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OnPoint Fund

OPF / RODO

Privacy and Cookies Policy

OnPoint Fund Alternatywna Spolka Inwestycyjna S.A.

Version 1.0, effective from 23 September 2026

When you, as a natural person, contact us, use our services, or act on behalf of our counterparty or client, or when we have received your personal data from other sources (e.g. from publicly available industry websites, or when your data was disclosed to us as contact details for the performance of agreements), we begin processing your personal data. We approach all information about you responsibly and in accordance with the law - in particular 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 the "GDPR").

The purpose of the following notice is to explain who we are, how we obtain information, and what we do with it in our business, commercial, and marketing relationships and in connection with contacting us. If anything is unclear to you or raises any doubts, please contact us.

I. Glossary - basic terms

  • Personal data - all information that we process about you. This includes, e.g., first name, surname, e-mail address, consumption data, payment data, etc.;
  • Processing - all operations that we perform on your personal data. This includes, e.g., collecting, storing, updating, sending you system messages, analyzing for billing purposes, or deleting;
  • User - a person who has entered into a services agreement with us;
  • Counterparty - a natural person conducting business activity, a legal person, or another organizational unit with which OnPoint Fund establishes business cooperation;
  • Representative - a member of a governing body, representative, or proxy of a Counterparty with whom OnPoint Fund has entered into an agreement in order to carry out cooperation;
  • Contact Person - any natural person who contacts the employees, representatives, or proxies of OnPoint Fund in order to establish or carry out business cooperation; in particular, a Contact Person may be an employee of a Counterparty or another person designated by, or acting on behalf of, the Counterparty;
  • Personal data controller - OnPoint Fund Alternatywna Spolka Inwestycyjna S.A. with its registered office at ul. GEN. WLADYSLAWA SIKORSKIEGO 26, 53-659 WROCLAW, DOLNOSLASKIE, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Wroclaw-Fabryczna in Wroclaw, 6th Commercial Division of the National Court Register, under KRS number: 0001018723, NIP (Tax ID): 6783204100, REGON (Statistical Number): 524435956;

II. You are a Representative or a Contact Person of a Counterparty with whom we enter into an agreement: what personal data do we collect and what are our purposes and legal bases for our actions?

Your personal data may be obtained directly from you or from our Counterparty, in connection with carrying out cooperation with OnPoint Fund.

The scope of data we process primarily includes the following categories:

  • identification data, including first name, surname, and NIP (Tax ID);
  • place of work, position held, department, professional qualifications;
  • contact details (e.g. telephone number, e-mail address);
  • other data provided by the Counterparty or provided directly by you in connection with the conclusion or performance of an agreement.

Providing the above personal data is generally necessary to conclude and perform an agreement with OnPoint Fund - without providing it, it is not possible to conclude an agreement or take actions in connection with its performance.

We may process the above information for the purposes of concluding and performing an agreement and fulfilling obligations arising from legal provisions.

The legal basis for such processing is, respectively, the necessity of performing an agreement (Article 6(1)(b) GDPR), our legitimate interest as a party to the agreement (Article 6(1)(f) GDPR), and a legal obligation (Article 6(1)(c) GDPR).

Sometimes your data will also be processed for archival (evidentiary) purposes and in order to establish or pursue potential claims or defend against such claims. In such a case, the legal basis for processing your data is our legitimate interest (Article 6(1)(f) GDPR).

Where your data is processed on the basis of the controller's legitimate interest, you have the right to object to such processing.

III. We are in contact with each other: what personal data do we collect and what are our purposes and legal bases for our actions?

The scope of data we process depends on what information you or, for example, your employer provide us with, on the form of contact chosen by you, and on what information is necessary in connection with our relationship - it primarily covers the content of documents, as well as the content of our correspondence/communication, and possibly other information we have obtained from publicly available sources related to our business relationship (e.g. industry portals).

In particular, this includes:

  • identification data, including first name and surname;
  • place of work, position or department, professional qualifications;
  • address and contact data, including correspondence address, telephone number, e-mail address, or other contact details.

