The www.wealthseed.eu website (hereinafter: “Website”) is maintained by Fair Place Finance S.A., with its registered office at ul. Inżynierska 1/3, 93-569 in Łódź (hereinafter: “WealthSeed” or “Controller”), operating under the trade name of “WealthSeed”.
Confidence and safety are among the most fundamental values of our company. In WealthSeed, we believe that protection of privacy and personal data of our Customers is an indispensable value that contributes to the development of mutual trust. Therefore, WealthSeed complies with legal provisions ensuring the highest quality of personal data protection and continually strives for improvement of its operations in this respect. Your personal data is processed based on applicable provisions of law, particularly the 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, and repealing Directive 95/46/EC (hereinafter: “GDPR“), and based on other generally applicable laws.
1. Personal Data Controller
The controller of your personal data is Fair Place Finances S.A. with its registered office at ul. Inżynierska 1/3, 93-569 in Łódź. In matters concerning the protection of your privacy, you can contact us by email at: email@example.com.
2. What Is Personal Data?
Personal data – any information relating to a natural person that is identified or identifiable by reference to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, including the IP address of the device, location data, Internet identifier, and information gathered through cookie files or a similar technology.
3. How Is Personal Data Processed?
3.1. Data Provided by the User
If you want to use the services offered by WealthSeed, you can apply to join the group of our Customers (hereinafter: “Onboarding Application”). The data provided will be used to verify identity and (upon completion of the full verification procedure) to conclude agreements with WealthSeed.
If you want to ask us a question via our contact form, please provide your identification data (name) and contact details (e-mail address, telephone number). We will use the data to answer the question asked and, provided that you have given your consent, to send you information about our offer.
In order to increase the transparency of privacy protection, Users providing their data through the Website are given information about the ways of processing this data, not later than upon its collection. Users can access it whenever they make data available to us.
3.2. Automatic Recording of Personal Data
To provide you with necessary information on our Website, WealthSeed also processes the following data:
- The IP address of your device;
- The date and time of accessing the web page by the User;
- The web page resources accessed by the User (the path/URL of the web page);
- Identification numbers stored on your device so that we can recognise them on our web page. Identification numbers are stored in the so-called cookie files;
- Device identifiers, which include individual features of your mobile device. Device identifiers allow us to recognise your device on our web page. Examples of device identifiers include “Ad-ID” of the iOS operational system and “Advertising Identifier” of the Android operational system.
4. When (And for What Purposes) Do We Process Your Personal Data?
4.1. Concluding Agreements and Obtaining Information Before Concluding an Agreement Upon the User’s Express Request
Any personal data you provide is processed during:
a/ Filling in an onboarding application form;
b/ Answering questions asked via the contact form and when sending marketing information, provided that the User gives their consent to it.
Purposes and legal bases for processing and other information concerning the rules of personal data processing are provided to the User not later than upon the collection of their data – by providing data privacy notices in accordance with Art. 13 of the GDPR.
4.2. Use of the Website – Cookie Files
Your personal data is also processed to create the best possible product offer tailored to your needs. We would like each visit to www.wealthseed.eu to be as transparent and as pleasant to Users as possible. This is why we process information that can constitute personal data in the form of cookie files. The legal basis for the processing of data is Art. 173 of the Telecommunications Act  and Art. 6 sec. 1 letter a of the GDPR, meaning your consent. You give your consent by acknowledging the use of cookie files during your visit to the Website.
You can withdraw your consent at any time by changing the settings of your browser. Directly on the Website, Users can also decide whether other than necessary cookie files will be used.
