This document containing the Privacy Policy (“Policy”) and the policy on using cookies on all our websites with the mountnut.pl domain, hereinafter also referred to as the “Service”, was drawn up and approved by MOUNTNUT INVESTMENT Sp. z o. o. ASI S.K.A. with its registered office in Łódź at ul. Żwirki 17, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Łódź Śródmieście in Łódź, 20th Department of the National Court Register, under the KRS number 0000897467, REGON No.: 388769027, Tax Identification Number (NIP):7272849598, (hereinafter referred to as “MOUNTNUT INVESTMENT”, “Controller” or “we”) in order to:

• Emphasise the special significance we attach to the issue of protection of the personal data of Users visiting the Service and using the Service by ensuring them security in accordance with the standard required in the 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, OJ L 119, 4.5.2016, p. 1 (hereinafter: GDPR);
• Emphasise the special significance we attach to the issue of protection of the personal data of Users visiting the Service and using the Service by ensuring the level of security at least equal to the standards determined in applicable regulations, particularly in the Act of 18 July 2002 on Rendering Electronic Services (hereinafter referred to as the “Act on Rendering Electronic Services”);
• Provide Users with information about the use of cookies in the Service, as required by the Telecommunications Act of 16 July 2004 (Journal of Laws of 171, item 1800, as amended), hereinafter referred to as the “Telecommunications Act”.

Introduction

1. The Data Controller is: MOUNTNUT INVESTMENT Sp. z o. o. ASI S.K.A. with its registered office in Łódź at ul. Żwirki 17, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Łódź Śródmieście in Łódź, 20th Department of the National Court Register, under the KRS number 0000897467, REGON No.: 388769027, Tax Identification Number (NIP):7272849598, email: tomasz.gora@homerevyou.pl, tel. 602 418 523 (hereinafter: “MOUNTNUT INVESTMENT”, “Controller” or “we”).
   All questions about your personal data and declarations of will concerning the exercising of your rights should be submitted to our Data Protection Officer – Grzegorz Polak to the email address rodo@expressisverbis.pl.
2. Why Do We Have Your Personal Data?
   We have received it from CROWDHOME Spółka z ograniczoną odpowiedzialnością with its registered office in Łódź, ul. Żwirki 17, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Łódź Śródmieście in Łódź, 20th Department of the National Court Register, under the KRS No.: 0000834344, Tax Identification Number (NIP): 7272841846, and REGON No.: 385810580, because you used the functionality of the CROWDHOME service consisting in transferring your personal data provided when registering an account in this service by this service to us. We could also receive the data directly from you when you concluded a service agreement with us, or later in connection with your further contact with us to learn our new offers or discuss joint project, or because you sent us an enquiry about one of our services.
3. The Purpose of and the Legal Basis for the Processing of Your Personal Data
   Conclusion and performance of an Agreement – the legal basis for the processing of personal data to conclude and perform an Agreement is Art. 6 sec. 1(b) of the GDPR pursuant to which the Controller can process personal data if it is necessary to perform an agreement concluded with the data subject or to undertake activities with the aim to conclude such an agreement.Contact – if you contact us via email, we will process your personal data to respond to the email sent. The basis for processing personal data in this respect is Art. 6 sec. 1(f) of the GDPR, while the legitimate interest pursued by the Controller is our communication with you.
   Compliance with obligations connected with personal data protection (such as creation of appropriate registers or exercising the rights of data subjects) – to comply with the obligations arising out of personal data protection regulations, we process personal data based on Art. 6 sec. 1(c) of the GDPR, pursuant to which the Controller can process personal data if its aim is to comply with a legal obligation to which the controller is subject.Activities connected with potential or actual claims (e.g. their determination, pursuance, or defence against them) – data processing in connection with the activities indicated is based on Art. 6 sec. 1(f) of the GDPR, pursuant to which the Controller can process personal data to pursue its legitimate interest which in this case is determination or pursuance of claims connected with the performance of the Agreement, or defence against such claims.
4. Voluntary Provision of Data
   The provision of personal data is not obligatory but completely voluntary.
   Unfortunately, if for whatever reason you do not want to provide your personal data, we will be unable to conclude an agreement with you and, in consequence, you will not be able to use the services of MOUNTNUT INVESTMENT.
5. Who Do We Make Your Personal Data Available To?
   Your personal data is used internally only in connection with the provision of the service you chose, and we transfer your personal data to: – authorised entities that process personal data on our behalf based on a concluded agreement and in performance of the Agreement concluded by you with MOUNTNUT INVESTMENT. These include in particular providers of IT, hosting, and legal services. – to the Navigator S.A. brokerage house in Warsaw, ul. Twarda 18, to maintain the register of shareholders. Moreover, the provisions of law require us to process your personal data for tax and accounting purposes.
6. Personal Data Storage Period
   Your personal data will only be stored for a period necessary to achieve individual purposes of its processing. In principle, personal data collected to conclude and perform an agreement are processed for a period necessary to fulfil the obligations arising out of the agreement, unless legal provisions, particularly accounting or tax provisions, require the Controller to process personal data longer and/or until the end of the period of limitation for claims which arises from the generally applicable regulations, depending on which of the periods is longer. The above data processing periods can be extended as required in the case of claims and proceedings, such as court proceedings, by the duration of these proceedings and their settlement.
7. What Are Your Rights?
   You have a number of rights connected with the processing of your personal data. In this section, we explain in detail these rights and how you can exercise them.
   • The right of access to personal data.
     At any time, you have the right to access information about you we process.
   • The right to rectify your personal data we have collected.
     At any time, you have the right to rectify information about you we process.
   • The right to delete your personal data we have collected and the right to restrict its processing.
     We will delete the gathered data about you after the purpose for which it was collected has been achieved.
     At any time, you have the right to request us to delete your personal data or to restrict its processing.
   • The right to object to the processing of personal data.
     If we process your personal data for the purposes of direct marketing, or if we process your personal data on account of our significant and legitimate interest or the public interest, you have the right to object to such processing at any time. In such a case we will cease processing your personal data for marketing purposes, but in other cases it may turn out that there are other reasons justifying the processing of your personal data – then we will have to reject your request. You will always be informed about the reasons for such a rejection.
   • The right to data portability.
     You have the right to request us to send you your personal data we have collected. If technically feasible, we will send your data in a commonly used format, in a manner you indicated and to the address provided.
   • The right to withdraw consent for the processing of personal data.
     If personal data is processed based on your consent, you can withdraw such consent at any time. Consent withdrawal will not render the processing of data performed before such consent withdrawal illegal.
8. Profiling. We do not use any of the information you provided for the purposes of automated decision-making, including profiling.
9. Transfer of Personal Data Outside EEA.
   We do not disclose your personal data to any entities located outside the European Economic Area or make it available to any international organisations, unless appropriate personal data protection standards are met. At the same time we would like to remind you that MOUNTNUT INVESTMENT, which you have trusted as your business partner, does not send to its Clients unnecessary aggressive spam, advertisement, or marketing materials. Therefore you can be sure that MOUNTNUT INVESTMENT does not make your personal data available to any external companies, including mostly marketing companies.

The Definition of Security

1. In MOUNTNUT INVESTMENT, data flow security is understood as:
   • Personal data confidentiality (making it impossible for third parties to access the data).
   • Information integrity (avoiding unauthorised data changes).
   • Information availability (ensuring access to the data whenever requested by the data subject).
   • Data archiving (storing the data in a place that cannot be accessed by third parties even when the data is no longer used).
   • Deletion of the data after the period determined in the agreement or by the law from the moment we cease to use them (permanent deletion from drives and servers or destroying any hard copy).

Security Procedures

1. MOUNTNUT INVESTMENT adopts adequate measures to ensure information security.
   Sensitive data (confidential data) shall mean:
   • Information about the orders fulfilled (planned, current, and historical),
   • Financial information,
   • Organisational information,
   • Access data to IT systems,
   • Personal Data,
   • Other information marked as “confidential information” or “confidential data”.
2. Protection of sensitive information about the Users of our Service is of utmost significance to use, which is why we make every effort to make you feel safe when browsing our websites. This Policy is to guarantee the Users of the Services protection of any personal data and information the Users provide to MOUNTNUT INVESTMENT via the Service as well as protection against breach of confidentiality of this data and information, and against its unauthorised use. The User is obligated to read this Policy before using the Service.
3. We would also like to note that the Service may contain links allowing the Users to get directly to other websites. MOUNTNUT INVESTMENT has no influence on the privacy policy followed by the administrators of these websites or their cookie policy, and cannot be held liable for them. Before using the resources offered by such websites, we recommend getting to know the document concerning privacy policy and the document concerning the cookie policy of these websites, if available, and in case there are no such documents, contacting the website administrator to obtain information about this.
4. Please report any problems with the Service to the email address: tomasz.gora@homerevyou.pl. We guarantee that each such report will be analysed and that we will respond to it.
5. Services restrict the collection and use of information about their Users to the necessary minimum, pursuant to Art. 5 sec. 1(c) of the GDPR. In particular, when collecting personal data via the Service, we distinguish the data that is actually necessary to provide information.
6. In order to receive an answer to an enquiry, you need to provide your full name and email address in a relevant form. When sending the contact form, the User will be asked to acknowledge the Policy. These fields are obligatory. Users’ contact details are also used to contact them whenever necessary (for example, to arrange a meeting).
7. We collect information about the way users use the Service and their IP addresses based on analysis of access logs. MOUNTNUT INVESTMENT only processes IT data generated automatically by the User’s Internet connection, browser, Internet address (e.g. IP address, time spent on a website, names of selected websites, the browsers used) and a cookie or cookies used to authenticate or identify the searcher to monitor traffic in the Service and for diagnostic and marketing studies. MOUNTNUT INVESTMENT only uses the above data for statistical purposes and it is not used for personal identification of the User. This information is used to diagnose problems with the server operation, analysis of potential security breaches, and to administer the website. We also use the IP address for statistical purposes, i.e. to collect and analyse the demographic data of website visitors (e.g. information about the region from which the connection was made). However, we assure you that this information is in no way associated (connected) by MOUNTNUT INVESTMENT with the personal data of the Users of the Service.

