The newsletter prepared by MCI Capital S.A. (“Newsletter”) makes it possible for all interested parties to receive information selected and developed by MCI Capital S.A. Use of the Newsletter service is voluntary, free of charge and not restricted in time. In order to provide the Newsletter service, it obtains e-mail address names from the interested parties. A registered person can, at any time, change or remove his or her data entered in the process of subscribing for the Newsletter. Information regarding the ways of registration, modification and removal of data is available after clicking on the links: “Newsletter Terms and Conditions”.

The Controller of your personal data submitted for the purpose of accessing the Newsletter is MCI Capital S.A. with its registered office in Warsaw at Plac Europejski 1, 00-844 Warsaw (hereinafter, “MC Capital”). You can contact MCI Capital by sending a letter (to the address indicated above) or via e-mail: office@mci.eu or by phone: (+48) 22 540 73 80. Your personal data are processed on the basis of your voluntary consent, which you have expressed by sending consent to receive the Newsletter at the e-mail address indicated by you. You also have the right to lodge a complaint with the President of Personal Data Protection Office, if you decide that the processing of your data by MCI Capital violates the provisions of law, in particular the Regulation of the European Parliament and the Council (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (General Data Protection Regulation). At the same time, we wish to inform you that your personal data processed for marketing purposes, i.e. for the purpose of sending the Newsletter, will be stored until an objection to their processing is filed or until the revocation of the consent for the processing thereof. MCI Capital does not transfer your personal data outside the European Economic Area. We would also like to inform you of your right to access your personal data and to demand a correction, to remove and to limit the processing thereof. Moreover, we inform you of your right to file an objection against the processing of your personal data on account of your exceptional situation if the basis of processing of the personal data is the premise of legitimate interest of the Personal Data Controller. Moreover, to the extent the basis for the processing of your personal data is consent, you have the right to revoke it, which, however, shall not affect the lawfulness of the processing completed before its revocation and to transfer the data provided to another data controller. You also have the right to file an objection with the supervisory body dealing with personal data protection. In respect of data processed by the Personal Data Controller, the competent authority for lodging a complaint is the President of the Personal Data Protection Office.

 

NEWSLETTER TERMS AND CONDITIONS

§ 1

These “Newsletter Terms and Conditions” (hereinafter: “Terms and Conditions”), developed on the basis of Article 8(1) of Act of 18 July 2002 on provision of services by electronic means (Journal of Laws of 2017 item 1219, as amended; hereinafter: “Act”), sets forth the rules for free-of-charge use, by individual users (hereinafter: “Users”), of the Newsletter (“Newsletter”) run and administered by MCI Capital S.A. with its registered office in Warsaw (00-844) at Plac Europejski 1, entered into the register of entrepreneurs of the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Division of the Court Register under the KRS number: 000004542 (hereinafter: “MCI Capital”).

§ 2

1. In order to provide the service of the Newsletter, MCI Capital obtains names of electronic mail addresses from interested parties.

2. Use of the Newsletter is voluntary, however delivery of the Newsletter by MCI Capital is impossible without submission of the required data, i.e. e-mail address.

3. Providing MCI Capital with the e-mail address or use of the Newsletter constitute acceptance of these Terms and Conditions and expression of consent by the User for receiving information determined in the Terms and Conditions.

4. Access to the Newsletter is conditional upon the User meeting the appropriate technical requirements, in particular having access to the Internet and appropriate software with an Internet browser using cookies technology.

5. The User may at any time on his or her own modify or delete his or her e-mail address (unsubscribe from the Newsletter) included on the distribution list of MCI Capital according to which the Newsletter is distributed. Information on how to modify/delete an address can be found in the Newsletter message footer sent to the User’s e-mail inbox.

6. User’s deletion from the address base is completed immediately and indicated with a message confirming the operation.

§ 3

Use of the Newsletter is free of charge and not restricted in time.

§ 4

1. The User is obliged to use the Newsletter in accordance with the provisions of law and these Terms and Conditions.

2. The User is entitled to use the Newsletter solely for his or her own use. The content of the Newsletter is protected by law, in particular by provisions of the Act of 4 February 1994 on copyright and derivative rights (Journal of Laws 2018 item 1191, as amended).

3. The e-mail address to which the Newsletter should be sent should be entered in the e-mail address field. The e-mail address entered must belong or be at the disposal of the person subscribing for the Newsletter. Use of e-mail addresses which do not belong or are not at the disposal of persons subscribing for the Newsletter is forbidden.

§ 5

1. By means of the Newsletter, MCI Capital provides Users with information on its investment projects, market comments, comments on its investment projects and other pieces of information originating in MCI Capital.

