Privacy Policy

This Privacy Policy (further: “Policy”) specifies the methods of collecting and processing personal data of users who take advantage of the services provided electronically through the websites run by the company Starward Industries S.A. https://www.starwardindustries.com and https://www.invinciblethegame.com (further: “Services”) and the rights vested in users whose personal data are processed.

The personal data controller is the company Starward Industries S.A., with its registered office at ul. Przemysłowa 12, 30-70 Kraków, entered into the register of entrepreneurs maintained by the District Court for Krakow, 11th Commercial Division of the National Court Register under KRS no. 0000750305 Tax ID No. (NIP): 6772437711 and Statistical ID No. (REGON): 381277255 (further: “Controller” or “Company”). Personal data protection matters should be dealt with by sending electronic mail to the address info@starward.co or a letter by conventional post to the Company’s address given above.

PROTECTION OF PERSONAL DATA

Any personal data are processed by the Controller in accordance with 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, repealing Directive 95/46/EC (further: “GDPR”).

The Controller does not intentionally collect personal data of children aged below 16, without the consent of the child’s parent or guardian. In the case of doubt, parents and guardians are asked to contact the Company at info@starward.co

PURPOSE OF PERSONAL DATA PROCESSING

Users’ personal data are processed by the Controller for the following purposes:

to provide services of which the user is taking advantage (i.e. in order to perform the contract between the user and the Controller) – this refers to running the website at: https://www.starwardindustries.com and https://www.invinciblethegame.com,
to provide services for which the user has agreed – this refers to sending the Controller’s investor newsletters (further: “Newsletter”). User’s consent can be withdrawn at any time, which will be tantamount to ceasing the provision of services that are performed based on it.

CATEGORIES OF PERSONAL DATA PROCESSED

As part of the Newsletter sending service, personal data in the following categories are collected: e-mail address. Failure to indicate an e-mail will prevent provision of the service to the user.

DATA STORAGE LOCATION

Data collected by the Controller are stored within the EEA on Company servers or on secure servers of Trusted Partners described below. The Controller is responsible for implementing appropriate technical and organisational measures in order to protect personal data against being illegally processed, lost, damaged, or destroyed. The Controller ensures that personal data are processed safely and in accordance with this Privacy Policy. Personal data are not made available to countries from outside the EEA.

DATA RETENTION PERIOD

Users’ personal data are processed as long as needed to achieve the purposes specified in this Policy. In certain extraordinary situations, longer retention periods may be required under the law.

Where users’ personal data do not have to be processed any more to provide the services indicated above, the Controller will be obliged to erase or anonymise them. In particular:

data collected based on the user’s consent (Newsletter) will be processed for a period for which the consent was given, however no longer than required by the processing purpose, and subsequently for a period determined by legal or settlement purposes,
in the case of a contact with the Controller, user’s data, including correspondence with the user, will be processed for as long as needed to provide assistance, and subsequently for a period determined by legal or settlement purposes.

LIABILITY

The Controller is not liable for usage by other users or third parties of any personal data made publicly available by the users themselves through the Services.

TRUSTED PARTNERS (PROCESSORS)

Personal data may be made available to the Controller’s Trusted Partners that help provide services to users (e.g. distribution of the Newsletter). The Controller ensures that only minimum information is provided to the partners in order to attain the objectives for which the co-operation was entered into. Trusted Partners may have potential or actual access to restricted user data and may process them on the Controller’s behalf. Personal data covered by this Privacy Policy are made available to the following Trusted Partners that may process them on the Controller’s behalf only for the purposes specified below:

partners providing the Controller with tools for internal management of data and for sharing them,
partners assisting in data analysis by way of providing analytical tools,
partners assisting in managing the Controller’s Newsletter and electronic communications by way of providing appropriate tools.