We therefore obtain the above information directly from you or from other persons, e.g. from your employers/principals, or from publicly available sources.

When using our telephone customer service, electronic messengers, or e-mail, we will process data identifying you (e.g. telephone number, e-mail address, IP address, as applicable), metadata regarding the communication (e.g. date of contact, duration of the call), and the content of our communication (e.g. chat history, e-mail content, recording of a telephone call, if you have been previously informed of this). We process the above information in order to respond to your inquiries, improve our communication, enhance the quality of customer service, and also for the purpose of marketing our services and concluding an appropriate services agreement with you.

The legal basis for these activities depends on the context of the communication. If these are general inquiries or conversations, the basis will be our "legitimate interest" as a controller (arising from the purposes indicated above; Article 6(1)(f) GDPR). However, if the inquiry aims at concluding an agreement, or relates to an agreement already concluded other than for the provision of our services, the legal basis will be "taking action at the request of the data subject prior to concluding an agreement" or the necessity of performing an agreement (Article 6(1)(b) GDPR).

When visiting our website, only technical local storage mechanisms necessary to preserve the selected theme and remember dismissal of the cookie notice are used. We do not use analytics or marketing cookies.

We use technical local storage mechanisms only to the extent necessary for the proper operation of the Website and to remember user preferences, pursuant to the Act of 12 July 2024 on the Law on Electronic Communications.

We may have obtained some of your data from you during a conference or industry event attended by our representatives, or from the organizer of such an event. In such a case, data from a business card, an inquiry, or a list of participants is processed in our database in order to send you information that may be of interest to you, respond to your inquiry, and conduct future correspondence/contact on the matter, or to send thanks for the meeting or for your participation in the event. In such cases, the legal basis for our action is our legitimate interest (Article 6(1)(f) GDPR).

If you did not provide us with your data on your own behalf, i.e. you are, for example, acting on behalf of our client, supplier, or another entity, we process your data in order to carry out contact, in the context in which you act on behalf of the third party, as well as to conclude or perform an agreement with that third party or to carry out a joint venture. The basis for processing your personal data for this purpose will be our legitimate interest (Article 6(1)(f) GDPR) - building and maintaining a relationship with the third party on whose behalf you act, including concluding and performing appropriate agreements with it, as well as the intention to build a positive image of OnPoint Fund.

Regardless of the above, your personal data, i.e. primarily your first name, surname, and correspondence address or, where applicable, e-mail address, may be used by us to send you occasional correspondence (e.g. holiday greetings) or to contact you regarding the promotion of OnPoint Fund's products or services.

The basis for processing your personal data for this purpose will be our legitimate interest (Article 6(1)(f) GDPR) - the intention to maintain our relationship, build a positive image of OnPoint Fund, and market OnPoint Fund's products or services.

Additionally, where your personal data is processed for the purpose of:

  • defense against potential claims, as well as for the possible pursuit of claims, the basis for processing your personal data for this purpose will be our legitimate interest (Article 6(1)(f) GDPR);
  • fulfilling the controller's legal obligations (e.g. tax, accounting obligations), the basis for processing your personal data for this purpose will be the fulfillment of legal obligations imposed on the controller (Article 6(1)(c) GDPR).

In every case, we send commercial information to electronic addresses (e-mail/telephone) only if you give your prior consent (legal basis).

Providing your personal data is voluntary; however, it may sometimes be necessary for purposes related to our cooperation, e.g. necessary to conclude or perform an agreement, to respond to an inquiry, or to conduct correspondence. This means that failure to provide it may in some cases constitute grounds for OnPoint Fund to refuse to establish cooperation or for OnPoint Fund to take legal steps to terminate a potential agreement.

In the case of data processed on the basis of consent, please remember that you may withdraw your previously given consent at any time, without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal. However, where your data is processed on the basis of the controller's legitimate interest, you have the right to object to such processing.

