Privacy Policy

1. This Privacy Policy sets out the rules for the processing of personal data obtained through the (www.cointester.com) website (hereinafter: the "Website").

2. The owner of the Website and, at the same time, data administrator is Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ based in Włocławek 87-800, ul. Duninowska 9, NIP 8883158286, KRS0000997001 hereinafter referred to as Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ

3. Personal data collected by Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ via the Website shall be processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), also referred to as GDPR.

4. Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ takes particular care to respect the privacy of Users visiting the Website.

§ 1 Type of data processed, purposes and legal basis

1. Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ. collects information on natural persons, natural persons conducting a business or professional activity on their own behalf and natural persons representing legal persons or organisational entities which are not legal persons and to which the law confers legal capacity, hereinafter collectively referred to as Users.

2. Users' personal data are collected in the case of:

a) registration of an account on the Application, in order to create and manage an individual account. Legal basis: necessary for the performance of the contract for the provision of the Account service (Article 6(1)(b) GDPR);

b) placing an order in the Application, for the purpose of fulfilling the sales contract. Legal basis: necessary for the performance of the sales contract (Article 6(1)(b) GDPR);

c) subscription to a newsletter (Newsletter), for the purpose of performing a contract the subject of which is a service provided electronically. Legal basis - consent of the data subject for the performance of the contract for the Newsletter service (Art. 6(1)(a) GDPR);

d) the use of the contact form service on the Application for the performance of the contract provided electronically. Legal basis: necessary for the performance of the contract for the provision of the contact form service (Article 6(1)(b) GDPR);

3. When placing an order in the Application, the User provides the following data:

e-mail address;

address details;

postal code and town;

street with house/apartment number;

name and surname

telephone number.

In the case of a purchase in the name of another individual, the following details of that individual will also be provided:

e-mail address;

address details;

postal code and town;

street with house/apartment number;

name and surname

telephone number.

4. In the case of Entrepreneurs, the above scope of data is further extended by:

the business name of the Entrepreneur;

the VAT number.

5. When using the Newsletter service, the User only provides his/her e- mail address

6. When using the contact form service, the User provides the following data:

e-mail address;

name and surname;

telephone number.

7. When creating an account on the Application, the User provides his/her e-mail address.

8. When using the Application, additional information may be collected, in particular: the IP address assigned to your computer or the external IP address of your Internet provider, domain name, browser type, access time, operating system type.

9. When using the Application, audio samples (no longer than 10 seconds) are taken for coin verification. The sound recording starts only when the User presses the "Start" button located on one of the screens of the Application. The Application does not record sounds in the background or without the User's knowledge and express consent. By accepting this privacy policy and clicking the "Start" button, the User consents to the recording of sound by his/her device and agrees to have it analysed by an external service.

10. navigational data may also be collected from Users, including information about the links and references they choose to click on or other actions they take on our Application. Legal basis - legitimate interest (Article 6(1)(f) GDPR) to facilitate the use of electronically provided services and to improve the functionality of these services.

11. For the purpose of establishing, investigating and enforcing claims, certain personal data provided by the User within the framework of the use of the functionalities in the Application may be processed, such as: name, surname, data on the use of the services, if the claims arise from the way the User uses the services, other data necessary to prove the existence of the claim, including the extent of the damage suffered. Legal basis - legitimate interest (Article 6(1)(f) GDPR) to establish, assert and enforce claims and to defend against claims in proceedings before courts and other state authorities.

12. The provision of personal data to Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ is voluntary, in connection with the conclusion of sales agreements or the provision of services through the Application, with the proviso, however, that failure to provide the data specified in the forms in the Registration process prevents the Registration and creation of a User Account, and in the case of placing an order without the Registration of a User Account, it will prevent the submission and fulfilment of the User's order.

§ 2 To whom are the data made available or entrusted and how long are they stored?

1. Your personal data is transmitted to the service providers used by Growth & Value SPÓŁKA Z OGRONICZONĄ ODPOWIEDZIALNOŚCIĄ within the Application. The service providers to whom your personal data are transferred, depending on the contractual arrangements and circumstances, are either subject to the instructions of Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ as to the purposes and means of processing such data (processors) or determine the purposes and means of processing themselves (controllers).

Processors. Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ uses suppliers who process personal data exclusively on the instructions of Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ These include, among others, suppliers providing accounting services, systems for analysing traffic on the Application, systems for analysing the effectiveness of marketing campaigns, systems for logging into the Application, systems for analysing data sent by the Application.

Administrators. Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ uses suppliers that do not act solely on instructions and determine themselves the purposes and uses of Users' personal data. They provide electronic payment and banking services.

2. Location. The service providers are mainly based in Poland and other countries in the European Economic Area (EEA).

3. Users' personal data is stored:

a) If the basis for the processing of personal data is consent, then the User's personal data are processed by Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ for as long as the consent is not revoked, and after revoking the consent for a period of time corresponding to the limitation period for claims that Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ may raise and that may be incurred against it. Unless a special provision provides otherwise, the limitation period shall be six years, and for claims for periodic benefits and claims relating to the conduct of business, three years.

b) Where the basis for data processing is the performance of a contract, then the User's personal data shall be processed by Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ for as long as is necessary for the performance of the contract, and thereafter for a period corresponding to the period of limitation of claims. Unless a special provision provides otherwise, the limitation period is six years, and for claims for periodic performance and claims related to the conduct of business, three years.

4. Navigation data may be used to provide Users with a better service, to analyse statistical data and to adapt the Application to Users' preferences, as well as to administer the Application.

5. In the event that the User chooses to pay via the "in app purchases" system, his/her personal data shall be forwarded to the extent necessary to process the payment to the relevant company:

Apple Inc, 1 Apple Park Way, Cupertino, California, USA

Alphabet Inc, Mountain View, California, USA

6. In the event that the User subscribes to a newsletter (Newsletter), Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ will send e-mails containing commercial information about promotions and new products available on the Application and within the Independent Trader group (entities that collaborate with Growth & Value) to the User's e-mail address.

7. If a request is made, Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ shall make personal data available to authorised state authorities, in particular to organisational units of the Prosecutor's Office, the Police, the President of the Office for Personal Data Protection, the President of the Office for Competition and Consumer Protection or the President of the Office of Electronic Communications.

§ 3 Cookie mechanism, IP address

1. The Website uses small files, known as cookies. These are stored by Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ on the end device of the person visiting the Website, if the Internet browser allows it. A cookie usually contains the name of the domain from which it originates, its "expiry time" and an individual random number identifying the cookie. The information collected through cookies of this type helps to adapt the products offered by Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ to the individual preferences and real needs of visitors to the Application. They also give the possibility to develop general statistics of visits to the presented products on the Website.

2. Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ uses two types of cookies:

a) Session cookies: once the session of a particular browser has ended or the computer has been switched off, the stored information is deleted from the memory of the device. The mechanism of session cookies does not allow the collection of any personal data or any confidential information from Users' computers.

b) Persistent cookies: they are stored in the memory of the User's terminal equipment and remain there until they are deleted or expire. The mechanism of permanent cookies does not allow any personal data or any confidential information to be retrieved from the Users' computer.

3. Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ. uses its own cookies for:

a) to authenticate the User on the Application and to provide a User session on the Application (after logging in) so that the User does not have to re-enter his/her login and password on each sub-page of the Application;

b) analysis and research, as well as audience auditing, and in particular to compile anonymous statistics which help to understand how Users use the Website and the Application, so as to improve its structure and content.

4. Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ uses external cookies for:

a) presentation on the information pages of the Website, of a map indicating the location of the Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ office by means of the maps.google.com website (external cookie administrator: Google Inc. with its registered office in the USA);

b) to present multimedia content on the websites of the Website, which are downloaded from the external website www.vimeo.com (external cookie administrator: Vimeo, LLC. based in the USA);

c) the collection of general and anonymous statistical data via the analytical tools of Google Analytics (third-party cookie controller: Google Inc. based in the USA);

5. The cookie mechanism is safe for the computers of the Users of the Application. In particular, it is not possible for viruses or other unwanted software or malware to enter Users' computers via this route. Nevertheless, Users have the option in their browsers to limit or disable the access of cookies to their computers. If this option is used, the use of the Website will be possible, except for functions that by their nature require cookies.

