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Privacy Policy

Introduction

This Privacy Policy ("Policy") of Sheik sp. z o.o., informs and explains the User how Sheik sp. z o.o. processes any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the User's identification or identifiability ("Personal Data") Sheik sp. z o.o. receives, when the User is using the Website and/or the Services.

This Policy sets forth the basic rules and principles by which Sheik sp. z o.o. processes the User's Personal Data and mentions Our responsibilities while processing the User's Personal Data according to transparency obligations. While using the Services the User agrees for the User's Personal Data processing in accordance with the Policy and affirms that. In case when the User does not agree with the Policy partially or fully, the User must stop using the Services. All data collected before the above-mentioned refusal will be processed in accordance with the Policy until the User's direct prohibition is received.

The Services are not directed to people under the age of eighteen (18). If the User becomes aware that the User's child has provided Sheik sp. z o.o. with Personal Data without the User's consent, please contact Sheik sp. z o.o. at the email address listed below. If Sheik sp. z o.o. becomes aware that a child under eighteen (18) has provided Sheik sp. z o.o. with Personal Data, Sheik sp. z o.o. will take steps to remove such information and/or terminate the child's Account.

Sheik sp. z o.o. is the Data Controller within the meaning of the General Data Protection Regulation (GDPR) and determines the purposes and means of processing the User's Personal Data.

Definitions

"Data controller" means a company which determines purposes and means of Personal Data Processing.

"Data processor" means a company which Processes Personal Data on behalf and upon instructions of the Data controller.

"Personal Data" means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processing" means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether by automated means or not, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Personal Data and Its Processing Methods

While providing the Services Sheik sp. z o.o. may collect the following:

Data Used for Performing Customer Due Diligence Measures

  • the User's data e.g. the User's photo, name, date and place of birth, address;
  • identity document data, e.g. photo of the document, number and validity;
  • financial data, e.g. ownership and source of funds and/or wealth;
  • contact details, including, the User's email address or details of other means of communication the User chooses to provide Us;
  • transaction data and the nature of using the service, e.g. transaction sums, counterparties, bank account and card number(s) and account holders;
  • other data e.g. media coverage, occupation and connection to other persons, and device information and location.

Usage Data

Includes details about how the User uses our Website.

Technical Data

Includes internet protocol (IP) address, the User's login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices which the User (whether a client or otherwise) uses to access and browse the Website.

Website Visit Data

Includes the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including date and time), products the User viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.

Marketing and Communications Data

Includes the User's preferences in receiving marketing from Sheik sp. z o.o. or our third parties and the User's communication preferences. This may include information whether the User has subscribed or unsubscribed from any of Our mailing lists, accepted any of Our invitations, or attended any of Our events.

Correspondence Between the User and Sheik sp. z o.o.

Sheik sp. z o.o. collects Personal Data for the following purposes and legal bases:

  • to provide the Services and carry out Our obligations arising from any contract the User enters into with Sheik sp. z o.o.;
  • to perform transactions;
  • to provide the User with information related to providing the Services;
  • to grant the User access to the Services;
  • to remember the User's settings, manage the User's requests, host, and back-end infrastructure;
  • to provide newsletters/offers/updates/advertisements which may be interesting to the User;
  • in order to improve the Website (testing features, interacting with feedback platforms, managing landing pages, heat mapping the Website, traffic optimization, and data analysis and research);
  • to provide customer support;
  • to collect statistical or technical non-personalized data about the use of the Website and the Services;
  • for Our justified interest, for the purpose of fulfilling a contract, including for establishing violations of the contract or legislation, as well as to confirm such violations;
  • in order to comply with legal requirements (including compliance with KYC and AML regulations);
  • in order to protect the User's vital interests or the vital interests of another natural person.

If Personal Data processing is carried out in accordance with Our justified interests, the User has a right to submit objections to such processing.

Disclosing the User's Personal Data

Sheik sp. z o.o. only shares the User's Personal Data when Sheik sp. z o.o. has a valid reason for it and when Sheik sp. z o.o. is legally permitted to do so.

Sheik sp. z o.o. may disclose the User's Personal Data to:

  • Data processors (including banking partners, technology providers, customer support centers);
  • Third parties acting as independent data controllers where required by applicable law (e.g. auditors, regulators, authorities);
  • An acquirer, successor, or assignee as part of a merger, acquisition, restructuring, or transfer of business or assets;
  • The User's authorised representatives or advisers.

