The website owner pays special attention to respecting the privacy of website users. The data obtained as part of the website is particularly protected and secured against access by unauthorized persons. The privacy policy and the rules for the use of cookies on the website are made available to all interested parties. The website is open.

The website owner ensures that its overriding goal is to provide people using the website with privacy protection at a level at least corresponding to the requirements of applicable law, in particular the Act of August 29, 1997 on the protection of personal data and the Act of July 18 2002 on the provision of electronic services.

The website owner may collect personal and other data. Collection of these data takes place, depending on their nature – automatically or as a result of the actions of visitors to the website.

Each person using the website in any way accepts all the rules contained in this privacy policy and cookies.

The website owner reserves the right to make changes to this document.


  1. General information, cookies
  1. The owner and operator of the website is Avia Capital Partners Sp. z o.o. sp. k. with its seat in Warsaw, address: ul. Bitwy Pod Rokitną 1/38, 01-506 Warsaw, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court in Warsaw under KRS number: 0000597011, NIP: 5252643510, REGON: 363529699
  2. The website performs the functions of obtaining information about website users and their behavior in the following way:
    1. The website automatically collects information that is contained in cookies.
    2. by data entered voluntarily by website users, in the forms available on the website pages.
    3. through the automatic collection of web server logs by the hosting operator.
  3. Cookie files (so-called “cookies”) are IT data, in particular text files, which are stored in the end device of the website user and are intended for using the website pages. Cookies usually contain the name of the website they come from, the storage time on the end device and a unique number.
  4. During a visit to the website, data of website users may be collected automatically, relating to a given user’s visit to the website and including, among others, IP address, type of web browser, domain name, number of page views, type of operating system, visits, screen resolution, number of screen colors, addresses of websites from which the website was accessed, time of using the website. These data are not personal data, nor do they allow the identification of the person using the website.
  5. The website may contain links to other websites. The website owner is not responsible for the privacy practices of these websites. At the same time, the website owner encourages the website user to read the privacy policy established on these websites. This privacy policy does not apply to other websites.
  6. The entity that places cookies on the website user’s end device and obtains access to them is the website owner.
  7. Cookies are used for the following purposes:
    1. adapting the content of the website pages to the user’s preferences and optimizing the use of websites; in particular, these files allow to recognize the website user’s device and properly display the website, tailored to his individual needs,
    2. creating statistics that help to understand how website users use websites, which allows improving their structure and content,
    3. maintaining the website user’s session (after logging in), thanks to which the user does not have to re-enter the login and password on each subpage of the website.
  8. The website uses the following types of cookies:
    1. “necessary” cookies, enabling the use of services available on the website, e.g. authentication cookies,
    2. cookies used to ensure security, e.g. used to detect abuse,
    3. “performance” cookies, used to obtain information about the way users use the website pages,
    4. “advertising” cookies, enabling users to provide advertising content more tailored to their interests,
    5. “functional” cookies, enabling “remembering” the settings selected by the User and adapting the website to the user, eg in the scope of the selected language.
  9. The website uses two basic types of cookies: session cookies and persistent cookies. Session cookies are temporary files stored on the end device until they leave the website, log out by the user or turn off the software (web browser). Persistent cookies are stored on the user’s end device for the time specified in the cookie file parameters or until they are deleted by the user.
  10. In the majority of cases, the software used for browsing websites allows cookies to be stored on the user’s end device by default. Website users have the option to change cookie settings at any time. These settings can be changed in the options of the web browser (software), among others in a way that prevents the automatic handling of cookies or forces the user to be informed whenever cookies are placed on the user’s device. Detailed information on the possibilities and methods of handling cookies is available in the web browser settings.
  11. Restrictions on the use of cookies may affect some of the functionalities available on the Website pages.
  12. Cookies placed on the user’s end device may also be used by advertisers and partners cooperating with the website owner.


