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Privacy Policy of the Elegant Investors platform

Effective from October 8, 2025
Last updated October 8, 2025

1. General provisions

1.1. This Privacy Policy defines the rules for the processing and protection of personal data of Users using the Elegant Investors platform, which is part of the Elegant Investors project operated by Kinga Stigter under unregistered business activity.

1.2. The controller of personal data is Kinga Stigter, who can be contacted via email at kinga.elegant.investors@gmail.com or through the contact form available on the website.

1.3. The platform respects the privacy of Users and ensures that personal data is processed in accordance with applicable laws, including Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR).

1.4. Personal data is collected and processed only to the extent necessary to achieve the purposes specified in this Privacy Policy.

2. Scope of processed data

When using the platform, the following personal data may be processed:

  • first and last name,

  • email address,

  • phone number (if provided),

  • billing details (address, country, tax identification number for invoicing purposes),

  • payment data (processed by payment service providers),

  • purchase and subscription history,

  • information related to the use of the platform (logs, cookies, analytical data).

3. Purposes of data processing

Users’ personal data is processed for the following purposes:

  • order fulfillment and provision of services (courses, subscriptions, online materials),

  • payment processing and invoice issuance,

  • correspondence handling and responding to inquiries,

  • sending newsletters (with prior consent),

  • marketing and informational activities related to Elegant Investors products,

  • ensuring the security and proper functioning of the website (for example logs, cookies, analytics).

4. Legal basis for data processing

Personal data is processed on the basis of:

  • Article 6(1)(b) GDPR – necessity for the performance of a contract (for example purchase of a course or subscription),

  • Article 6(1)(a) GDPR – consent of the User (for example subscription to a newsletter),

  • Article 6(1)(c) GDPR – legal obligations related to accounting and taxation,

  • Article 6(1)(f) GDPR – legitimate interests of the controller (for example website security and statistical analysis).

5. Data retention

5.1. Personal data is stored for the period necessary to perform the contract and, after its completion, for the period required by tax law or until the limitation period for claims expires.

5.2. Data processed based on consent (for example newsletter subscription) is stored until the consent is withdrawn.

5.3. Analytical data and cookies may be stored for up to 24 months.

6. Data sharing

6.1. Personal data may be transferred only to trusted entities cooperating with Elegant Investors for the purpose of service delivery, in particular:

  • payment service providers (cards, Google Pay, Stripe),

  • mailing platforms (for example MailerLite, Mailchimp, Odoo),

  • course platforms and CMS systems (for example Odoo),

  • hosting and analytics service providers (for example Google).

6.2. All data processors act on the basis of data processing agreements and are obliged to maintain confidentiality.

6.3. Data is not transferred outside the European Economic Area unless a given service provider ensures an appropriate compliance mechanism (for example an adequacy decision or EU standard contractual clauses).

7. User rights

7.1. Each User has the right to:

  • access their personal data,

  • rectify or update data,

  • erase data (right to be forgotten),

  • restrict processing,

  • data portability,

  • withdraw consent at any time,

  • object to the processing of personal data.

7.2. To exercise the above rights, the User may contact the controller via email at kinga.elegant.investors@gmail.com.

7.3. The User also has the right to lodge a complaint with the relevant supervisory authority if they believe that their data is processed unlawfully.

8. Newsletter

8.1. Subscription to the newsletter is voluntary and requires providing an email address and granting appropriate consent.

8.2. The User may unsubscribe from the newsletter at any time by clicking the unsubscribe link in the footer of the email or by contacting the controller via email.

8.3. Newsletter distribution is carried out using a mailing system integrated with the Odoo platform, which ensures data security and compliance with GDPR requirements.

9. Cookies and analytics

9.1. The website uses cookies to ensure proper operation, personalize content, generate statistics, and analyze traffic.

9.2. The User may change cookie settings at any time in their web browser.

9.3. The website uses analytical tools (for example Google Analytics) that may collect anonymized data regarding user activity.

9.4. Detailed rules regarding the use of cookies are described in the Cookies Policy.

10. Data security

10.1. Personal data is processed in a manner that ensures its security, using technical and organizational measures protecting against unauthorized access, loss, or destruction.

10.2. The website uses encrypted SSL connections (https) and secure servers.

11. Changes to the Privacy Policy

11.1. The controller reserves the right to amend this Privacy Policy in the event of changes in legal regulations or the operation of the platform.

11.2. Users will be informed of any changes via a notice on the website or by email.

11.3. The current version of the Privacy Policy is always available on the website.

12. Contact

If you have any questions regarding the processing of personal data or this Privacy Policy, please contact us at kinga.elegant.investors@gmail.com.