Privacy Policy

I.Personal Data
Apricot Capital Group Sp. z.o.o. and its affiliates and its and their directors, officers, employees and agents (together, the “Apricot Capital Group”, “we”, “us” or “our”) believe that it is important to us to keep the Personal Data (as defined below) youchoose to share with us secure and to ensure that you know how we will use it. This Privacy Policy sets forth our intentions with respect to your Personal Data.“Personal Data” means information and data of a personal nature which is associated with a specific individual and may be confidential, such as the person’s name, contact information (e.g., an electronic mail (“email”) address, other electronic communication addresses, a facsimile number, a postal address or other contact details), date of birth, government-issued identification numbers or alpha-numeric strings, educational history, military history, work eligibility status, employment compensation and performance, and financial account information; provided, however, that Personal Data does not include information or data that is or has been made public other than by a party other than you breaching the confidentiality of the Personal Data.

II.Collecting Personal Data

You are under no legal obligation to share your Personal Data with us.You may choose to provide to us Personal Data either by virtue of a communication to us by electronic mail (“email”), in some other form of electronic communication, by facsimile or otherwise in writing (each such communication, a “Communication”), based on a written agreement with us (an “Agreement”), or through this website (the “Site”). We do not currently collect or accept any Personal Data on the Site other than in statistical form as noted below. In the case that you have a specific Agreement with us thatcovers the collection and/ or use of your Personal Data, the terms and conditions of that Agreement supersede those of this Privacy Policy to the extent that there is a conflict.If you provide to us your address for a Communication, we may communicate to you on occasion by using the address you have provided. Such address will be kept in accordance with this policy and laws and regulations applicable to us.We will not collect or seek to obtain more Personal Data than we need for the purpose for which it is sought. We will not use the Personal Data for other than the purposes for which it was sought unless we have obtained your permission to use it for other purposes.

III.Using and Storing Personal Data

To the extent we obtain Personal Data through a Communication or by an Agreement, we will use the Personal Data in connection with the services we provide and our business. We will accept and hold such Personal Data in accordance with all laws and regulations applicable to us, including the EU General Data Protection Regulation. We will observe rights granted to you under applicable privacy and data protection laws and regulations, including the EU General Data Protection Regulation.We do not sell or market your Personal Data to anyone outside the Apricot Capital Group, and only transfer the Personal Data within the group to the extent it is necessary or advisable to carry out our services and business. If you have an Agreement with us, we will use the Personal Data you provide to us under that Agreement in accordance with the terms of that Agreement.We will use and store your Personal Data on our internal network and systems and may transfer it to affiliated companies, employees and agents. We will seek to ensure that we have appropriate security measures in place on our network and systems to protect your Personal Data from unauthorised access or processing, or loss or destruction. The network and systems may be located in countries outside the European Union and European Economic Area, and may not provide the same level of protection as those within the European Union and European Economic Area. We will comply with any lawful requirements or requests by government bodies with respect to the Personal Data.Our staff will be advised of their obligations to use and store Personal Data securely. By reviewing and navigating through our Site, you agree to be bound by its terms and conditions. The Site is intended to be informational only, and is not intended to be and is not financial or other advice. When you navigate through our Site, we may log the date, time and duration of your visit and which pages you visit. We will use that information solely as part of our statistical analysis of the manner in which our Site is used, and not for any other purpose.We will adhere to our Personal Data retention practices, and dispose of your Personal Data before or at the end of such retention periods.When we outsource the processing of your Personal Data, we will seek to ensure that the outsourcing party has appropriate security measures in place to protect your Personal Data and is contractually committed to compliance with this Privacy Policy.Where Personal Data is not identifiable as belonging to an individual, such as through the use of pseudonyms or other forms of anonymity, this Privacy Policy does not apply.To the extent that local law contains requirements that exceed this Privacy Policy, the requirements of local law will apply in that jurisdiction.

IV.Personal Data Processing

Personal Data will be processed in accordance with applicable law and regulations.Individuals will be asked to provide their clear and unequivocal consent for the collection, processing and transfer of their Personal Data, and such Personal Data will be processedin accordance with the individual’s legal rights.Personal Data will be accurate and, where necessary kept up up-to-date. Reasonable steps will be taken to rectify or delete Personal Data that is inaccurate or incomplete. Personal Data will be deleted oramended following an appropriate request by the concerned individual.The network and systems of the Apricot CapitalGroup may include security architecture such as “firewalls” and intrusion detection devices to protect Personal Data from corruption, to block unauthorised access and to seek to protect against unauthorised use. The Personal Data may be “backed up” to avoid the consequences of inadvertent erasure and to meet regulatory, accounting and other requirements, and the “back up” devices are subject to similar security measures.


In the event of a complaint or concern under this Privacy Policy, please contact the Apricot CapitalGroup at the following address: