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Privacy Policy

PRIVACY POLICY

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (general data protection regulation – hereinafter referred to as “GDPR”), as well as other applicable laws and regulations, we hereby present the following information concerning the principles governing the processing of your personal data.

The protection of private information relating to users of tequity.xyz (“Website”) is of utmost importance to us. Accordingly, we make conscious efforts to ensure the safety of your data.

Please take the time to read this document (hereinafter the “Privacy Policy”), which is intended to explain how we handle your personal data when you visit the Website. By accessing the Website, you acknowledge that you have read this Privacy Policy.

This Privacy Policy is intended to comply with applicable data protection laws and regulations. The rights available to Users may vary depending on their country or state of residence and the applicable legal framework. Users may be entitled to additional rights under applicable law. In certain jurisdictions, privacy rights may depend on the legal classification of the individual under applicable law.

DEFINITIONS

In this Policy, the following terms shall have the meanings set forth below:

“Privacy Policy” or “Policy” means this document, entitled “Privacy Policy.”

“Controller”, “we”, or “us” means Cloudtech sp. z o.o., a company incorporated under the laws of Poland, whose registered office is situated at Aleksandra Lubomirskiego 20 31-509 Kraków Poland, entered into the register of entrepreneurs by the district court for Kraków-Śródmieście in Kraków, XI Commercial Division under no: 0000899953, NIP: 6751750963, REGON: 38890473200000, share capital: 5400,00 PLN.

“User” or “you” means a natural person (individual), who has used the Website by browsing the Website or submitting personal data through the Contact form.

“Contact Form” means an interactive electronic form available at the Website, through which the User may send an inquiry or message to us, providing the following data: first and last name, company name, e‑mail address, subject of inquiry, and the message or inquiry itself.

  1. INTRODUCTION
  1. The Website is operated by us, and we are the Controller of your personal data we process in connection with your use of the Website within the meaning of the GDPR.
  2. The Website may contain external links to websites, plugins, or applications operated by third parties. Clicking such links or permitting connection results in transmission of your data (e.g., IP address and browser identifier) to that site’s controller, who thereby becomes a controller of your personal data in that context. Upon leaving the Website, we encourage you to review the privacy policies of any external sites you visit.
  3. By using the Website, the User confirms that they have read and understood this Privacy Policy.
  1. COOKIES
  1. The Website uses “cookies.” Upon the User’s first visit to the Website, a notification regarding the use of cookies is displayed. This notification remains visible until the User provides consent via the designated acceptance button.
  2. By clicking the button labeled accordingly (e.g., “Accept Cookies”), the User consents to the use of cookies. Consent applies only to non-essential cookies and can be withdrawn at any time.
  3. Detailed information concerning cookies – including their definition and how they are used by the Website – is available to the User by clicking the “Cookie Policy” link, which appears alongside the cookie notification. The full Cookie Policy can also be accessed at any time via the “Cookie Policy” section at the Website.
  1. YOUR DATA
  1. “Personal data” means any information relating to an identified or identifiable individual. Information that has been anonymized in such a way that the individual cannot be identified or re-identified does not qualify as personal data.
  2. Your personal data will be processed lawfully, fairly, and transparently, in accordance with the principles of accuracy, data minimization, and purpose limitation.
  3. The Website does not collect or process personal data for the purpose of transferring or selling it to external entities for marketing purposes.
  4. We may collect, process, store, and transfer different categories of personal data, grouped as follows:
  • Identity Data: name, surname, or similar identifier.
  • Contact Data: email address.
  • Technical Data: IP address, login data, browser type and version, time zone and location settings, browser plugin types and versions, operating system, and information concerning other technologies used by your devices to access the Website.
  • Usage Data: information about how you use the Website and which services you access.
  • Marketing and Communication Data: your preferences regarding receiving marketing information and communications from us.
  1. Depending on how you interact with our Website you interact with, we may process different categories of personal data for different purposes.
  2. When you use the Website, Technical Data may be collected automatically via cookies and other technologies, in accordance with the Cookie Policy.
  1. PURPOSE AND LEGAL BASIS FOR PROCESSING YOUR DATA
  1. When you provide us with your personal data, it will be processed for the purposes described below, in accordance with applicable data protection laws.
  2. The table below outlines the purposes/activities of personal data processing, the categories of data involved. Under GDPR, each processing activity must be based on an appropriate legal basis.Relevant legal bases under Article 6 of GDPR are also provided.