USER’S RIGHTS

Under the applicable law, the following rights are vested in individuals whose data are processed:

right to access the user’s personal data being processed by the Controller,
right to request that the user’s personal data be deleted from the Controller’s database,
right to request that the user’s personal data be rectified/corrected in justified cases,
right to request that the processing of the user’s personal data be restricted,
right to have the user’s personal data transferred to another entity,
right to lodge a complaint with an appropriate data protection authority.

In order to exercise the aforesaid rights, please contact the Company at: info@starward.co.

In the case of any questions or doubts about personal data protection, please contact the Controller at: info@starward.co

In order to lodge a complaint with an appropriate personal data protection authority , the user may report to a local personal data protection authority or the President of the Personal Data Protection Authority (PUODO) in Poland.

On the website, there are technologies implemented to collect information that helps improve user’s online experience (known as “cookies”).

Using the services is tantamount to agreeing for the cookie notice that appears together while entering the website, which means that the user gives his/her consent that the Controller can store and access cookies as described in this policy.

In order to receive more information, please contact the Controller at info@starward.co.

WHAT A COOKIE IS

Cookies are small text files that are stored on user’s computer or mobile device. They are widely used in order to make websites and other online services work or to be better or more efficient. They can do this because websites and other online services can read and write these files, enabling them to recognize users and remember important information that will make their use more convenient (e.g. by remembering user’s preferences).

WHAT TYPES OF COOKIES ARE USED

Controller may use the following types of cookies:

Essential Cookies. These cookies are essential to the operation of the services in order to enable user to move around it and to use its features. Without these cookies, services the user has asked for, such as accessing secure areas of a website, cannot be provided. These cookies are essential for using the service and therefore cannot be turned off without severely affecting user’s use of it.

Performance Cookies. Performance cookies, which often include analytics cookies, collect information about user’s use of the services and enable the Controller to improve the way it works. For example, performance cookies show what are the most frequently visited pages on the website, allow the Controller to see the overall patterns of usage on the website, help record any difficulties users have with the services and show whether the advertising is effective or not. Cookies may also be used to help users navigate within the website and travel back to pages.

Functionality Cookies. In some circumstances, functionality cookies may be used. Functionality cookies allow to remember the choices users make on the website and to provide enhanced and more personalized features. All of these features help to improve users’ visit on the webpage.

Tracking Cookies. These cookies are used to analyse users’ behaviour and provide information allowing user’s identification, including for marketing purposes within third party websites; the Controller will use this information subject to users’ choices and preferences to make the webpage and the advertising displayed on it more relevant to users’ interests, the Controller may also share this information with third parties for this purpose; if the user visited the website earlier – these cookies remember that the user visited the website, and record his activity there. Information gathered in this manner is transmitted to third–party providers.

HOW THIRD PARTIES USE COOKIES ON THE WEBSITE

In some circumstances, the Controller may work with third parties to provide services on the website. For example, third-party analytics providers may use their own cookies to collect information about users’ activities and/or the advertisements users have clicked on. This information may be used by them to serve advertisements that they believe are most likely to be of interest to the user, based on content he has viewed. The Controller does not control these cookies and to disable or reject third-party cookies, please refer to the relevant third party’s website.

The following third-parties can use their own cookies on our websites:

google.com
facebook.com
twitter.com
tiktok.com
reddit.com

HOW USERS CAN CONTROL COOKIES

It is possible to stop accepting cookies from the website at any time by activating the setting on the browser or mobile device, which allows to stop accepting cookies or similar technologies. In order to obtain more information on commonly used browsers it can be useful to refer to http://www.allaboutcookies.org/manage-cookies. The users shall be aware that if cookies are disabled, not all features of the website services may operate as intended.

FINAL PROVISIONS

This Privacy Policy can be amended at any time, in particular in order to reflect changes made in the services provided by the Controller or amendments to the applicable law.

In order to obtain full details about electronically provided services, please read Terms of Service made available at: https://www.ir.starwardindustries.com/terms-and-conditions.