6. Growth & Value SPÓŁKA Z OGRANICZONĄ Z ODPOWIEDZIALNOŚCIĄ may collect IP addresses of Users. An IP address is a number assigned to the computer of a person visiting the Website by an internet service provider. The IP number allows access to the Internet. In most cases, it is assigned to the computer dynamically, i.e. it changes each time you connect to the Internet. The IP address is used by Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ to diagnose technical problems with the server, to create statistical analyses (e.g. to determine from which regions we record the highest number of visits), as information useful in administering and improving the Website, as well as for security purposes and the possible identification of unwanted automatic browsing programmes overloading the server.

7. The application contains links and references to other websites. Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ is not responsible for the privacy policies of these sites.

§ 4 Data subject rights

1. right to withdraw consent - legal basis: article 7(3) GDPR.

a) The user has the right to revoke any consent given by Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ

b) Withdrawal of consent has effect from the moment of withdrawal.

c) The withdrawal of consent shall not affect the processing carried out by Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ in accordance with the law prior to its withdrawal.

d) Withdrawal of consent does not entail any negative consequences for the User, but may prevent further use of services or functionalities that Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ can legally provide only with consent.

2. the right to object to the processing of data - legal basis: article 21 GDPR.

a) You have the right to object at any time - on grounds relating to your particular situation - to the processing of your personal data, including profiling, if Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ processes your data on the basis of a legitimate interest, such as marketing Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ's products and services, keeping statistics on the use of particular functionalities of the Website and facilitating the use of the Website, as well as satisfaction surveys.

b) Opting out, in the form of an email, from receiving marketing communications about products or services will imply the User's objection to the processing of his/her personal data, including profiling for these purposes

c) If the User's objection proves to be well-founded and Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ has no other legal basis for the processing of personal data, the User's personal data will be deleted, to the processing of which the User has objected.

3. the right to erasure ("right to be forgotten") - legal basis: article 17 GDPR.

a) You have the right to request the deletion of all or some of your personal data.

b) The user has the right to request the deletion of personal data if:

a. the personal data are no longer necessary for the purposes for which they were collected or for which they were processed;

b. has withdrawn specific consent, to the extent that the personal data were processed on the basis of his/her consent;

c. has objected to the use of his/her data for marketing purposes;

d. personal data is processed unlawfully;

e. the personal data must be erased in order to comply with a legal obligation under Union or Member State law to which Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ is subject;

f. the personal data was collected in connection with the offering of information society services.

c) Despite a request for erasure of personal data, due to the filing of an objection or withdrawal of consent, Growth & Value SPÓŁKA Z LIMITED LIABILITY may retain certain personal data to the extent that the processing is necessary for the establishment, investigation or defence of claims, as well as to comply with a legal obligation requiring processing under Union law or the law of a Member State to which Growth & Value SPÓŁKA Z LIMITED LIABILITY is subject This applies in particular to personal data including: first name, last name, e-mail address, which data is retained for the purpose of handling complaints and claims relating to the use of Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ's services or, in addition, home address/correspondence address, order number, which data is retained for the purpose of handling complaints and claims relating to concluded sales contracts or the provision of services.

