processed for automated decision-making, which could affect your rights.

IX. COOKIE POLICY

The website uses so-called cookies. These are small text files placed on users' devices (e.g. computers) via web browsers. These files allow certain information to be stored on the User's device and then read by the service that created the files. Cookies usually contain, in addition to the domain name of the website from which they originate, the time they are stored on the end device and a unique number.

Cookies are used by us for:

• Matching the content of websites to individual user preferences and optimizing the use of websites by the user, (cookies allow, in particular, to recognize the device of the user of the website and the appropriate display of the website, so that it is best adapted to his individual needs);
• maintain the session of the website user after logging in (this is extremely useful for the user, as it prevents the need to log in again (enter login and password) on each subsequent subpage of the website);
• to create statistics (so that we can better understand how users of our website use the websites, and consequently we can improve the structure and content of these pages);
• To provide users with advertising content that corresponds to their individual preferences.

The service does not store any information about the computer's hardware configuration or programs installed on the user's computer.

Changing cookie settings

Usually, the user's web browser allows cookies to be stored on the user's terminal device by default. However, at any time, website users have the ability and right to change their cookie settings. To change the cookie settings, users should refer to the detailed information on the possibilities and ways of handling cookies, which are available in the settings of their web browser.

If you do not agree to the placement of cookies on your device, you can block their placement by configuring your web browser accordingly. He will find information on how to do this in the help files of his web browser. Unfortunately, if you block cookies from the website, we cannot guarantee its correct operation. If you do not change your cookie settings, the files will be placed on your terminal device. This means that we will store information on your end device and access this information.

X. SOCIAL MEDIA

The services use plug-ins and other social tools provided by social networks, such as Facebook.

In connection with the use of a site that contains such a plug-in, the user's browser establishes a direct connection to the servers of the administrators of social networks (service providers). The content of the plug-in is transmitted by the respective service provider directly to the user's browser and integrated into the site. Thanks to this integration, the service providers receive information that the user's browser has displayed the site, even if the user does not have a profile with the service provider or is not currently logged in with it. Such information (along with the IP address) is sent by the user's browser directly to the service provider's server(some servers are located in the US) and stored there.

If the user has logged into one of the social networks, then this service provider will be able to directly attribute the site visit to the user's profile on the respective social network. If the user uses a particular plug-in, such as the "Like" button, then the corresponding information will also be sent directly to the server of the respective service provider and stored there. In addition, this information will be published on the respective social network and will appear to the people added as contacts of the user.

The purpose and scope of data collection and its further processing and use by service providers, as well as the possibility of contact and user rights in this regard and the possibility of making settings to ensure user privacy are described in the privacy policies of individual service providers.

Facebook - https://www.facebook.com/privacy/explanation

Twitter - https://twitter.com/en/privacy

Pinterest - https://policy.pinterest.com/en/privacy-policy

If a user does not want social networks to attribute data collected during a visit to a site directly to his or her profile on that site, it is necessary to log out of that site before visiting it. It is also possible to prevent plug-ins from loading on the site altogether by using appropriate extensions for the user's browser, such as blocking scripts.

XI. TOOLS OF OUR PARTNERS

In order for us to provide our services and improve and analyze them, we also rely on the services and tools of other entities. These entities only carry out the purposes specified by us. Below is information about our partners and the tools they use.

Google Analytics

On the Website, we use the Google Analytics tool provided by Google Inc.(Google), based in the United States. As part of this feature, we use cookies to acquire and analyze information regarding, among other things, the number of pages visited, the effectiveness of our marketing campaigns or the time spent on the Service. We use this information only to improve the quality of the Service.

Facebook Pixel

We use the Facebook Pixel tool to measure the effectiveness of advertising our services via the Facebook platform and to optimize our ads that appear there. We use Pixel data to, among other things: (i) broadcasting ads to the right audience, (ii) creating groups of ad audiences, (iii) analyzing what happened as a result of clicking on an ad, (iv) using other Facebook advertising tools.

XII.CHANGES TO PRIVACY POLICY

The policy is reviewed on an ongoing basis and updated as necessary. The current version of the policy has been adopted and is effective as of February 1, 2022.