Privacy Police


(hereinafter the “Privacy and Cookies Policy“)

In order to comply with our obligations under Regulation (EU) 2016/679 of the European Parliament and of the European 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 (General Data Protection Regulation, hereinafter “GDPR”), we provide you with all the necessary information about the scope and legal grounds for processing your personal data, as well as our contact details to help you understand how we will process your data, and to reassure you that we apply sufficient and effective measures to protect these data.



Personal Data Controller

The Controller of your personal data is DARK POOL ONE SPÓŁKA AKCYJNA with its registered office in Warsaw, ul. Pańska 98/104, 00-837 Warszawa, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under KRS number: 0000907341, NIP: 5272962589, REGON: 389275735, with the share capital of PLN 100,000.00 (hereinafter the “Controller” or “we”).

If you have any questions or concerns regarding the Privacy and Cookies Policy, you can contact the Controller in the following ways:

  • by traditional mail sent to the address: DARK POOL ONE S.A., ul. Pańska 98/104, 00-837 Warszawa;
  • by e-mail at: [email protected].

Purposes and Basis of Personal Data Processing

Your data will be processed by us when:

  • the processing is necessary for the purpose of taking steps at your request prior to entering into a contract and for the performance of the contract concluded (Article 6(1)(b) GDPR), which includes:
    1. the provision of services consisting in the conduct of the subscription process for the Controller’s shares and the conclusion of a share subscription agreement with the Controller;
    2. participation in the recruitment process to which you have applied;
  • the processing is necessary for the purpose of complying with the Controller’s legal obligations connected with the subscription for shares (Article 6(1)(c) of the GDPR);
  • the processing is necessary for the pursuit of our legitimate interests (Article 6(1)(f) GDPR), which include:
    1. asserting, pursuing, and defending against possible claims of users of the Service;
    2. responding to messages and questions from users of the Service;
    3. statistical analysis of activity on the Website, improvement of the Website’s operation and the Controller’s marketing activities;
    4. processing of data within the Controller’s profile on Facebook and Instagram social networks (data is co-controlled by the Controller and Facebook/Instagram respectively);
    5. considering complaints and inform of the outcome of the complaints.


Voluntary Nature of Data Provision

 Providing personal data is voluntary, however, a refusal to provide certain personal data may prevent or significantly hinder the use of the Website and its functionalities (e.g., registration for shares, participation in the recruitment process). In the event of the provision of data in a scope insufficient for the performance of a given activity, such data will be immediately deleted.


Recipients of Personal Data

Recipients of personal data may be entities entitled to obtain data on the basis of legal regulations, entities providing services to the Controller on the basis of agreements concluded with it (including entities operating IT systems, providing IT services, providing advisory, consulting, legal, tax, accounting services), subcontractors who provide services to the Controller on the basis of an agreement concluded with it, the entity maintaining the register of shareholders and other entities that participate in the process of subscribing for shares and conducting and issuing shares.


Retention Period of Your Personal Data

Your data will be processed by us (i) in connection with a share subscription until the completion of the actions taken on the basis of said subscription, and thereafter for the period required by law; (ii) if you have contacted us in any form, we will process your personal data until we have answered your questions; (iii) in the event of a complaint, we will process the data for the duration of the complaint process; (iv) if the processing is based on your consent or the legitimate interest of the controller, respectively, until you withdraw your consent or successfully object to the processing.

Any and all personal data that we process on the basis of our legitimate interest will be processed for as long as our interest exists. However, notwithstanding the foregoing, we will process your data until the expiry of the statutory limitation period for potential claims.


Your rights connected with the processing of your personal data

Under the GDPR, you have the following rights in connection with our processing of your personal data:

  • The right to withdraw consent (Article 7(1) GDPR);
  • The right of access to your personal data (Article 15 GDPR);
  • The right to request the rectification of your personal data (Article 16 GDPR);
  • The right to request the erasure of your personal data (Article 17 GDPR);
  • The right to request the restriction of the processing of personal data (Article 18 GDPR);
  • The right to data portability, i.e., the, right to receive your personal data from us in a structured, commonly used, machine-readable IT format; you can send these data to another controller or request that we send your data to another controller, however, we will only do so if such an action is technically possible (Article 20 GDPR);
  • The right to object to the processing of your data on the basis of our legitimate interests which are not overridden by your interests or your rights and freedoms, and the right to object to the processing of your data for the purposes of direct marketing (Article 21 GDPR).

