Privacy Policy

We appreciate the trust you have in us by entrusting us with your personal data, thus we take all reasonable measures to protect it. Below you will find information on how we collect and process your data when you use our website ( – hereinafter referred to as the “Website”).

Data Controller

The Data Controller of your personal data collected via the Website (hereinafter referred to as the “Website”), including in the case of logging in to the website available in the “Investor’s zone” tab (hereinafter referred to as “the Investor’s Zone”), as well as when using Leonarto’s websites on social networks are:

Leonarto Alfa Spółka Akcyjna ASI Spółka komandytowa – a Polish limited partnership with its main office in Wrocław, 141-155 Krakowska Street, 50-428 Wrocław, entered into companies register of the National Court Register (KRS) kept by District Court for Wrocław-Fabryczna in Worcław, VI Commercial Department under 0000807307, NIP: 8992789985 and

Leonarto Alfa Spółka Akcyjna – a Polish joint stock company with its main office in Wrocław, 141-155 Krakowska Street, 50-428 Wrocław, entered into companies register of the National Court Register (KRS) kept by District Court for Wrocław-Fabryczna in Worcław, VI Commercial Department under No. 0000697623, NIP (national tax identification numer): 8992829377

In case of data processed for purposes related to establishing contact using the data provided on the Website, the appropriate company to which the contact attempt is directed will be the data controller:

  1. Leonarto Alfa Spółka Akcyjna ASI Spółka komandytowa or
  2. Leonarto Alfa Spółka Akcyjna or
  3. Leonarto Funds SCSp with its main office: 2, Place de Strasbourg, L-2562 Luxembourg, entered into companies register in Luxembourg under No. B234200 or
  4.  Leonarto Management S.a.r.l. with its main office: 2, Place de Strasbourg, L-2562 Luxembourg, entered into companies register in Luxembourg under No. B233632.

“Leonarto”, “We”, “Our “,” Us “etc. means the Company which accordingly is the data controller of your personal data in a given case.

You can contact us in all matters regarding your personal data:: 

  1. by post – to the address: 
    • Leonarto Alfa Spółka Akcyjna ASI Spółka komandytowa / Leonarto Alfa Spółka akcyjna, 141-155 Krakowska Street, 50-428 Wrocław – in all cases regarding any of these two companies
    • Leonarto Funds SCSp / Leonarto Management S.a.r.l., 2 Place de Strasbourg, L-25652 Luxembourg – in all cases regarding any of these two companies
  2. by e-mail –  

Purpose and legal basis for processing personal data

We will process your personal data in order to:

a) respond to inquiries addressed to Us using the contact details provided on the Website – based on Our legitimate interest as a data controller,

b) keep statistics, analyze the way the Website is used, as well as improve its functioning – based on our legitimate interest as a data controller,

c) enable the use of services provided through the Investor’s Zone,

d) pursue and defend against claims, before courts and administrative bodies and outside them – based on our legitimate interest as a data controller.

Scope of processing personal data

The following categories of your personal data will be processed for the purposes indicated above:

  1. when you send a message to the Data Controller’s e-mail address given on the Website: e-mail address, date and time you send us your message, as well as other data that you include in your inquiry, such as your identification data or the content of the inquiry which you send Us,
  2. when you use the Investor’s Zone: username, e-mail address, other identification data, data on the use of functionalities provided by the Investor’s Zone,
  3. additionally, each time you visit the Website: data identifying the device you are using, the way you use our Website – we will protect data in this regard, however, in principle, we do not assign them to a specific person and they will be considered personal data only if they allow the identification of a specific person without excessive effort and costs.

Transfer of personal data

We will use due diligence in the selection of entities to which we will transfer your data and in the case of such selected entities we will require that they protect your data by appropriate technical and organizational measures. Your personal data may only be disclosed:

a) to third parties providing services to us that are needed to achieve the purposes in relation to which we process your data (e.g. IT services, electronic communication, hosting), as well as their subcontractors,

b) to entities from the Leonarto capital group (entities associated with Leonarto), in particular when they provide each other with services, or as part of the internal administrative purposes of the Leonarto group (e.g. when this results from the organization of tasks within the group),

c) to recipients to whom the disclosure is required by relevant law or order of a court or other authority,

d) to other recipients, if you give your consent to such transfer or if the transfer of data to them is necessary to protect your vital interests or vital interests of other individuals or for the common good.

