Privacy Policy

Appendix No 1 to the Rules and Regulations of the bpower2.com Website – Privacy Policy

1. Introduction

1.1. The bpower2.com Privacy Policy defines the principles of processing and protection of personal
data of bpower2.com Service Users, hereinafter referred to as “Users”, collected and managed
Bpower2 LTD and includes all data collected in the bpower2.com database, hereinafter referred to as
“the Bpower2.com Data Collection”.
1.2. The purpose of this Privacy Policy is in particular to protect the personal data of bpower2.com
Website Users processed in the Bpower2 Data Collection by creating and implementing appropriate
procedures to ensure the security of the above data.
1.3. The phrases and expressions contained in this Privacy Policy have the meaning given to them in
the Rules and Regulations of the bpower2.com Website, unless any provisions of this Privacy Policy
state otherwise.

2. Data Administrator and Information Security Administrator

2.1. The Administrator of the Bpower2 Data Collection collected in connection with the use of the
bpower2.com Website is Bpower2 LTD, Caraven House 40-44 Uxbridge Road, London, United
Kingdom is responsible for the proper processing of all personal data collected in the Bpower2 Data
Collection, including personal data and other data whose processing has been entrusted by Bpower2
LTD to other entities on the basis of an appropriate agreement.
2.2. The implementation of this Privacy Policy is the responsibility of the Information Security
Administrator.

3. Compliance with the information requirement

3.1. Bpower2 LTD informs the Users about:
3.1.1. The address and full name of the data administrator of the Bpower2 Data Collection (see point
2.1).
3.1.2. The purpose of collecting their personal data, and in particular information known to them at the
time of providing the information or anticipated recipients of such data (or categories of recipients)
(see point 8.1);
3.1.3. Right of users to access and correct their personal data (see point 11);
3.1.4. Voluntary provision of personal data by Users (see point 5.3).
3.1.5. The information specified in point 3.1 is provided to the Users in a clear and understandable
manner in the registration form available on the bpower2.com website, and may also be provided in
any other manner that Bpower2 LTD deems appropriate.

4. Purpose of processing of personal data

4.1. Bpower2 LTD processes data collected in the Bpower2 Data Collection for the purpose of fulfilling
obligations towards Users of the bpower2.com Service resulting from the Rules and Regulations of the
bpower2.com Service and, in accordance with the content of Users' consent to process their personal
data for commercial, marketing and promotional purposes.

5. Legal basis for the processing of personal data

5.1. Bpower2 LTD processes Users' personal data in accordance with the law (legal basis: Article
23(1)(1) and (3) of Act of 29 August 1997 on personal data protection – uniform text Journal of Laws of
2002 No. 101 item 926, hereinafter referred to as “the Act”.
5.2. Bpower2 LTD processes Users' personal data for marketing and advertising purposes on the
basis of consent to join the bpower2.com Website.
5.3. Providing personal data by Users for the benefit of Bpower2 LTD is voluntary.
5.4. The User gives his/her consent to process his/her personal data referred to in point 5.2 by
electronic recording (by registering on the websites indicated in point 3.1) or in any other way specified
in the Rules and Regulations of the bpower2.com Website or indicated by Bpower2 LTD (e.g. on
survey forms or during a telephone conversation).
5.5. If the User does not consent to the processing of his/her personal data referred to in clause 5.2,
Bpower2 LTD processes the User's data pursuant to Article 23(1)(3) of the Act, only to the extent
necessary to fulfill the obligations of Bpower2 LTD towards such User resulting from the Rules and
Regulations of the bpower2.com Website.
5.6. Bpower2 LTD does not process the User's personal data for purposes other than those specified
in point 4.1, unless:
5.6.1. Bpower2 LTD is entitled under the Act to process the User's personal data for other purposes
without the User's consent,
5.6.2. Bpower2 LTD obtains the User's prior consent, expressed in an appropriate form, to the
processing of his/her personal data for other purposes.