4. The right to restrict data processing - legal basis: article 18 GDPR.

a) You have the right to request the restriction of the processing of your personal data. The submission of a request, pending its consideration, prevents the use of certain functionalities or services, the use of which will involve the processing of the data covered by the request. Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ will also not send any communications, including marketing communications.

b) You have the right to request a restriction of the use of your personal data in the following cases:

a. if he or she questions the correctness of his or her personal data, Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ restricts the use of his or her personal data for the time necessary to check the correctness of the data, but for no longer than 7 days;

b. when the processing of the data is unlawful and instead of deleting the data, the User requests the restriction of its use;

c. when the personal data are no longer necessary for the purposes for which they were collected or used but are needed by the User in order to establish, assert or defend a claim;

d. when he/she has objected to the use of his/her data, in which case the restriction shall be for the time necessary to consider whether, due to the particular situation, the protection of the interests, rights and freedoms of the User outweighs the interests pursued by the Administrator in processing the User's personal data.

5. right of access to data - legal basis: article 15 GDPR.

a)You have the right to obtain confirmation from the Administrator as to whether it is processing personal data and, if so, you have the right:

a. gain access to your personal data;

b. obtain information about the purposes of the processing, the categories of personal data processed, the recipients or categories of recipients of such data, the intended period of storage of the User's data or the criteria for determining this period (where it is not possible to determine the intended period of processing), the User's rights under the GDPR and the right to lodge a complaint with a supervisory authority, the source of such data, automated decision-making, including profiling, and the safeguards applied in connection with the transfer of such data outside the European Union;

c. obtain a copy of your personal data.

6. Right to rectification of data - legal basis: article 16 GDPR.

a) The User has the right to request the Administrator to rectify without delay personal data concerning him or her which are inaccurate. Taking into account the purposes of the processing, the Data Subject has the right to request the completion of incomplete personal data, including by providing an additional statement, by addressing the request to the email address.

7. right to data portability - legal basis: article 20 GDPR.

a) You have the right to have your personal data that you have provided to the Administrator sent to another controller of your choice. The User also has the right to request that the personal data be sent by the Administrator directly to such controller, insofar as this is technically possible. In this case, the Administrator will send the User's personal data in the form of a file in csv format, which is a commonly used, machine- readable format that allows for the transmission of the received data to another personal data controller.

8. In the event of the User's assertion of an entitlement arising from the above rights, Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ shall either comply with the request or refuse to comply with it immediately, but no later than within one month of receipt. However, if - due to the complexity of the request or the number of requests - Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ is unable to comply with the request within one month, it will comply with the request within a further two months informing the User beforehand - within one month of receipt of the request - of the intended extension of the deadline and the reasons for it.

9. The User may lodge complaints, queries and requests to the Administrator regarding the processing of his/her personal data and the exercise of his/her rights.

10. You have the right to request Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ to provide you with a copy of the standard contractual clauses by addressing your request in the manner indicated in §5 of the Privacy Policy.

11. You have the right to lodge a complaint with the President of the Data Protection Authority regarding a breach of your data protection rights or other rights granted under the GDPR.

§ 5 Security management - Password

1. Growth & Value SPÓŁKA Z OGRONICZONĄ ODPOWIEDZIALNOŚCIĄ provides Users with a secure and encrypted connection when transmitting personal data and when logging into the User Account on the Website. Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ uses an SSL certificate issued by one of the world's leading companies in the field of security and encryption of data transmitted over the Internet.

2. In the event that a User with an account on the Application has lost his/her password in any way, the Application allows a new password to be generated. Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ does not send a password reminder. The password is stored in encrypted form in such a way that it cannot be read. In order to generate a new password, the User must provide an e-mail address in the form available under the link "You have forgotten your password", provided at the Application account login form. The User will receive an e- mail message to the e-mail address provided during registration or saved in the last change of the account profile, containing a redirection to a dedicated form made available on the Website, where the User will have the opportunity to set a new password.

3. Growth & Value SPÓŁKA Z OGRANICZONĄ Z ODPOWIEDZIALNOŚCIĄ shall never send any correspondence, including electronic correspondence, requesting login details and in particular the password to access the User's account.

4. Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ recommends that Users create a unique password for their account that is not used on other services by the User.

§ 6 Changes to the Privacy Policy

1. The Privacy Policy is subject to change, of which Growth & Value SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ will inform Users 14 days in advance.

2. Please direct any questions relating to the Privacy Policy to: kontakt@cointester.com