2. MCI Capital represents that when preparing the materials and information sent via the Newsletter it uses information obtained from publicly available and credible sources, making every effort to ensure that the information put in the material sent is accurate, however it cannot guarantee that it is correct, complete and up-to-date. Data sent through the Newsletter (historical and forecast) do not constitute guarantee of achieving similar results in the future. MCI Capital does not guarantee that scenarios or forecasts presented in the information sent will come true.  Conclusions drawn on the basis of comments and forecasts presented should not constitute the sole basis for any investment-related decisions. Materials sent using the Newsletter are intended for information purposes only and do not contain full information necessary for assessment of the risk connected with investment in securities and other instruments.

3. Information sent via the Newsletter is intended for information purposes only and does not

constitute recommendation, investment advice, other advice, offer or offer within the meaning of the applicable law. For this reason, MCI Capital shall not be liable for decisions taken by the User after reading the materials sent via the Newsletter. In particular, information sent via the Newsletter should not constitute basis for any investment-related decisions concerning investing in investment funds. Materials available through the Newsletter are intended for information purposes only and do not contain information necessary for assessment of the risk associated with investment in investment funds.

4. MCI Capital shall not be liable for activities of third persons managing the Newsletter, nor for any loss resulting from damage to the User’s computer hardware or his or her data resources in the course of or in connection with the use of the Newsletter, in particular as a consequence of computer viruses penetrating into the IT system of the User. At the same time, MCI Capital asserts that it makes every effort in the process of creation and management of the Newsletter, taking all necessary and justified actions, to eliminate potential risks or threats regarding using the Newsletter and related to the IT environment.

5. MCI Capital shall not be liable for unavailability of the Newsletter due to IT network failure

and other consequences of faulty operation of telecommunications connections and damage caused thereby. MCI Capital is entitled to temporarily switch the Newsletter service off if it is necessary for technical reasons (e.g. maintenance, modifications, repair).

6. MACI Capital is entitled to fully cease the provision of the service of the Newsletter after prior communication of this fact to the Users, without giving reason.

7. MCI Capital is entitled to delete an account the User of which has violated these Terms and Conditions or commonly applicable provisions of law or takes actions interfering with uninterrupted use of the service by other Users.

§ 6

1. In order to provide the Newsletter service, MCI Capital obtains the names of electronic mail addresses from the Users; personal data are shared by the User in this way voluntarily. Use of the Newsletter requires the User to express consent to receiving information in connection with the provision of the Newsletter service using electronic means of communication, as per the Act.

2. Expression of consent to the processing of the User’s personal data and the User’s consent to receiving the Newsletter referred to in the preceding point as well as confirmation of reading these Terms and Conditions and acceptance thereof are obtained by means of the User ticking the relevant box in the relevant form used for expressing the will to receive information included in the Newsletter.

3. Personal data of the User, i.e. e-mail address, are used for the purpose of sending content in the Newsletter.

4. Personal data are processed in accordance with the Regulation of the European Parliament and the Council (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and free movement of such data and repeal of Directive 95/46/EC (General Data Protection Regulation).  Detailed information on the processing of personal data and User’s rights in connection therewith is set out in the GDPR Information in the “Legal Information” tab.

5. Provision of information in the Newsletter is completed in accordance with the Act. The User has the right to modify the data necessary for sending the aforementioned information as well as to revoke the consent for the sending thereof.

6. The Controller of the aforesaid data, including personal data, of the Users is MCI Capital S.A. with its registered office in Warsaw (postal code: 00-844 Warsaw), at Plac Europejski 1.

7. Personal data may be made available to other entities of the MCI Capital capital group on the basis of a separate statement, expressed in the form of appropriate ticking of the choice field in a separate form dedicated to expressing consent in the aforementioned respect.

8. Based on a separate statement, the User may express his or her consent to the processing of personal data for a purpose different than the one indicated in the Terms and Conditions and having as its object delivery of marketing and promotional materials, other commercial information as well as contract proposals by MCI Capital S.A. with its registered office in Warsaw at Plac Europejski 1.

§ 7

1. MCI Capital may change the Terms and Conditions at any time.

2. Changes to the Terms and Conditions will be communicated on the website www.mci.pl.

3. All remarks, comments and questions regarding the Newsletter can be sent to the office’s address: MCI Capital S.A., Plac Europejski 1, 00-844 Warsaw.

4. Complaints regarding the Newsletter should be made via electronic mail to the address: office@mci.pl.

5. Information on the result of the complaint handling is communicated to the interested parties with a letter or via electronic mail within 30 days of the day of the receipt of the complaint.

MCI Capital S.A.

Plac Europejski 1

00-844 Warsaw