  1. Processing of personal data, information about forms
  1. If personal data is collected by the website operator, they are processed on the basis of art. 23 sec. 1 point 1 or point 5 of the Act on the Protection of Personal Data (i.e. Journal of Laws of 2002, No. 101, item 926, as amended).
  2. As part of the website, personal data is processed, which are only voluntarily provided by the website user.
  3. As part of the registration form, the following personal data of the website user may be collected: name, surname, address, e-mail address, login, password.
  4. The data contained in the forms, provided to the website operator by the website user, are not made available to third parties (excluding entities related to the website operator) other than with the consent of the user.
  5. The data provided in the form are processed for the purpose resulting from the function of a specific form, e.g. to register on the website and for marketing purposes of own products and services as well as products and services of entities associated with the website operator, in particular offering products, advertising, as well as for archival and statistical purposes. The consent of the data subject is expressed by checking the appropriate window in the registration / verification form or in an e-mail.
  6. Pursuant to Art. 32 sec. 1 point 8 of the Act on the Protection of Personal Data, the user has the right to object to the processing of his personal data by the Personal Data Administrator for marketing purposes or to the transfer of his personal data to another data administrator by sending an appropriate request to the address, including the user’s name and surname service.
  7. In the case of personal data processing by the website operator pursuant to Art. 23 sec. 1 point 1 of the Act on the Protection of Personal Data, i.e. the consent of the data subject, pursuant to Art. 7 point 5 of the above-mentioned of the Act, the consent may be revoked at any time. This right is exercised by sending an appropriate request by e-mail to the address of the website user.
  8. The website user, by selecting the appropriate window in the registration form, may refuse or consent to receive commercial information via electronic means of communication, in accordance with the Act of July 18, 2002 on the provision of electronic services (Journal of Laws of 2002 r., No. 144, item 1024, as amended). If the user has consented to receive commercial information by means of electronic communication, he has the right to withdraw this consent at any time. The exercise of the right to withdraw consent to receive commercial information is carried out by sending an e-mail to the address of a relevant request, providing the user’s name and surname.
  9. The data provided in the forms may be transferred to entities that technically provide certain services – in particular, this applies to the transfer of information about the owner of a registered domain to entities that are operators of the Internet domain (in particular the Scientific and Academic Computer Network j. B. – NASK), payment services or other entities with which the website operator cooperates to this extent.
  10. Users’ personal data is stored in a database in which technical and organizational measures have been applied to ensure the protection of the processed data in accordance with the requirements set out in the provisions on the protection of personal data, including the regulation of the Minister of Internal Affairs and Administration of 29 April 2004 in on personal data processing documentation and technical and organizational conditions to be met by devices and IT systems used to process personal data (Journal of Laws of 2004, No. 100, item 1024).
  11. The user has the right to inspect his data at any time and has the option of updating and deleting them. In order to prevent the re-registration of persons whose participation in the website has been terminated due to unauthorized use of the website’s services, the operator may refuse to delete the data necessary to block the possibility of re-registration. The legal basis for the refusal is Art. 19 paragraph 2 point 3 in connection with Art. 21 sec. 1 of the Act of July 18, 2002 on the provision of electronic services (i.e. of October 15, 2013, Journal of Laws of 2013, item 1422). Refusal to remove also takes place in cases provided for by law.
  12. In cases provided for by law, Ventures S.A. may share some personal data of website users with third parties for purposes related to the protection of third party rights, in particular for the protection of copyrights, provided that this will be done at the written request of such a person. The entity submitting the request is obliged to prove the fact of infringement of its rights, and in particular to prove that it is entitled to the copyright to the work. There must also be a suspicion that the rights of the applicant have been infringed. The website operator may also provide the collected personal data at the request / consent of the website user or at the request of state authorities authorized under the provisions of law. Mail addressed to the website operator is archived and may in some cases be used for evidence purposes.
  13. The operator reserves the right to send e-mails to all website users with notifications about important changes to the website. The operator may send e-mails of a commercial nature, in particular advertisements and other commercial information, provided that the user has consented to it. Ads and other commercial information may also be attached to incoming and outgoing letters from the system account.


III. Server logs

  1. In accordance with the accepted practice of most websites, the website operator stores http queries directed to the website operator’s server (information about some of the website users’ behavior is logged in the server layer). The browsed resources are identified by URL addresses. The exact list of information stored in the web server log files is as follows:
    1. public IP address of the computer from which the inquiry came,
    2. name of the client’s station – identification performed by the http protocol, if possible,
    3. user name provided in the authorization (login) process,
    4. time of arrival of the inquiry,
    5. http response code,
    6. number of bytes sent by the server,
    7. URL address of the page previously visited by the website user (referrer link) – in the event that the go to
    8. the website was followed by a link,
    9. information about the user’s web browser,
    10. information about errors that occurred during the execution of the http transaction.

The above data is not associated with specific people browsing the pages available on the Website. In order to ensure the highest quality of the website, the website operator occasionally analyzes log files to determine which pages within the website are most often visited, which web browsers are used, whether the website structure contains errors, etc.

  1. The logs collected by the operator are stored for an indefinite period as auxiliary material used for the proper administration of the website. The information contained therein will not be disclosed to any entities other than the operator or entities related to the operator personally, by capital or contractually. Based on the information contained in these files, statistics can be generated to help in administering the website. Summaries containing such statistics do not contain features that identify visitors to the website.