Personal Data Administrator
The administrator of your personal data is STELLAXIS CAPITAL ADVISORS SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ with its registered office in Warsaw (02-972) at Herbu Janina 5 lok. U08, NIP: 9512621017, REGON: 541685654, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, XIII Business Division of the National Court Register under KRS number 0001171971 (hereinafter “we“, “Administrator” or “Company“).
Contact with the Administrator is possible via e-mail address: contact@stellaxis-capital.pl or in writing to the Company’s registered address.

Purpose and scope of personal data collection and legal basis for personal data processing
We process personal data for the following purposes:
Operation of the website In the case of the provision of services, consisting of providing users with the content of the website, the legal basis for the processing is the necessity of the processing for the performance of the contract (provision of the service electronically), referred to in Article 6(1)(b) of the GDPR.
Analytics In order to perform analytical and statistical tasks, including researching users’ activities and preferences in order to improve the website’s functions, the legal basis for processing is your voluntary consent (Article 6(1)(a) of the GDPR), expressed, for example, through a cookie banner, in accordance with the cookie section below.
Marketing For marketing purposes, including tailoring the content and advertisements displayed to your interests and measuring the effectiveness of marketing activities, the legal basis for processing data (including that from marketing cookies) is your voluntary consent (Article 6(1)(a) of the GDPR), expressed, for example, through a banner cookie, in accordance with the section on cookies below.

Handling of inquiries (Contact Us) We process your personal data to handle inquiries that come to us (e.g., via email, phone or contact form), including responding to you and ensuring effective communication. The legal basis for the processing is our legitimate interest (Article 6(1)(f) GDPR) in handling correspondence and responding to your inquiries. We keep the data processed for these purposes for the period necessary to handle your inquiry and possibly for the period necessary to secure or assert claims.

Protection against claims In the event of potential initiation or assertion of claims, or to safeguard against such claims, the legal basis for data processing is the controller’s legitimate interest referred to in Article 6(1)(f) of the GDPR, which is the defense of the Company’s interests.

Data source
We collect data directly from you if you call us, fill out and send us the contact form provided on our website, correspond with us by e-mail or by mail. We may also obtain your data from companies with whom we cooperate and who indicate you as a representative or competent contact person. The data we receive in this case is your business contact information or, if applicable, the data contained in a power of attorney or an excerpt from the National Court Register.

Recipients of data
Your personal data may be shared with our authorized employees and associates. They may also be shared with entities that process data on our behalf, such as IT service providers (e.g. hosting, website maintenance), analytical, marketing, accounting or legal services, as well as postal and courier service providers. We share this data only to the extent necessary and on the basis of data processing entrustment agreements, obliging processors to ensure adequate data security. Your data may also be disclosed to entities authorized by law. Transfers of personal data outside the European Economic Area (EEA) take place only when necessary and with an adequate degree of protection, such as on the basis of standard contractual clauses.

Rights in connection with data processing
You have the following rights in connection with data processing:
The right to access your personal data (Article 15 GDPR), including obtaining a copy of your data (Article 15(3) GDPR),
The right to rectify (correct) or complete incomplete personal data (Article 16 GDPR),
The right to request the deletion of personal data in cases provided by law (Article 17 of the GDPR),
The right to request a restriction of the processing of personal data (Article 18 GDPR),
The right to receive your data in a structured, commonly used format and to have it transferred when processing is based on your consent, and when processing is carried out by automated means (Article 20 GDPR),
The right to object to the processing of your personal data in the case of processing for the Company’s legitimate interest, for reasons related to your particular situation (Article 21 GDPR),
In cases where the processing of data is based on the consent you have given, you have the right to withdraw the consents you have given at any time, but without affecting the legality of the processing before withdrawal. You may withdraw your consent by sending a message to the Company’s address: contact@stellaxis- capital.pl
in case you consider that the processing of your personal data violates the provisions of the GDPR, you have the right to file a complaint with the supervisory authority, i.e. the President of the Office for Personal Data Protection, based in Warsaw. Details on how to file a complaint can be found on the website of the President of the Office for Personal Data Protection at: uodo.gov.pl/en.

Provision of data
Providing personal data is voluntary, but it may be necessary if you wish to take advantage of some of the opportunities we offer, e.g. we need your contact information to answer questions.

Cookies and similar technology
Cookies are small text files installed on your device (as a User) browsing our website (Service). Cookies collect information that facilitates the use of the Service
– for example, by remembering the User’s visits to the Service and the activities performed by the User, as well as maintaining the User’s session.
We use the following types of cookies:
Necessary cookies We use them for the proper functioning of the Website and to enable you to use its basic functions. They are necessary to provide you with electronic services (e.g. displaying content, maintaining sessions). The legal basis for their use is Article 6(1)(b) of the GDPR (necessary for the performance of the contract for the provision of electronic services). These cookies include, for example, data entered by the User (session ID) for the duration of the session (user-entered cookies).
Analytical cookies We use them to improve the quality of services available on the Website, to study your interaction with the Website, to generate statistics and to create reports on the functioning of the Website. They allow us to better understand how Users use the Service and optimize its performance. These cookies may include, for example, cookies provided by Google Analytics. The legal basis for their use is your voluntary consent (Article 6(1)(a) GDPR).
Marketing cookies We use them to tailor marketing content to your preferences and to run marketing and remarketing campaigns. They may be used to show you ads on other websites that are tailored to your interests shown on our Service. They also allow us to measure the effectiveness of our advertising efforts. The legal basis for their use is your voluntary consent (Article 6(1)(a) GDPR).

Managing cookie settings
You have full control over the cookies used on our Service.
Cookies necessary for the use of the Service are installed automatically on your device. Their use is necessary to provide a service (e.g., data transmission to display content) and you cannot opt out of them if you want to use the Service.
Analytical and marketing cookies are not automatically implemented. You may give your consent to their installation (or to the installation of the types of these cookies of your choice) through the consent management mechanism (e.g. cookie banner) appearing on your first visit to the Website. Your consent is voluntary. Once on the Site, you may:
Accept all analytics and marketing cookies by clicking the appropriate button (e.g. “Consent”).
Reject all optional cookies by clicking the appropriate button (e.g. “I do not consent”).
You have the right to withdraw the consent you have given for analytics and/or marketing cookies at any time. Withdrawal of consent does not affect the lawfulness of the processing performed on the basis of consent before its withdrawal. To do so, you can use the consent management mechanism available on the Website (e.g. by clicking on the cookie management icon/link, often located in the footer of the page) or change the settings of your web browser. Detailed information on how to change the settings of cookies and how to delete them yourself in the most popular web browsers is available in the help section of your web browser and on the following pages (just click on the link):

Chrome
Firefox
Internet Explorer
Opera
Safari
Microsoft Edge
In case of lack of consent or in case of withdrawal of consent for a certain type of cookies (analytical, marketing), the Company will not install such cookies on your terminal device.

Final provisions
The policy is continuously reviewed and updated as necessary. Last updated: 30.05.2025