Privacy policy
1. Data controller
The controller of your personal data is ART-Tech Alternatywna Spółka Inwestycyjna Sp. z o.o. (ART-Tech Alternative Investment Company Ltd.), with its registered office in Kraków, ul. Mogilska 65, 31-545 Kraków, entered into the entrepreneurs' register of the National Court Register (KRS) under number 0000994565, NIP (tax ID) 6751771209, REGON 523253851 (hereinafter: "the Controller" or "the Company").
The Company is entered into the register of managers of alternative investment companies (ZASI) maintained by the Polish Financial Supervision Authority (KNF).
Contact regarding data protection matters: inwestycje@atifund.pl.
2. Purposes and legal bases of processing
Your personal data is processed on the basis of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and the Polish Act of 10 May 2018 on the protection of personal data.
2.1. Handling enquiries via the contact form
- Purpose: responding to enquiries submitted via the form, e-mail or LinkedIn.
- Legal basis: Art. 6(1)(f) GDPR — the legitimate interest of the Controller in maintaining communication with persons interested in the Company's activities.
2.2. Performance of AML / KYC obligations
- Purpose: verification of the identity of professional clients and fulfilment of obligations arising from the Act of 1 March 2018 on counteracting money laundering and terrorist financing.
- Legal basis: Art. 6(1)(c) GDPR (legal obligation).
2.3. Performance of investment agreements
- Purpose: conclusion and performance of agreements with investors and portfolio companies.
- Legal basis: Art. 6(1)(b) GDPR (performance of a contract).
2.4. Tax and accounting obligations
- Purpose: fulfilment of obligations arising from the Accounting Act and tax regulations.
- Legal basis: Art. 6(1)(c) GDPR.
3. Scope of processed data
We process data provided to us voluntarily by you or obtained in the course of cooperation:
- First name, last name, company name
- E-mail address, phone number
- Content of correspondence
- Identification data required by AML regulations (for professional clients): PESEL/identity document number, address, beneficial ownership data
- Technical data (IP address, browser identifier, timestamps) — see the Cookies section
Provision of data is voluntary; however, failure to provide it may prevent us from responding or carrying out cooperation.
4. Retention period
- Contact correspondence: up to 3 years from the last contact (purpose: potential further communication, pursuit / defence of claims).
- AML / KYC documentation: 5 years from termination of the business relationship (Art. 49(1) of the AML Act).
- Accounting records: 5 years from the end of the financial year (Accounting Act).
- Server logs: up to 12 months.
5. Recipients and transfers of data
Your data may be disclosed to:
- Entities providing IT, hosting and e-mail services (under data processing agreements);
- Accounting offices and advisers (accounting, legal, tax);
- State authorities authorised under applicable regulations (KNF, UODO, tax offices, courts, prosecutor's office);
- To a limited extent, investment partners and portfolio companies — only with your consent or where necessary for the performance of an agreement.
We do not transfer your data outside the European Economic Area (EEA), unless required for the performance of a specific agreement and agreed with you, with the safeguards required by the GDPR (Art. 46–49) in place.
6. Rights of data subjects
You are entitled to the following rights:
- Access to your data (Art. 15 GDPR);
- Rectification (Art. 16 GDPR);
- Erasure ("right to be forgotten", Art. 17 GDPR);
- Restriction of processing (Art. 18 GDPR);
- Data portability (Art. 20 GDPR);
- Objection to processing based on legitimate interest (Art. 21 GDPR);
- Lodging a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl).
To exercise any of these rights, please contact us: inwestycje@atifund.pl. We will respond within 30 days.
7. Cookies and analytics
The atifund.pl website uses cookies and local storage (localStorage) only to the extent necessary for the operation of the service (including remembering accessibility panel settings). Details are set out in the Cookies policy.
The website loads Google Fonts from fonts.googleapis.com — this may involve transmitting your IP address to Google LLC. The legal basis is Art. 6(1)(f) GDPR (legitimate interest — ensuring consistent typography). You can block font loading via your browser settings.
8. Changes to the policy
We reserve the right to amend this policy in the event of changes in legislation or data processing practice. We will notify you of material changes via the website and, in the case of persons with whom we maintain active correspondence, also by e-mail.
9. Contact
For matters related to the processing of personal data, please contact:
ART-Tech ASI Sp. z o.o.
ul. Mogilska 65, 31-545 Kraków, Poland
E-mail: inwestycje@atifund.pl