Sheik sp. z o.o. does not sell the User's Personal Data to third parties.

Personal Data Storage

Sheik sp. z o.o. stores the User's Personal Data for as long as necessary to fulfil contractual, legal, and regulatory obligations. In accordance with record-keeping obligations, Personal Data may be retained for statutory periods required under applicable AML/CFT and other legal requirements.

Cookies

Our Cookies Policy is available on the Website.

Security and International Transfers

Although generally the Personal Data is processed within the European Economic Area, certain activities may result in the transferring of Personal Data to Third Countries, meaning countries located outside the EU/EEA. Sheik sp. z o.o. takes all necessary measures to protect the data against unauthorized access, modification, disclosure, or destruction. Sheik sp. z o.o. has implemented various technical and organizational measures to be compliant with applicable Personal Data, privacy, and data security legislation in the countries where Sheik sp. z o.o. operates or where the applicable law applies to Sheik sp. z o.o..

Sheik sp. z o.o. has put in place procedures to deal with any suspected Personal Data breach and will notify the User and any relevant regulator of a breach where Sheik sp. z o.o. is required to do so by law.

Sheik sp. z o.o. is not responsible for Personal Data protection measures violations if such violations are caused by actions performed by the User or a third person.

The User's Rights and Obligations

In accordance with relevant legal acts (primarily – GDPR) the User can exercise the following rights by contacting Us:

  • request access to the User's own Personal Data;
  • request changes to the User's own Personal Data;
  • request removal of the User's own Personal Data;
  • submit objections to the User's own Personal Data processing on any grounds.

Sheik sp. z o.o. replies to the User's requests and requirements within one (1) month and notifies about measures taken to perform the provided requests and requirements.

If the requests or requirements of the User are obviously not justified or excessive, primarily due to their repetitive nature, Sheik sp. z o.o. has the right to refuse performing such requests or requirements.

The User does not need to pay a fee to access information or other rights; however, Sheik sp. z o.o. may charge a reasonable fee if the User's request is clearly unfounded, repetitive, or excessive, or refuse to comply with the User's request in such circumstances.

In cases where Personal Data is processed based on the User's consent, the User has the right to revoke such consent at any time. Revocation of consent does not affect the lawfulness of processing carried out prior to the revocation.

Where Sheik sp. z o.o. needs to collect Personal Data by law, or under the terms of a contract with the User, and the User fails to provide such data when requested, Sheik sp. z o.o. may not be able to perform the contract (including provision of the Services). In such case, Sheik sp. z o.o. may have to cancel the User's access to the Services and will notify the User accordingly.

The User must notify Sheik sp. z o.o. about changes in the User's contact details to keep them up to date.

In case of a violation of the User's rights, the User has the right to lodge a complaint with the competent supervisory authority or a court.

The competent data protection authority in Poland is:

President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych – PUODO) ul. Stawki 2, 00-193 Warsaw, Poland https://uodo.gov.pl

Legal Limitations

Notwithstanding anything to the contrary in this Policy, Sheik sp. z o.o. may preserve or disclose the User's information if Sheik sp. z o.o. reasonably believes that such action is necessary to comply with applicable law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security, or technical issues; or to protect the rights or property of Sheik sp. z o.o. or its Users.

The User acknowledges that Sheik sp. z o.o. is not liable for any illegal or abusive use of the User's information. The User further acknowledges that where the User shares information from the Website or Services on social networks or third-party platforms, such information is subject to the privacy policies of those third parties.

Sheik sp. z o.o. may share the User's Personal Data with law enforcement authorities, data protection authorities, government officials, or other competent authorities only where legally required or necessary to protect the safety of Users or the Website.

Third-Party Links

The Website may include links to third-party websites, plug-ins, or applications. Clicking on such links or enabling such connections may allow third parties to collect or share data about the User. Sheik sp. z o.o. does not control these third-party websites and is not responsible for their privacy policies. Users are encouraged to review the privacy policies of any third-party websites they visit.

Policy Changing

This Policy may be amended to comply with changes in law, Personal Data processing practices, or instructions of supervisory authorities. Sheik sp. z o.o. will make the updated Policy available on the Website.

Contact Details and Questions

Any questions regarding this Policy, the processing of Personal Data, or data subject requests may be addressed to Sheik sp. z o.o. via the contact channels available on the Website or by email at: [email protected]