A. Newsletter

We may send you commercial information about us and our partners through your chosen communication channel, but only with your prior consent, including information tailored to your interests based on profiling. The legal basis for processing your Personal Data for this purpose is our legitimate interest or that of our partners (Article 6(1)(f) GDPR) - our own marketing purposes or those of a third party.

Providing Personal Data is voluntary, but necessary in order to sign up for the Newsletter.

We may also process your Personal Data for the purpose of defense against claims - the legal basis for such processing is, respectively, our legitimate interest (Article 6(1)(f) GDPR).

We may process your Personal Data for the period during which it is necessary for our marketing activities, unless you object to its processing; a longer period may result from retaining it in case of potential claims, for the limitation period set out in legal provisions, in particular the Civil Code, or for the duration and settlement of court proceedings. In every case, the longer retention period shall apply.

IV. How long do we process your data?

As a general rule, data processed on the basis of our legitimate interest will be processed until an objection is raised or the purpose for which it was processed has been fulfilled.

Data collected solely in connection with ongoing contact (Section III of the policy above), if you are not our counterparty, is stored depending on the category of specific information, for a period ranging from a few weeks (certain cookies) up to a maximum of 2 years (more detailed inquiries and conversations that may be relevant to our future contact).

Data processed solely on the basis of consent is processed until you possibly withdraw your consent or until the purpose for which it was given has been fulfilled.

Data related to the performance of various agreements, including data of Representatives and Contact Persons (Sections II-III of the policy above), is stored for the duration of the agreement and usually for a period of up to 7 years after its termination, resulting from tax regulations and the limitation period for certain claims.

These periods may be extended as necessary in the event of potential claims and court proceedings - for the duration of such proceedings and their settlement - and also if legal provisions require us, in certain cases, to process the data for a longer period.

V. Who actually has access to your personal data?

Only the following have access to your personal data:

  • appropriately authorized employees or associates of OnPoint Fund, who are obliged to keep it confidential and not to use it for purposes other than those for which OnPoint Fund obtained the data;
  • entities that support us in providing services, on the basis of appropriate data processing agreements, such as e-mail marketing platforms, IT service providers, or contact tools (messengers);
  • providers of legal, advisory, accounting, and tax services;
  • providers of audit services;
  • postal operators and courier companies;
  • insurers, entities providing archiving services;
  • companies within the capital group to which OnPoint Fund belongs.

All of these entities have access only to the information that is necessary for them to perform specific tasks.

In some cases, entities providing us with solutions may be based outside the European Economic Area (EEA). Whenever data is transferred outside the EEA, we apply the required safeguards, including standard data protection clauses adopted by decision of the European Commission. Additionally, in order to protect personal data both during transmission and after receipt, we apply generally accepted standards that meet the requirements of the GDPR and the case law of the Court of Justice of the European Union.

You have the right to obtain a copy of the safeguards we apply regarding the transfer of personal data to a third country by contacting us at our registered office address.

OnPoint Fund may also be obliged to provide certain information to public authorities for the purposes of proceedings conducted by them. In such a case, information is provided only if there is an appropriate legal basis for doing so.

VI. What are "cookies" and other similar technologies? How and for what purpose do we use them?

Cookies and similar local storage mechanisms are small pieces of information stored on a user's device. The Website uses them only to the extent technically necessary for proper operation and to remember user settings.

The Website does not use cookies or similar technologies for analytics, profiling, remarketing or cross-site tracking.

We assure you that all information obtained in this way is used by us solely for the purposes indicated in this policy and is in no way harmful either to you or to the device you are using, since it does not introduce any configuration changes to it.

You may of course change the way you use "cookies", including blocking or deleting them entirely, using your web browser or service configuration. However, please note that such operations may prevent or significantly hinder the proper functioning of our website, for instance by significantly slowing down its operation, which is why we recommend not disabling them in your browser.

Cookies used on the website:

  • Technical cookies - includes cookies necessary for the proper operation of the website, needed to enable the website's functionality; however, their operation has nothing to do with tracking the user

VII. OnPoint Fund's contact details

The controller of your personal data is OnPoint Fund Alternatywna Spolka Inwestycyjna S.A. with its registered office in Wroclaw.