The recipients of the data indicated above are based mainly in Poland, Luxembourg and other countries of the European Economic Area (EEA). For recipients outside the EEA, we will make sure that they guarantee a high level of personal data protection, including using standard contractual clauses approved by the European Commission or being participants of the EU-US Privacy Shield program,

Plug-ins and links to third party websites

The Website has a Facebook plugin that allows you to share news from the Website on your profile on this social network. Leonarto indicates that together with Facebook Ireland Limited (hereinafter “Facebook”) they act as joint controllers within the scope of processing your personal data for the purposes of statistics. Information on the principles of data sharing between Leonarto and Facebook can be found on this page:

Information on how Facebook processes personal data for statistical purposes is available here

We would also like to inform you that the Website may contain links to other websites, including profiles on social media belonging to Leonarto or to persons performing various functions in Leonarto. These pages have their own rules regarding the processing of personal data that you should read before using them.

Your rights

For each of the following rights, you can contact us in particular using the contact details provided at the top of this Privacy Policy.

a) The right to obtain information, access to data and to receive a copy of the data. You have the right at any time to request information about your personal data that we store or to which we have access. At your request, you will be presented with a free copy of your personal data being processed. For sending each subsequent copy of data we have the right to request a fee that will cover the reasonable costs of handling such a request.

b) Right to withdraw consent. Each time your data is processed based on the consent given, you have the right to withdraw this consent at any time, whereas withdrawal of consent will not affect the lawfulness of data processing before you withdraw your consent.

c) The right to rectify personal data. We take reasonable steps to ensure that your personal information is correct, complete and current. If it is necessary to change these data, please let us know.

d) Right to data portability. You have the right to request the transfer of personal data in a structured, commonly used machine-readable format, as well as to request the transfer of data to another data controller, when the basis for the processing of your personal data is consent.

e) The right to delete data and to limit processing. In the cases specified in the provisions on the protection of personal data, you have the right to request the deletion of your personal data. However, this right is not absolute – there may be occasions when we are still entitled to process your personal data. You can also request a restriction on the further processing of your data.

f) Right to object to processing. In the cases indicated in the provisions of law, you have the right to object to the further processing of your data, when the basis for the processing of personal data is our legitimate interest.

g) The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with the supervisory authority dealing with the protection of personal data – in principle, it will be the President of the Office for Personal Data Protection in the case of companies based in Poland (PUODO – Prezes Urzędu Ochrony Danych) and the Commission Nationale pour la Protection des Données (CNPD) in the case of companies with headquarters in Luxembourg.

Duration of processing of personal data

Your personal data will be processed:

a) for the purposes of replying to your contact request – from the day you forward us the question until we respond or resolve the matter in relation to which you are contacting Us,

b) in the case of data processing based on your consent – from the moment of granting Us this consent and for the time for which the data is necessary for the purpose for which it was collected, but not longer than until the consent is withdrawn by you,

for archival purposes as well as for investigation and defense against claims – from the moment of collecting your data and for the time during which our legitimate interest exists, no longer than for 6 years from the end of the year in which we collected the data, or until you effectively object to processing.

Cookies Policy

This Website uses cookies.

A cookie is a small text file placed on a computer or other device of a user entering the Website, which, among others enables specific functions to work properly. We also use cookies to collect statistical data on the number of people visiting the website and on how they use it. These data allow us to develop and optimize the Website. We also use cookies to remember the choices you made with the help of the Website, so that you do not have to make them repeatedly (e.g. regarding the language of the Webpage display or acceptance of cookies).

The data collected through cookies placed using our Website are used only for Our own purposes and not for the purposes of third parties. In particular, cookies allow Us to recognize the basic parameters of the user’s device and browser and display the Website accordingly. The cookies We use are not intended to collect and provide Leonarto with information that uniquely identifies you. However, sometimes such information will be collected as a result of combining with other data held by Leonarto, which may happen in particular when you use the Website to the extent that you need to log in to the so-called “Investor’s zone”.

The cookies we use can be deleted automatically when the user closes the web browser (so-called “session cookies”) or stored on the user’s computer or other device to improve future visits to the Website (so-called “persistent cookies”). Persistent cookies are automatically deleted after a specified period of time.

The Website does not use marketing cookies or analytics provided by third parties, nor does it use other similar techniques to track user behavior.

The Website contains plugins and links to other websites (such as social networking sites) whose administrators are other entities. On these pages, their administrators may place other types of cookies than those described above. We recommend that you always familiarize yourself with the rules on cookies used by these providers, which they make available on their websites.

How to avoid cookies?

You can block the use of cookies by changing your web browser settings in such a way that it automatically rejects the placement of cookies or informs you whenever the website requests to save a cookie. You can also delete previously saved cookies using a web browser. Blocking cookies may have a negative impact on the functioning of the Website.

Most web browsers allow some control over the use of cookies through browser settings. Instructions for managing cookies differ depending on the browser used. On the following pages you can get additional information – describing the possibilities of configuring cookies for the most popular browsers:

  1. Google Chrome
  2. Opera
  3. Firefox
  4. Apple Safari
  5. Windows Internet Explorer
Talk – Action = Bullshit