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PRIVACY POLICY
SUNREEF VENTURE S.A.

§ 1 GENERAL PROVISIONS
  1. The following provisions constitute the privacy policy of SUNREEF VENTURE S.A. based in Gdansk (hereinafter referred to as the Privacy Policy). The Privacy Policy contains information on the collection and processing of user data of the website operated at: https://www.sunreef-yachts.com (hereinafter referred to as the Website), including personal data.
  2. The Website is operated by SUNREEF VENTURE joint-stock company based in Gdansk at ul. Tarcice 6, 80-718 Gdansk, registered in the register of entrepreneurs of the National Court Register kept by the District Court Gdańsk-Północ in Gdansk, VII Commercial Department of the National Court Register under the number KRS 0000611783, NIP: 5223059783, REGON: 364163013, share capital PLN 39.100.000 – paid in full (hereinafter referred to as SUNREEF VENTURE or the Administrator).
  3. SUNREEF VENTURE makes every effort to enable users of the Website to fully use its functionalities. At the same time, SUNREEF VENTURE ensures that the data provided by the users of the Website, including their personal data, are safe and processed in accordance with the applicable law — including 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 referred to as GDPR).
  4. In concern for the safety of users’ personal data, we inform that by entering the Website and using it, the user agrees to the use of cookies by SUNREEF VENTURE and the processing of his personal data in accordance with the Privacy Policy. The provision and processing of the aforementioned data is key to the proper operation of the Website. At the same time, providing data is voluntary and can be changed by the Website user at any time by changing the browser settings. Failure to provide data may result in limited functionality of the Website for its user.
  5. SUNREEF VENTURE also allows users of the Website to use additional services, i.e.:
    1. receiving a free newsletter service — according to the information described in § 3 par. 9 below,
    2. contact service (including via e-mail, contact form available on the Website, or in another way, e.g. via social media channels and others) — according to the information described in § 3 par. 9 below.
  6.  This Privacy Policy specifies in particular information on:
    1. collection and processing of information, including personal data — in particular regarding: the identity and contact data of the administrator; purposes of processing personal data and legal grounds for processing; legitimate interests pursued by the administrator; information on recipients of personal data or categories of recipients; information concerning the transfer of personal data to a third country or an international organization and the Commission’s determination or lack of determination of an appropriate level of protection or references to appropriate or adequate safeguards and the possibilities of obtaining a copy of the data or the place where the data has been made available; the period for which the personal data will be stored, or the criteria for determining this period; information on the rights of the data subject; information on automated decision-making, including profiling; the category of relevant personal data and the source of personal data — if applicable;
    2. automatic processing of information, including personal data,
    3. cookie policy,
    4. tools used for processing data, including personal data — within the Website and beyond (newsletter, contact form),
    5. changes to this Privacy Policy.
§ 2 INFORMATION ON THE PROCESSING OF PERSONAL DATA
  1. The administrator of your personal data is the company SUNREEF VENTURE S.A. based in Gdansk (detailed data can be found in § 1 sec. 2 above). The Administrator is responsible for using your personal data in a safe way and in accordance with applicable legal regulations. If you have any doubts related to the processing of personal data, you can contact us at any time by sending a message to SUNREEF VENTURE or by e-mail: gdpr@sunreef.com.
  2. When you provide us with your personal data while using our Website, we will use and process it in the manner described in this Privacy Policy. Your personal data is not used for other purposes unless we have obtained your consent for this or if it is required or permitted by law or professional standards.
  3. Providing data when using the Website is voluntary. At the same time, providing data may depend on your browser settings and can be changed at any time by changing your browser settings. Failure to provide data may result in limited functionality of the Website for its user.
  4. If you are an employee or collaborator of our client and cooperate with us on its behalf, we may receive your contact details from our client in connection with their designation of persons representing or contacting us on their behalf.
  5. Depending on the purpose for which your data is processed, the Administrator has the appropriate legal basis for their processing, for example:
    1. when processing is necessary to perform a contract concluded with you or to take actions at your request before entering into a contract — art. 6 sec. 1 point b GDPR,
    2. when you are asked for consent to process data for a specified purpose (e.g., for inclusion in the mailing list and sending you a newsletter, ordering marketing information or commercial information; contacting you after it has been initiated by you) – art. 6 sec.1 point a GDPR,
    3. when we have so-called legitimate interests to fulfill, e.g., accepting your query and responding to it; dispute resolution; maintaining business contacts; identification of representatives, contact persons or other employees or collaborators of our clients acting on behalf of the same clients; preventing abuse, criminal activities and acting to protect our IT systems; personalizing online user experiences and improving the performance, usefulness, and effectiveness of the Website, as well as SUNREEF VENTURE’s presence on the Internet; conducting and analyzing our marketing activities, unless this requires separate consent according to legal regulations; meeting our corporate obligations and social responsibility; archiving correspondence for the purpose of demonstrating its course in the future; ensuring that the user can use the full functionality of the Website, including optimizing the use of the Website and adapting it to the individual settings (preferences) of the user, analyzing, verifying and improving the operation, functionality and performance of the Website, as well as our marketing activities; creating and defining target group lists for marketing purposes; analyzing and verifying the use of the Website by its users, including so-called analysis of traffic on the Website;