Cookies

1. The Services make use of cookie files (cookies). Information about the cookies used by the Services is displayed on the screen of the User’s device as soon as the User enters the Service.
2. The User can: a. give general consent to the storing of all cookies used by the Service on the device;
   b. give consent to the storing of individual types of cookies;
   c. refuse consent to the storing of cookies that are necessary for the proper operation of the Service (refusing consent to the storing of cookie files necessary for the proper operation of the Service will render using the Service impossible).
3. By acknowledging the rules of using cookies provided in the Policy the User consents to receiving offers and information adjusted to the User’s personal preferences, provided by online marketing platforms of external service providers (such as Google), based on data without any elements enabling identification, and the Google Remarketing system used by MOUNTNUT INVESTMENT. Every Google user has the right to disable personalised advertisements on http://www.google.com/settings/ads.

The Tools Used in the Service

4. The Service uses the Google Tag Manager tool to monitor the stability and efficiency of the Service. This tool analyses information about the website’s tags and data recorded in standard HTTP request logs, which is deleted fully within 14 days from the moment it is received, without collecting any other information that would allow to identify the User. More information about Google Tag Manager can be found on: https://support.google.com/tagmanager/answer/9323295?hl=pl.
5. The Service also uses a tool for analysing traffic on the Matomo website, which works based on cookies (provided that the User consented to it). Matomo makes it possible to optimise the website using completely anonymised information and prevent it from being sent to other entities.
6. In special cases, based on the information received as described above, summary statistical compilations are drawn up. They are not revealed to any third parties. They usually include information about the viewability of the service. However, we would like to emphasise that these compilations do not include any data allowing to identify (discover the identity) of a given user of the Service.
7. We would also like to inform that we may be obligated to reveal information about the IP address of a given user of the Service, if requested by authorised – pursuant to the applicable regulations – state authorities in connection with the proceedings they conduct.
8. It is possible to delete all cookies stored on the end device. In the browser settings you can enable or disable all future cookies, please note, however, that when cookies are disabled, some website contents may become unavailable. The following links provide information about managing cookies in different browsers:
   • Internet Explorer: https://support.microsoft.com/pl-pl/help/17442/windows-internet-explorer-delete-manage-cookies
   • Chrome: https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies
   • Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirectlocale=en-US&redirectslug=Enabling+and+disabling+cookies
   • Safari: https://support.apple.com/?path=Safari/5.0/en/9277.html

   MOUNTNUT INVESTMENT also uses services of third parties the list of which is constantly updated and which use cookies for the following purposes: monitoring the traffic on our websites; collecting anonymous summary statistics allowing us to understand how Users use our websites and making it possible to constantly improve our offers; determining the number of anonymous users of our websites (which is necessary to analyse the way MOUNTNUT INVESTMENT’s Service is used); controlling how often selected contents are displayed to the Users; controlling how often users select a given offer; using communication tools; and integration with a social media portal. As of the day this document was drawn up, these parties included:

   Facebook
   A service using social media plugins of Facebook.com administered by Facebook Inc., Palo Alto, CA, USA (“Facebook”). The plugins can be identified by the Facebook logo. When a User visits one of our websites containing plugins, they are inactive. They get activated when the User clicks the button saying “Facebook”. By activating plugins, the User establishes a connection with Facebook and consents to the transferring of data to Facebook. If the User is logged in on Facebook, Facebook can associate the visit to the Service with the User’s Facebook account. After clicking a specific button, relevant information is transferred directly to Facebook via the User’s browser and stored there in accordance with Facebook’s Privacy Policy. To obtain information about the scope and purpose of gathering data, its further processing and use by Facebook, User’s rights, and settings Users can change to protect their privacy, you have to read Facebook’s provisions on personal data protection. In case the User does not want Facebook to gather data about them via our website, they should log out of Facebook before visiting our website.

9. When a public network without appropriate security measures is used, personal data can be intercepted. The basic risks connected with using Internet services – including services offered by MOUNTNUT INVESTMENT via electronic access channels – include: phishing, malware, and unwanted mail – spam. These risks do not only concern computers but also portable devices such as smartphones and tablets. MOUNTNUT INVESTMENT shall not be liable for any trouble or losses being a result of the theft of personal data provided when connecting to the Service using an unprotected public network.
10. The Service content is the property of MOUNTNUT INVESTMENT. All moral rights and proprietary copyrights to any elements of the Service (text, graphic, layout etc.) are reserved.
11. MOUNTNUT INVESTMENT shall not be liable for any loss caused by or resulting from access to and use of information connected with any other webpages, websites, banner ads, and other services links to which can be found in the Service. After entering an external webpage, the User is subject to a different Privacy Policy. MOUNTNUT INVESTMENT shall not be liable for the content of personal data and information provided by the Users or the technical data gathered or collected by the administrators of other websites.

Final Provisions

The Controller has the right to update this Policy.
The Policy becomes effective on 10 November 2021.