The Website uses the following types of cookie files:
- “Session cookies” – these are temporary files stored on the User’s device until the User logs out of the website or closes the software (Internet browser). We use them for technical reasons, for example, to ensure better navigation on the web page, to make it possible for you to adjust your preferences as to the use of the web page, and to “remember” logged-in Users;
- “Persistent cookies” – these are files stored on the User’s device for a period determined by the Controller in the cookie file parameters or until they are manually removed by the User. Cookie files of this type are saved on the User’s hard drive to determine which Users are new on the Website and which have already visited it;
- “Third-party cookies” – these are cookies from partner websites of the Website owner and they are subject to privacy policies of the respective partner websites. We use them to provide you, through modern tools, with the best possible offer adjusted to your needs and preferences.
4.3. Sending Commercial Information
If you consent to it, we will send you commercial information by electronic means. Thanks to this you will receive the latest information about our offer and you will be able to use the various possibilities we offer. You will have the right to withdraw your consent at any time by sending a brief email message, reading for example: “I withdraw my consent to receiving marketing information” to the address: firstname.lastname@example.org. Your request will be granted immediately and without any further conditions. The legal basis for processing is Art. 6 sec. 1 letter a of the GDPR and Art. 10 of the Act on Rendering Electronic Services.
4.4. Validity of the Services Rendered and Pursuing and Defending Claims
We hope that our cooperation with you will be harmonious and uninterrupted. However, in case any dispute arises, your data can be used for defence against any possible claims or to effectively pursue them. It may also prove necessary to demonstrate that a service was rendered correctly.
The legal basis for processing is the legitimate interest of WealthSeed, which consists in the possibility of pursuing claims, defending against claims, and proving that services were rendered correctly (Art. 6 sec. 1 letter f of the GDPR).
In such a case, you have the right to object to further processing of your personal data for the above purpose but reasons for such an objection have to arise from your special situation.
5. Data Recipients
Recipients of your data can be entities we are obligated to reveal data to based on applicable laws as well as entities that support our business processes: these can be entities rendering IT services and marketing services, entities supporting the processing of onboarding application forms, and entities performing activities that support regulated services rendered by WealthSeed. Such entities cooperate with us based on separate agreements and in the processing of your data they are obligated to follow our orders and instructions.
6. Tracking Systems for the Purposes of Website Analysis
6.1. General Terms and Conditions
We would like the Website to be designed in the best possible way. This is why, constantly seeking quality improvement, we use “tracking” tools that allow us to monitor the effectiveness of network offers. We intend to use network monitoring tools to collect the following data:
- Which links are used to redirect online users to the wealthseed.eu website;
- Which of our web pages are visited, when, how often, and in what order;
- What information Users look for on our web pages;
- Which links or offers are accessed by Users of our web pages;
- How much time Users spent on a given web page;
- What language versions of browsers Users use;
- Whether Users are also customers of WealthSeed;
- Where Users are located;
- The age of Users.
Based on this information, we plan to produce statistics that will allow us to understand answers to the following questions:
- Which tabs are particularly attractive to Users of our web pages?
- Which products are most interesting to our Users?
- Which services should we offer to our Users?
In particular, we use automatically collected data referred to in sec. 3.2 above. Based on it, anonymous user profiles are created using pseudonyms, which store data.
6.2. Google Analytics
The Website uses the Google Analytics tool, an online analytical service provided by Google Inc. (hereinafter: “Google“) with its registered office in the USA. Google Analytics uses cookie files that make it possible to analyse the way you use the Website. Information generated by a cookie file with regard to the way you use the Website is transferred to and stored on the Google server. Upon request of this Website, Google will use this information to analyse the use of the Website by Users in order to prepare reports on the activity on the Website and on the provision of other services connected with the use of the Website and the Internet for the Website’s owner.
The IP address obtained as part of Google Analytics from your browser will not be combined with any other Google data.
You can disable storing cookie files using the settings of your browser, please note, however, that in such a case you might not be able to fully use all functions of this Website. Moreover, Users can make it impossible for Google to gather data generated by cookie files and relating to your use of the Website (including your IP address) and to process this data by Google by downloading and installing a browser plugin available on https://tools.google.com/dlpage/gaoptout?hl=pl.
Data of the third party: Google Ireland Ltd with its registered office in Dublin in Ireland at Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.
Terms of Service: http://www.google.com/analytics/terms/pl.html
Objection to Processing Personal Data:
At any time, you can object to gathering and processing data connected with the use of the Website by Google (including your IP address) by downloading an installing in your browser a plugin available on: https://tools.google.com/dlpage/gaoptout?hl=en.
7. Retention Period
According to applicable laws, we process your personal data over a period necessary to achieve the aim set. After this period, your personal data will be irrevocably deleted or destroyed.
You will be informed about detailed retention periods in obligatory information presented while collecting data.
Data collected as part of website analysis will be stored for a period determined for the life of a given type of cookie files. Please note that the User can at any time change browser settings and remove cookie files from their device. This will indicate that consent to use cookie files has been withdrawn.
8. Rights Relating to Data Processing
With regard to personal data of the Website User, you have the following rights:
- The right to be informed about personal data processing – based on it, a person submitting such a request receives from the Controller information about personal data processing, including particularly the purposes and legal bases of processing, the scope of the data owned, the entities to whom the personal data is disclosed, and the planned date of its removal;
- The right to rectification – based on it, the Controller removes potential inconsistencies or errors concerning the personal data processed or completes or updates any incomplete or changed data;
- The right to erasure – based on it you can request that data the processing of which is no longer necessary in relation to the purposes for which they were collected be erased;
- The right to restriction of processing – based on it, the Controller stops performing any operations on personal data, except for operations the data subject consented to and its storing in accordance with applicable retention rules or until reasons for restricting data processing cease to exist (e.g. a supervisory authority makes a decision allowing for further data processing);
- The right to data portability – based on it, to the extent data is processed in connection with an agreement concluded or consent given, the Controller shall give you the data you provided in a machine-readable format. You can also request that the data be sent to a different entity, provided, however, that both the Controller and the other entity have necessary technical means.
- The right to object to the processing of data for marketing purposes – the data subject can at any time object to the processing of personal data for marketing purposes without the need to justify such an objection;
- You also have the right to object to processing for other purposes, however, it depends on your special situation and the Controller does not have to consider it.
An application concerning the exercising of rights described above can be submitted by email at email@example.com
The User can easily withdraw consent to data processing in connection with the use of cookie files by changing the settings of the browser used.
The application should describe in reasonable detail the object of the request, in particular: who submits the application, which right the person submitting the application wants to exercise; and the processing purposes the request concerns (e.g. marketing purposes, analytical purposes etc.).
If the Controller is unable to determine the contents of your request or to identify the person submitting the application based on the communication received, you will be asked for further information.
A response to the application will be given immediately, not later than within one month upon its receipt. In case it is necessary to extend this period, the Controller will inform you about the reasons for such extension.
Responses shall be sent to the email address from which the application was received.
You also have the right to lodge a complaint with a supervisory authority – President of the Personal Data Protection Office, in case you suspect personal data is processed contrary to the GDPR.
9. Transferring Personal Data to Third Countries and International Organisations
Since WealthSeed cooperates with partners ensuring the highest quality of the services rendered and on account of the use of marketing tools described above, your personal data can be transferred to third countries, i.e. outside the European Economic Area (hereinafter: “EEA”).
Your personal data can be transferred to third countries, i.e. outside the EEA, based on mechanisms validating transfers outside the EEA, including standard contractual clauses, and based on the Commission Implementing Decision confirming an adequate level of protection of personal data. Data can also be transferred outside the EEA on account of the fact that providers supporting marketing services have servers located outside the EEA, which is beyond our control.
To all matters not settled herein relevant provisions of the GDPR shall apply.
In case you have any questions or suggestions concerning personal data protection, please submit them by email at firstname.lastname@example.org.
As on: 23rd July 2021.
 OJ L 119, 4.5.2016.
 Journal of Laws no. 171/2004, item 1800, as amended.
 Journal of Laws 144/2002, item 1204, as amended.