Purpose / Activity

Categories of Personal Data

Legal Basis

Management and security of the Website (diagnostics, maintenance, analytics, testing, server and hosting management)

Identity Data

Contact Data

Technical Data

Legitimate interest of the Controller (business operation, IT management, ensuring security and proper functioning, fraud prevention) (Art. 6(1)(f) GDPR)

Ensuring appropriate content and advertisements on the Website, and analyzing advertising effectiveness

Account Data

Usage Data

Marketing & Communication Data

Technical Data

Consent obtained via cookie banner where required under applicable law (Art. 6(1)(a) GDPR)

Responding to User inquiries via Contact Form, providing order details, or resolving technical issues on the Website

Contact Data

Identity Data

Legitimate interest of the Controller (Art. 6(1)(f) GDPR)

Transmission of data to operators of external websites, plugins, or applications linked from the Website

Technical Data

Based on the User’s interaction with the Website (e.g. clicking external links); where applicable, consent obtained via cookie banner (Art. 6(1)(a) GDPR)
  1. Provision of personal data is voluntary. However, certain data is necessary to enter into and perform the Services or to use specific functionalities of the Website.
  2. We may use your personal data to create user profiles in order to personalize content and offers. This involves analyzing your activity on the Website (e.g., visited pages, interactions, or purchase history) and may constitute automated decision making within the meaning of GDPR. This profiling does not produce legal consequences or similarly significant effects on the User.
  1. DATA DISCLOSURE AND TRANSFERS

In connection with the purposes described in the preceding section, we may disclose your personal data to external third parties where permitted under applicable law, including in particular payment processors, marketing agencies, accounting and IT service providers (including hosting and cloud computing), social media platforms, as well as to the Polish Tax Office and other public authorities within the Republic of Poland.

  1. We do not sell your personal data in the traditional sense (i.e., for monetary consideration). However, due to our use of certain analytics and advertising tools (e.g., Google Analytics, Google Ads, Meta Pixel), we may disclose limited data (such as online identifiers and device information) to third parties, which may be considered a “sale” or “sharing for cross-context behavioral advertising purposes” under certain US privacy laws.
  2. We require the recipients of your data to implement appropriate security measures and to process personal data in accordance with applicable law. Where such entities act as processors, they process personal data only on our behalf and in accordance with our instructions. In certain cases, third parties may act as independent controllers (e.g., social media platforms or analytics providers). In such cases, they process personal data  in accordance with their own privacy policies and are independently responsible for such processing.
  3. Information for EU Users in connection with data transfers outside EEA. To the extent we rely on external processing entities, your personal data may be transferred outside the EEA. In such cases, we ensure a comparable level of protection by applying at least one of the following safeguards:
  • Transfer to countries deemed “adequate” by the European Commission, meaning they provide a level of data protection essentially equivalent to that of the EEA.
  • Transfer under Standard Contractual Clauses (SCCs) approved by the European Commission, which legally bind the recipient to protect personal data to EU standards.

Your data may also be transferred to entities certified under the EU-US Data Privacy Framework.

