SMASH/CAPITALISM

⊕ Legal

Privacy Policy

SMASH CAPITALISM · smashcapitalism.com · Version 1.0 · Effective Date: July 10, 2025

1. General Information

This Privacy Policy describes how SILVERMOOR CAPITAL PARTNERS sp. z o.o. (the “Controller”, “Seller”), owner of the SMASH CAPITALISM brand, processes personal data of users of the online store available at smashcapitalism.com.

The Controller makes every effort to ensure that Users’ personal data is processed in accordance with applicable law, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and the Polish Act of 10 May 2018 on the protection of personal data.

2. Data Controller

The controller of personal data is:

SILVERMOOR CAPITAL PARTNERS sp. z o.o.
ul. Chmielna 73B lok. 14, 00-801 Warsaw, Poland
NIP: 5273225634 · KRS: 0001250847 · REGON: 54516353300000
Email: contact@silvermoor-capital.com
Phone: +48 608 145 528

3. Scope and Sources of Data Collected

The Controller processes personal data that the User:

  • provides voluntarily in registration, order or contact forms (including: name, email address, delivery address, phone number),
  • generates while using the Store (including: IP address, browser data, purchase history, activity in the Store),
  • provides in connection with payment (including payment data processed by the payment operator – the Controller does not store payment card numbers).

4. Purposes and Legal Bases for Processing

4.1 Contract performance (Art. 6(1)(b) GDPR)

  • concluding and performing the Sales Agreement (order fulfilment, delivery, payments, issuing Proofs of purchase),
  • servicing the User’s Account in the Store.

4.2 Legal obligations (Art. 6(1)(c) GDPR)

  • fulfilling tax and accounting obligations (retaining documentation for the period required by law),
  • handling complaints and protecting claims.

4.3 Legitimate interest of the Controller (Art. 6(1)(f) GDPR)

  • direct marketing of the Controller’s own products and services (including newsletter – if the User grants separate consent),
  • analytics and site statistics (Google Analytics or an equivalent tool),
  • ensuring the security of systems and preventing abuse,
  • asserting or defending claims.

4.4 Consent (Art. 6(1)(a) GDPR)

  • sending newsletters and marketing communications by electronic means,
  • use of analytical and marketing cookies.

5. Data Retention Period

  • Data related to contract performance – for the time necessary to perform it, and then for the limitation period for claims (up to 6 years).
  • Data processed under a legal obligation – for the period required by law (e.g. 5 years for accounting documents).
  • Data processed based on consent – until consent is withdrawn.
  • Data processed under legitimate interest – until an effective objection is raised or that interest ceases.
  • User Account – until the Account is deleted by the User or the Controller.

6. Data Recipients

  • carriers and courier companies – to the extent necessary to deliver the Product,
  • electronic payment operators (e.g. PayU, Przelewy24) – for payment processing,
  • hosting and IT infrastructure providers,
  • the Controller’s accounting office and law firm,
  • providers of analytics and marketing tools (e.g. Google LLC) – on the basis of applicable data processing agreements,
  • public authorities authorised by law.

The Controller does not sell Users’ personal data to third parties.

7. Transfers Outside the EEA

In connection with the use of tools such as Google Analytics and related ones, data may be transferred to the United States or other third countries. The transfer takes place on the basis of standard contractual clauses approved by the European Commission or other appropriate mechanisms provided for by the GDPR. The User has the right to obtain a copy of the safeguards applied.

8. Users’ Rights

  • right of access (Art. 15 GDPR),
  • right to rectification (Art. 16 GDPR),
  • right to erasure – “right to be forgotten” (Art. 17 GDPR),
  • right to restriction of processing (Art. 18 GDPR),
  • right to data portability (Art. 20 GDPR),
  • right to object to processing (Art. 21 GDPR),
  • right to withdraw consent at any time, without affecting the lawfulness of prior processing,
  • right to lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office (PUODO), ul. Stawki 2, 00-193 Warsaw, www.uodo.gov.pl.

To exercise these rights, the User may contact the Controller at: contact@smashcapitalism.com or in writing at the registered address. The Controller will respond without undue delay, no later than within 3 months of receiving the request.

9. Cookies

9.1 The Store uses cookies – small files saved on the User’s device.

9.2 The following types of cookies are used:

  • Necessary (session and persistent) – required for the proper operation of the Store; their use does not require consent.
  • Analytical – enable analysis of traffic and user behaviour (e.g. Google Analytics); used with the User’s consent.
  • Marketing – enable the delivery of personalised advertising; used with the User’s consent.

9.3 The User can manage cookies via browser settings or the consent management panel available in the Store.

9.4 Disabling certain cookies may affect the functionality of the Store.

10. Data Security

The Controller applies appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction or disclosure, in particular:

  • encryption of data transmission (SSL/TLS – HTTPS),
  • encrypted storage of passwords,
  • access to data limited to authorised employees and collaborators,
  • regular security testing of IT systems.

11. Direct Marketing and Newsletter

11.1 With the User’s explicit consent, the Controller may send commercial information electronically (newsletter) to the provided email address.

11.2 The User may unsubscribe from the newsletter at any time by clicking the unsubscribe link in the email or by contacting the Controller.

11.3 Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

12. Profiling and Automated Decision-Making

The Controller may use profiling for marketing purposes (e.g. adjusting content to the User’s preferences). Profiling does not lead to automated decision-making producing legal effects or similarly significantly affecting the User.

13. Links to External Sites

The Store may contain references to external websites (e.g. social media). The Controller is not responsible for the privacy policies of those services. The User uses them at their own risk.

14. Changes to the Privacy Policy

The Controller reserves the right to change this Privacy Policy. The Controller will inform Users of any material change electronically (where possible) or through a visible notice on the Store’s website. The date of the last update is always shown in the document header.

15. Contact

For matters related to the protection of personal data, please contact:

SILVERMOOR CAPITAL PARTNERS sp. z o.o. – SMASH CAPITALISM
Email: privacy@silvermoor-capital.com
Correspondence address: ul. Chmielna 73B lok. 14, 00-801 Warsaw

President of the Personal Data Protection Office (supervisory authority):
ul. Stawki 2, 00-193 Warsaw | www.uodo.gov.pl