To exercise the above-mentioned rights, please contact us by email: [email protected] or by post at:
Dark Pool One S.A., ul. Pańska 98/104, 00-837 Warszawa

You also have the right to lodge a complaint with the supervisory authority dealing with the protection of personal data, i.e., the President of the Office for Personal Data Protection (Article 77 GDPR).


Automated data processing

 Your personal data are not processed by automated means, including profiling.


Transfers of data to third countries (outside the European Economic Area)

 As a general rule, your personal data will not be transferred outside the European Economic Area.

Nevertheless, some of the data collected may be transferred outside the European Economic Area in connection with the use of Google Analytics, under the terms and conditions set out in the “Cookies” section of this document, under ” Google Analytics”.



The Website uses cookies, which are computer files stored on the User’s terminal equipment. These files do not interfere in any way with the functioning of your device. Cookies are used in order to:

  • facilitate your use of the Website while browsing;
  • subsequently recognise the user (but without processing his/her personal data) in the event that the Service is reconnected to the device on which they have been stored;
  • ensure security and prevent fraud and abuse;
  • compile statistics which help us understand how visitors use websites, so that we can improve their structure and content;
  • adapt the content of the Website to specific user preferences and optimise the use of the Websites, adjusted to individual user needs;
  • authenticate users;
  • make content available on the Website in the highest possible quality.

Cookies usually contain the name of the website they come from, the time they are stored on the user’s end device and a unique number. We use the following types of Cookies as part of the Service:

  • session” – stored in the user’s end equipment until the user leaves the website, switches off the web browser;
  • permanent” – stored in the user’s terminal equipment for the time specified in the parameters of the cookies or until they are deleted by the user;
  • indispensable” – enable the use of the Website, e.g., authentication cookies, cookies used for security purposes, etc.;
  • Google Analytics cookies” – you should read the cookie policy available at:

Mechanism of Cookies on the Website

Each User can change the settings concerning Cookies in the settings of their Internet browser (by clicking on the name of the browser you will be redirected to the relevant website):

Disabling Cookies in the browser does not prevent the User from accessing the resources of our Website, however, disabling Cookies necessary for the authentication processes, security or maintaining User preferences may make it difficult, and in extreme cases even impossible, to use the Website. The Internet browser enables deleting Cookies.


Google Analytics

On the Website, we use Google Analytics, a web analytics service, on the basis of our legitimate interest within the meaning of Article 6(1)(f) of the GDPR, in order to learn about the Users of our Website and to optimise our offer for these Users (marketing and optimisation purposes).

The service provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google uses this information to evaluate your use of our Website, to compile reports on Website activity and to provide other services connected with your use of our Website. The IP address transmitted by your browser as part of Google Analytics is not combined with other Google data.

You can prevent the collection of data generated by cookies and connected with your use of our Website (including your IP address) to Google and the processing of this data by Google by installing a plug-in provided by Google (when you click on the link, you will be redirected to an external website):

For more information on the terms and conditions of data protection, please visit (when you click on the link you will be redirected to an external website): lub /.

Data transfer to third countries is possible. As an appropriate safeguard, the standard contractual clauses pursuant to Article 46 GDPR apply. Further information on this issue can be found here:


Social media plug-ins

You may find social media plug-ins on the Website. These plugins may cause Cookies (including your personal data) to be sent to social media sites. For information regarding the use of Cookies by social media sites, please refer to the privacy policies of those sites, which you can find under the links below.

Facebook, Instagram





Additional Information

External links may be placed within the Website that enable Users to directly access other websites or, when using the Website, Cookies from other entities may also be placed on your device, in particular from suppliers such as Google, in order to enable Users to use the functionalities of the Website integrated with these websites. Each provider sets forth the rules for the use of cookies in its privacy policy, therefore, for security reasons, we recommend that you read their privacy policy document before using such websites.


Changes to the Privacy and Cookies Policy

In order to ensure that the information provided complies with current legal requirements, we reserve the right to amend the Privacy Policy and Cookies at any time. This proviso also applies in cases where the data protection information must be adapted due to new or modified services and functionalities offered by our Website. Changes to this Privacy and Cookies Policy will be made by posting the new text on the Website, which will take effect automatically the next time you visit it. Any and all previous versions of the Privacy and Cookies Policy will be made available upon request.