  1. Further information about the safeguards applied in connection with international data transfers may be obtained by contacting us.
  1. DATA SECURITY
  1. We process Users’ personal data in compliance with applicable data protection laws and implements appropriate security measures to protect such data.
  2. We have implemented appropriate technical and organisational measures, taking into account the nature, scope, context and purposes of processing, as well as the risks to individuals, to protect your data against accidental loss, unauthorised access, misuse, alteration, or disclosure.
  3. Access to your personal data is limited to employees, service providers, and third parties for whom such access is essential for carrying out our business activities. Such persons process your personal data only on the Organizer’s instructions and are bound by confidentiality obligations.
  4. We have adopted adequate procedures for responding to suspected personal data breaches. In the event of a breach, we will notify both you and the competent supervisory authority where we are legally obliged to do so.
  5. Despite the measures we implement, no method of transmission over the internet or electronic storage is completely secure. Therefore, we cannot guarantee absolute security of your personal data.
  1. DATA RETENTION
  1. Your personal data will be retained no longer than necessary to fulfill the purposes for which it was collected (i.e., for the duration necessary to perform the Agreement), unless a longer retention period is required to comply with applicable law, or is necessary for the establishment, exercise, or defense of legal claims under civil law.
  2. Data obtained via the contact form on the Website will be stored for the duration of the correspondence and afterwards for the period justified by our legitimate interests (e.g. case history analysis or lead management purposes, typically no longer than 6 – 12 months).
  3. Information about your device, browser, and technical environment will be retained for as long as necessary for the purposes of security, analytics, and the proper functioning of the Website – typically, this period does not exceed 12 months (this includes persistent cookies). Some cookies (session cookies) are automatically deleted when you close your browser.
  4. In specific cases, we may anonymize your personal data – rendering it permanently non-identifiable – for internal research or statistical purposes. Anonymized data may be stored indefinitely without further notification to you.
  1. YOUR RIGHTS
  1. In certain situations, you have the right to request information whether we process your personal data and to request access to your personal data (or “right to know” as understood under certain privacy laws), including information about the categories of data we collect, the purposes of processing, and the recipients of such data. You may also request correction of your personal data, restriction of processing, or deletion of your personal data processed by the Organizer. Further, you have the right to object to the processing of your personal data.
  2. Please note that we may not always be able to fulfill your request to delete your personal data, particularly due to specific legal obligations or the necessity to pursue claims. In such cases, we will inform you after receiving such a request.
  3. Where the processing of your personal data is based on your consent, you have the right to withdraw your consent to the processing of personal data at any time by sending a message to the following email: legal@tequity.ventures. Moreover, it does not affect the lawfulness of processing based on consent before its withdrawal. This means that the withdrawal of consent applies to the future, not to the processing of data that occurred in the past, during the period between granting and withdrawing consent.
  4. You have the right to request the Organizer to transfer your personal data that the Organizer administers to another data controller, provided that technical and organizational requirements allow for the transfer of such personal data (right to data portability).
  5. The Organizer will promptly – within one month of receiving the request – provide the User who submitted one of the requests mentioned in this paragraph with information about the actions taken in connection with the request, or about any extension of the deadline due to the nature of the request or the number of requests, or about the reasons for not taking action and the possibility of filing a complaint with the supervisory authority and seeking legal remedies before a court.
  6. Exercising the rights outlined above is free of charge; however, the Organizer may charge the User a reasonable fee if the request or requests are manifestly unfounded, repetitive, or excessive. In such cases, we may also refuse to comply with the presented request.
  7. To fulfill individual requests, the Organizer may require specific information from the User to verify their identity and ensure the exercise of individual rights. This serves as a security measure to ensure that personal data is not disclosed to unauthorized persons.
  8. The User whose personal data is processed by us has the right to file a complaint with the supervisory authority, particularly – if they believe the processing infringes upon GDPR – in the EU Member State:
  1. of their habitual residence,
  2. of their place of work, or
  3. of the place of the alleged infringement.
  1. To exercise the rights listed above, please e-mail us at legal@tequity.ventures.
  1. ADDITIONAL INFORMATION FOR US RESIDENTS
  1. If you are a US resident, depending on your state of residence, you may be entitled to different and/or additional rights under applicable privacy laws, including:
    1. the right to opt out of the sale or sharing of your personal data, including for targeted advertising purposes;
    2. the right to opt out of certain forms of profiling, including use of your data for the purposes of targeted advertising (where applicable);
    3. the right not to be discriminated against for exercising your rights;
    4. the right to appeal a decision we make regarding your request (where applicable under state law).
  2. To exercise these rights, please contact us at:  legal@tequity.ventures.
  1. GENERAL
  1. This Privacy Policy is effective as of the date of its publication.
  2. The Organizer may update this Privacy Policy from time to time, in particular to reflect changes in applicable law, processing practices, or the functionalities of the Website. Any significant changes to this Policy will be communicated by posting an appropriate notice on the Website and, where appropriate, by other means of communication.
  3. The updated version of the Privacy Policy will be effective from the date of its publication.
  4. For more information on processing of your personal data or related matters, please contact us at:  legal@tequity.ventures.