6. Collection and further processing of personal data

6.1. Bpower2 LTD processes data obtained from Users as a result of joining the bpower2.com
Website (data contained in the Registration Form available on the websites indicated in point 3.2 or
transferred to Bpower2 LTD in any other way specified in the Rules and Regulations of the
bpower2.com Website or indicated by Bpower2 LTD);
6.2. Bpower2 LTD may use the User's e-mail address, mobile phone number or other electronic
communication media in order to fulfil its obligations towards Bpower2 Users, provide advice or
information on changes and novelties in services provided within the Bpower2 Website or conduct
other correspondence related to the Bpower2 Website. Such an address may also be, in relation to
Users who have granted the consent referred to in point. 5.2, used to send Users promotional,
marketing and advertising information.

7. Accuracy of personal data

7.1. Bpower2 LTD processes personal data of Users with such content as has been provided to it by
Users.
7.2. Bpower2 LTD updates the Users' personal data processed in the Bpower2 Data Collection as the
data is updated by the Users.
7.3. Each User should inform Bpower2 LTD about the change of his/her personal data, which are
processed in Bpower2 Data Collection, on the principles specified in the Rules and Regulations of the
bpower2.com Website, in order to enable Bpower2 LTD:
7.3.1. updating the personal data of a given User processed in the Bpower2 Data Collection, and

7.3.2. fulfilling the obligations of Bpower2 LTD towards the User resulting from the Rules and
Regulations of the bpower2.com Website.

8. Principles of personal data processing

8.1. Bpower2 LTD does not share personal data collected in the Bpower2 Data Collection with any
third parties, with the reservation that the personal data of Users who have given their consent to the
processing of their personal data by the Partners for marketing purposes may be made available to
Bpower2 Website Partners in accordance with the provisions of point 4.1.
8.2. Bpower2 LTD does not transfer, share or sell Users' personal data to any other entities or
individuals, with the reservation that Bpower2 LTD:
8.2.1. may transfer personal data of Users to Bpower2 Website Partners on the basis of the rules
specified in point 8.1, and
8.2.2. may outsource the processing of personal data in accordance with the principles set out in point
9.1.4. No personal data is shared by Bpower2 LTD with marketing agencies.
8.2.3. Bpower2 LTD may disclose personal data processed in the Bpower2 Data Collection if it is
obliged to do so under the provisions of law.

9. Protection of personal data

9.1. Bpower2 LTD takes all necessary actions to ensure protection of Users' personal data against any
unauthorized access or disclosure.
9.1.1. Bpower2 LTD protects personal data against unauthorized access, acquisition by an
unauthorized person, processing in violation of the Act, alteration, loss, distortion or unauthorized
removal.
9.1.2. Bpower2 LTD protects all Users' personal data, regardless of the type of medium on which they
are stored.
9.1.3. The following measures for the protection of personal data are used:
9.1.3.1. Physical protection measures, e.g. 24-hour security of the building where the servers
containing the Bpower2 Data Collection are located (e.g. using the monitoring system), use of
electronic locks for rooms and alarm system;
9.1.3.2. Organisational measures, e.g. limitation of access to the Bpower2 Data Collection, obligation
of employees admitted to processing personal data to maintain confidentiality, training of employees in
personal data protection legislation;
9.1.3.3. Software measures, e.g. authorization of access to the Bpower2 Data Collection by entering
passwords, use of screen savers, installation of devices eliminating disturbances and overvoltages in
the power supply network and devices supporting the power supply in the event of its failure,
application of data transmission security measures, e.g. data transmission using encryption
technology, protection of the server on which the bpower2.com Users Collection is located from the
internal and external network using the firewall, keeping logging register to the Bpower2 Data
Collection.
9.1.4. If Bpower2 LTD entrusts the processing of Users' personal data to another entity in accordance
with Article 31 of the Act, Bpower2 LTD obliges such entity to process personal data only within the
scope and purpose provided for in the relevant agreement between Bpower2 LTD and such entity and
in accordance with the instructions of Bpower2 LTD, including the protection of personal data. The