    4. when processing is necessary to fulfill a legal obligation that rests on us, e.g., in case of the necessity to make personal data available to state authorities – art. 6 sec. 1 point c GDPR.
  6. Personal data obtained through the Website may also be processed for other purposes than they were collected (e.g., in the implementation of legitimate interests of the Administrator – to send marketing information about provided services, collecting opinions on satisfaction, improving service quality, for analytical and statistical purposes, and for purposes related to the security and integrity of SUNREEF VENTURE’s IT systems). SUNREEF VENTURE guarantees thatpersonal data will be processed exclusively for specified, clear and legal purposes. In each such case, before further processing, we will provide you with all relevant information, including about this other purpose.
  7. We will process (including store) your personal data for the duration of SUNREEF VENTURE’s business operations or its legal successor, unless the conditions of this Privacy Policy, individual services or tools state otherwise.
  8. We obtained your personal data based on information provided by you and information left on the Website while using it.
  9. SUNREEF VENTURE does not collect so-called sensitive personal data (special categories of personal data in the sense of art. 9 GDPR), unless such an obligation results from applicable legal regulations. At the same time, we remind you to be cautious and prudent when providing us with personal data and in no case to provide us with so-called sensitive personal data — unless you express clear consent to the processing of this personal data by us for one or more specific purposes. If you have any doubts in this regard, you can contact us at any time by sending a message to SUNREEF VENTURE or by e-mail: gdpr@sunreef.com.
  10. Your personal data may also be processed by other persons and entities.
§ 3 DATA PROCESSING TOOLS
  1. On the Website, we use tools and technologies that allow us to collect and process data related to users’ visits (i.e., automated personal data processing). The gathered data help us better understand and improve the operation, functionality, and performance of the Website and determine the effectiveness of our marketing efforts, including through the analysis of demographic data.
  2. hrough the Website, we process the following data, including personal data:
    1. IP address and location of the end device,
    2. data of the end device, browser, and operating system,
    3. server date and time — i.e., the time at which the server collected data about the user relative to the server’s date.
  3. Not all information collected in this way constitutes personal data, i.e., allows us to identify a specific user, but this may happen, for example, when it will be possible to associate the IP address or location information with a specific user’s email address.
  4. An IP address is an identification number of the end device (e.g., a computer, phone, tablet) or server that enables communication between devices. IP addresses of users visiting the Website may be recorded for the purposes described in sec. 1 above.
  5. Cookies:
    1. While using the Website, «cookies» are collected. Cookies are computer data (small text files) stored in users’ end devices (e.g., a computer, smartphone, tablet). These files allow recognizing and identifying the user’s device necessary to perform a specific operation (e.g., authentication, collecting statistical data, or saving data in forms), and then properly display the Website adapted to its individual preferences. Cookies are harmless to the device, its user, and its data.
    2. Cookies usually contain: the name of the Website from which they originate, the time of their storage on the end device, and a unique number. Cookies are placed by our Website in the device connected to the Internet during each visit to the Website, which allows remembering the user’s device.
    3. Cookies collected on users’ end devices can be read by:
      1. our IT system (so-called own cookies) — used for the proper operation of our Websiteand purposes specified in point 1 above,
      2. IT systems of third parties (so-called third-party cookies) — our Website, like other websites, uses functions provided by third parties, which involves their use of cookies.
    4. We use two types of cookies — session and persistent:
      1. so-called session cookies are temporary files that remain on the user’s device until logging out of the Website or turning off the software (closing the web browser). If the user wants to change the previously selected option, they should delete cookies from their web browser,
      2. so-called persistent cookies remain on the user’s device for the time specified in the cookie settings or until they are manually deleted by the user. Persistent cookies allow us to recognize your browser when you re-enter the Website.
    5. Cookies used by the operator’s partners of the Website, including its users, are subject to their privacy policy.
    6. Cookies may contain data in the form of:
    7. Cookies themselves do not contain information about the user’s personal data, and our analyses use only the aforementioned identification data, used, for example, to determine the number of unique users or their location and trends by the country of origin — without identifying individual users.
    8. The legal basis for collecting and processing data read from cookies is Art. 6 sec. 1 point f GDPR, allowing the processing of personal data to achieve the purposes resulting from the legitimate interests of the Administrator. These purposes are:
      1. user’s use of the full functionality of the Website, including optimizing the use of the Website and adapting it to the individual settings (preferences) of the user,
      2. analysis, verification, and improvement of the operation, functionality, and performance of the Website,
      3. analysis, verification, and improvement of the actions taken by us, e.g., marketing actions, creating and defining target group lists for marketing purposes,
      4. analysis and verification of the use of the Website by its users, including the so-called analysis of traffic on the Website — both individual and conducted in a collective form, excluding personal identification of the user.
    9. During your first visit to the Website, you are presented with information about the use of cookies – for cookies to function, they need to be accepted by your browser and not deleted from your disk. In many cases, the software used for browsing websites (browser) by default allows for storing cookies on the user’s device. You have the option to manage cookies from the site level. You can also change the settings of cookies in your browser at any time (e.g., by blocking their automatic handling or information about each placement on the device) or completely remove cookies. Detailed information is available in your browser settings (e.g., help menu). Remember, disabling or restricting cookies can affect the functionality of the Website and other websites (e.g., causing difficulties in using them).
    10. More information about cookies can be found, for example, in the help menu of the browser or on the website https://www.aboutcookies.org/.
  6. Google Analytics Tools
    1. We use Google Analytics tools provided by Google LLC (address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) on our Website. The information gathered in this way is transmitted to the Google LLC server and stored there.
    2. Considering that Google LLC is based in the USA and uses the technical infrastructure located in the USA, it has joined the EU-US-Privacy Shield program to ensure an adequate level of personal data protection required by European regulations. As part of the agreement between the USA and the European Commission, the latter has confirmed an appropriate level of data protection for companies with a Privacy Shield certificate.
    3. Google Analytics tool is used for automatic collection and analysis of information related to the use of the Website (so-called site traffic), including the number of visits, displayed subpages, and transitions between them, their browsing time, and others. Google LLC’s cookies related to the Google Analytics service are used for this purpose. As part of Google Analytics, we also collect demographic data and interest data.
    4. We carry out actions in this area based on our legitimate interest (Art. 6 sec. 1 point f GDPR) for the purposes described in sec. 5 (cookies) – point 8.
    5. Due to the IP address anonymization activated by us, your IP address is shortened before being forwarded. Only in exceptional cases is the full IP address transmitted to a Google server in the United States and shortened there. The anonymized IP address transmitted by your browser as part of Google Analytics is generally not combined with other Google data.
    6. You can decide how your data collected via Google Analytics is used, including by:
      1. Changing cookie settings in your browser (more information in sec. 5 (cookies) – point 8,
      2. Installing a browser plugin that prevents the recording of data collected by cookies related to the use of our Website by Google LLC, as well as the processing of these data by Google LLC. The plugin is available at: https://tools.google.com/dlpage/gaoptout.
    7. More information on this topic can be found at: http://www.google.com/analytics/learn/privacy.html, https://support.google.com/analytics/answer/6004245.
  7. Hotjar Tool
    1. On our Website, we use Hotjar analytical tools provided by Hotjar Limited (address: Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta). The information gathered in this way (cookies) is transmitted to the Hotjar Limited server in Malta and stored there.
    2. The Hotjar tool is used to collect and analyze information about user behavior on our Website, including time spent on the Website and individual subpages, features used by users (buttons, links, etc.), used devices and systems (including an anonymized IP number, information about the used device and browser, device location and language).
    3. We carry out actions in this area based on our legitimate interest (Art. 6 sec. 1 point f GDPR) for the purposes described in section 5 (cookies) – point 8.
    4. Hotjar stores this information as part of a pseudonymized profile. Neither Hotjar nor we will ever use this information to identify your identity.
    5. You can decide how your data collected via Hotjar tools is used, including by:
      1. changing cookie settings in your browser (more information in section 5 [cookies] – item 8point b.
      2. objecting to the creation of your anonymous profile and storing information about you by Hotjar by going to this page: https://www.hotjar.com/legal/compliance/opt-out.
    6. More information about the use of Hotjar tools can be found at: https://www.hotjar.com/legal/policies/privacy, https://www.hotjar.com/legal/compliance/gdpr-commitment#hs_cos_wrapper_widget_5701130418.
§ 4 CHANGES TO PRIVACY POLICY AND FINAL PROVISIONS
  1. SUNREEF VENTURE reserves the right to make changes to the Privacy Policy. Every user of the Website is bound by the current version of the Privacy Policy available on the Website. SUNREEF VENTURE will inform about changes to the Privacy Policy on the Website.
  2. If you have any doubts related to the processing of information and personal data, we encourage you to contact us. For this purpose, you can use the SUNREEF VENTURE data provided in § 1 of this Privacy Policy or send a message to the email address: gdpr@sunreef.com.
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Sunreef Venture S.A.

Sunreef Yachts Shipyard

ul. Tarcice 6

80-718 Gdańsk, Poland

+48 58 769 77 77