OnPoint Fund's registered office and contact address is: ul. GEN. WLADYSLAWA SIKORSKIEGO 26, 53-659 WROCLAW, DOLNOSLASKIE

General contact e-mail address: kontakt@onpointfund.pl.

VIII. What rights do you have in connection with OnPoint Fund's processing of your personal data?

Please note that the instructions regarding the manner/form of contacting us provided below are merely a recommendation, not a requirement.

To streamline the processes described below, please direct your messages to the e-mail address: kontakt@onpointfund.pl, entering "GDPR" in the subject line.

Access to personal data

You may always request access to your personal data in order to see what data about you we process and to obtain detailed information regarding:

  • whether we process your personal data,
  • for what purpose,
  • what categories of data we process,
  • who the recipients are,
  • where possible - the planned period for which the data will be stored, or, if that is not possible, the criteria for determining that period,
  • if the personal data was not collected from you - any available information about its source.

Right to rectification of personal data

If, in your opinion, the information about you is incorrect or incomplete, you have the right to request the rectification of the data you consider to be inaccurate or incomplete in scope.

Right to erasure of personal data

In certain situations, the GDPR grants you the so-called right to be forgotten. Circumstances justifying such a request include:

  • the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
  • you withdraw your consent to the processing of personal data, and there is no other legal basis for its further processing;
  • you object to the processing of personal data, and there are no overriding legitimate grounds for processing;
  • you object to the processing of personal data for marketing purposes;
  • your data has been processed unlawfully;
  • compliance with a legal obligation under Union or Member State law to which OnPoint Fund is subject.

Right to restriction of processing

You may request the restriction of the processing of your personal data where:

  • you contest the accuracy of the personal data we process - for a period enabling us to verify the accuracy of that data,
  • the processing of your personal data is unlawful, but instead of erasure, you prefer restriction of its use,
  • OnPoint Fund no longer needs your personal data for processing purposes, but you need it in order to establish, exercise, or defend legal claims,
  • you have objected to the processing of your personal data - pending verification as to whether our legitimate grounds override yours.

Successfully submitting a request for restriction of processing will result in restricting the actions we take on the data you specify, and in respect of the specified operations/purposes of processing, to the necessary minimum - generally limited solely to storage.

Right to data portability

You have the right to receive your data in a commonly used, machine-readable format, and to have it transmitted to another controller.

You may exercise this right if:

  • the processing is based on your consent or on an agreement, and
  • the processing is carried out by automated means.

Right to object

In certain situations, you have the right to object to particular processing. You may exercise this right:

  • against the processing of your personal data based on the necessity of performing a task carried out in the public interest or in the exercise of official authority vested in OnPoint Fund, including profiling, on grounds relating to your particular situation,
  • against the processing of your personal data where it is necessary for the purposes of the legitimate interests pursued by OnPoint Fund or by a third party, including profiling, on grounds relating to your particular situation,
  • against the processing of your personal data for direct marketing purposes, at any time, to the extent that the processing relates to such direct marketing,
  • against the processing of your personal data for statistical purposes, on grounds relating to your particular situation.

Please note, however, that if, despite your objection, we conclude that there are compelling legitimate grounds for processing that override your interests, rights, and freedoms, or grounds for the establishment, exercise, or defense of legal claims, we will continue to process the data covered by your objection. If you disagree with such an assessment of the situation, you may exercise your right to lodge a complaint with the supervisory authority (more information below).

Right to lodge a complaint with the supervisory authority

In connection with our activities as the controller of your personal data, you have the right to lodge a complaint with the supervisory authority.

If you wish to lodge a complaint with the supervisory authority, you can find the list of local data protection authorities in the European Union and their contact details at: https://edpb.europa.eu/about-edpb/board/members_en. In Poland, the competent supervisory authority is the President of the Personal Data Protection Office (PUODO).

A detailed description of the procedure for lodging a complaint with PUODO is available on the website maintained by PUODO at: https://uodo.gov.pl/pl/83/155.