data processing entity applies the legally required physical protection measures, organisational
measures and software measures to protect personal data processed in the Bpower2 Data Collection.
Bpower2 LTD informs its employees about the policy and procedures of personal data protection.
9.1.6. If it is necessary to delete personal data from the Bpower2 Data Collection, such data are
deleted with special care, in such a way as to protect them from unauthorized access and in such a
way as to prevent their recovery.
9.1.7. Bpower2 LTD ensures supervision over what personal data, when and by whom they are
entered into the Bpower2 Data Collection and to whom they are transferred.
9.1.8. Bpower2 LTD maintains a register of persons employed in the processing of personal data
collected in the Bpower2 Data Collection. Persons who have access to such personal data are
required to keep it confidential, even after the termination of their employment.
9.1.9. Bpower2 LTD is not liable for violation of any data protection regulations by the operators of
websites that can be accessed via the web pages of bpower2.com and recommends that users of its
web pages read the data protection policy applied by such operator before disclosing any personal
data on such pages.
9.2. Cookies and Log Files
9.2.1. Cookies may be used in certain areas of the bpower2.com website. Cookies are small files
stored on a user's hard drive that track the website's navigation – for example, a cookie can be used to
store registration information so that the user does not have to provide it every time they visit the
website.
9.2.2. In order to create statistics of bpower2.com website users, Bpower2 LTD may register certain
information, such as domain or browser type, in order to identify user categories. The above
information does not allow to identify the user in any way.

10. Obtaining information

10.1. Bpower2 LTD makes this Privacy Policy available to Users and other interested persons on the
bpower2.com websites, referred to in point 3.2 or otherwise.

11. Control of personal data by the User

11.1. Each User has the right to control the processing of personal data concerning him/her collected
in the Bpower2 Data Collection, in particular:
11.1.1. The right to obtain comprehensive information on the existence of the filing system and to
establish the administrator, the address of its registered office and full name;
11.1.2. The right to obtain information about the purpose, scope and manner of processing of his/her
personal data;
11.1.3. The right to obtain information from when his / her personal data are processed in the data
filing system and the right to request the content of these data in a commonly understood form;
11.1.4. The right to be informed of the source of his/her personal data,
11.1.5. The right to obtain information on the way in which his/her data are disclosed, and in particular
on the recipients or categories of recipients to whom the data are disclosed,

11.1.6. The right to amend, update, rectify personal data, demand temporary or permanent
suspension of processing or their deletion, if such data are incomplete, outdated, untrue or
unnecessary for the purpose for which they were collected,
11.1.7. The right to submit a written and justified request to stop processing his/her personal data due
to his/her special situation, in the cases specified in the Act,
11.1.8. The right to raise an objection to the processing of his / her personal data in the cases
specified in the Act.
11.2. All requests and objections referred to in point 11.1 should be directed to Bpower2 LTD, to the
postal address or e-mail address office@bpower2.com and should identify the person making the
inquiry, request and objection (i.e. name, surname, date of birth of the person making the inquiry or
objection and mobile phone number).
11.3. The requests and objections referred to in point 11.1 may be made by the Users in any way,
however, for reasons of protection of personal data processed in the Bpower2 Data Collection,
Bpower2 LTD recommends that requests and objections be made in writing. The use of written form is
not intended to limit the User's control rights, but to protect his/her personal data against unauthorized
disclosure to third parties. Enabling the User to control the processing of personal data concerning
him/her requires identification of the person making the request or objection and documenting the
submission of such a request or objection.
11.4. The User may be charged with the necessary costs related to the fulfilment of information
obligations by Bpower2 LTD, referred to above. In any case, the User will be informed about the
amount of such costs before they are incurred by Bpower2 LTD.
11.5. The User may exercise the right to the information referred to in points 11.1 (11.1.1), (11.1.2),
(11.1.3), (11.1.4) and (11.1.5), not more frequently than once every 12 months.
11.6. At the request of the User, submitted in the manner provided for in point 11.2, Bpower2 LTD is
obliged to inform, within 30 days, about the rights granted to the User under the Act.
11.7. Bpower2 LTD has the right to refuse to provide information and provide access to data in cases
provided for in the Act.