Privacy Policy

Regulations of Averton Sterling sp. z o.o. of 02.11.2020



The expressions used in these Regulations mean:

Civil Code – means the Act of April 23, 1964 – Civil Code (consolidated text: Journal of Laws of 2018, item 1025, as amended);

Privacy Policy – means a document called “Privacy Policy” available for download on the Website’s website;

Project initiator – means a natural or legal person or an organizational unit without legal personality intending to establish cooperation with Averton Sterling sp. Z oo;

Regulations – means these “Regulations for the use of the website

Website – means a website located on the Internet available at and all functions and tools available through this website;

Administrator – means the company Averton Sterling limited liability company with its registered office in Warsaw, entered in the register of entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Division of the National Court Register under the number KRS 0000845226;

User – means any natural person who in any way uses the resources of the Website;

Website Resources – means materials made available on the Website, on the terms and to the extent specified in these Regulations


These Regulations define the rules of free and unlimited use of the Website by users, maintained and administered by the Administrator.

By using the Website, you accept the provisions of these Regulations and agree to comply with them.

The subject of the Regulations is not to define the rights and obligations or any other elements of the legal relationship between:

The Administrator and Project Initiator, which are the subject of a separate agreement, or the User and Project Initiator, which are specified on the Campaign pages.


The website enables Users to access information about the activities of Averton Sterling sp. z o.o.


Access to the Website Resources does not depend on the User’s fulfillment of any formalities, in particular on the User’s registration in the Website system.

Using the Website requires:

– devices with Internet access with an installed web browser;

– cookie acceptance enabled in the web browser used;

– pop-up support enabled.

The Administrator provides an unregistered User with free access to the Website Resources for an indefinite period.


The User is obliged to use the Website in accordance with the law, the provisions of the Regulations and good manners.

The User is entitled to use the Website Resources only for personal use. This means in particular that with regard to data and any other materials contained in the Website Resources, both those that are protected under copyright law and those that are not subject to such protection, it is not allowed to use these materials for the purpose of conducting by the User. commercial activity.


The Administrator reserves the right to block the User’s access to the Website Resources at any time in the event of a breach by the User of the terms of its use, in particular in situations of violation of the law or good manners, including the content of information and texts posted on the Website, such as and in relation to the Administrator.

Blocking access to the Website Resources is tantamount to termination of the Agreement by the Administrator.


Users’ personal data are processed on the terms set out in the Privacy Policy available on the Website. The User should read the Privacy Policy before providing or transferring any data to the Administrator.


All intellectual property rights, including in particular copyrights and trademark rights in relation to all materials, texts, illustrations, sounds, software and other Website Resources and their layout, are the property of the Administrator or are subject to permission for their use granted by the owner (administrator) of these rights.

The User may print parts of the Website or download them to the computer’s hard drive and pass them on to third parties, provided that he does so solely for information purposes or for other purposes permitted under applicable law.

Without the prior written consent of the Administrator, the User may not:

– use the Website (including a copy or part thereof) or markings contained in the content of the Website for commercial purposes;

– modify the Website (its parts) or incorporate it into the content of other studies (including paper documents, websites, blogs, third party accounts on social networks).


The Administrator is not responsible for the actions of third parties operating the Website’s IT system, as well as for damages resulting from damage to the User’s computer equipment or its data resources, during or in connection with the use of the Website Resources, in particular as a result of getting into the User’s IT system. computer viruses.

The Administrator shall not be liable for technical malfunction of the Website beyond its control and for interruptions in the availability of the Website or Website Resources due to a failure of the telecommunications communication system and for other effects of malfunctioning of telecommunications lines and damages caused by them.

In no event is the Administrator liable for any indirect damage resulting from the use of the Website.

The Administrator is not responsible for the content published on the Campaign websites, in particular those available in the domains or subdomains of third parties, including Project Initiators. In particular, the Administrator is not responsible for the truthfulness, reliability and completeness of information regarding the Campaign or Project Initiator. The entity responsible for the truthfulness, reliability and completeness of the information published on the Campaign website and the documents available on them rests solely with the Project Initiator.

Legal reservations

Some information provided on the Website is of a historical nature and may be out of date. All information of a historical nature should be considered current at the time of its first publication. The administrator is not obliged to update the published information.

The website contains hypertext links to other websites. The administrator has not read and does not bear and does not accept any responsibility for information or opinions presented on other websites.

The administrator does not perform the function of an offeror with regard to any financial instruments, does not provide investment advisory services, offer or accept and transmit orders for financial instruments, or any other activities requiring a permit to conduct brokerage activities. Information on the fact of conducting a public offering of financial instruments is published on the Website’s Resources only as part of promotional campaigns conducted by Project Initiators, but only to the extent that they do not constitute the basis for a decision to purchase a given financial instrument. All information on financial instruments to which the offer relates to such a promotional campaign, terms of purchase of financial and other instruments related to the public offering, as well as information on risks and other required by law are available only from the Project Initiator or in the materials presented by him, and all activities aimed at financial instruments are purchased only between the buyer and the Project Initiator, without the intermediation of the Administrator. The administrator does not provide any information about the Project Initiator or the offers of financial instruments conducted by him.

The Administrator does not examine the adequacy of participation in a given Campaign by the User.

The materials posted on the Website Resources do not constitute an offer within the meaning of Art. 66 of the Civil Code. None of the entries made available on the Website Resources constitute any investment, legal or tax recommendation or advice, nor is it an indication that any investment or strategy is appropriate in the User’s individual situation.

The Administrator is not responsible for the effects and consequences of decisions made by Users in relation to the Campaign, including financial instruments offered by the Project Initiator.

Users should analyze and evaluate the information contained on the Campaign pages on their own, and their decision to participate in the Campaign should be based on such analysis as they consider appropriate.

The Administrator does not accept, transfer or store funds paid by Users as part of the Campaign, nor does it provide any other payment services.

The Administrator does not make any declarations relating to tax issues that could be related to payments or receiving funds related to financial instruments or other property rights offered in connection with the Campaign or any Project Initiator’s benefits. It is advisable that any User considering participation in the Campaign should seek the advice of a professional consultant in this regard and on all tax aspects related to financial instruments or other rights acquired under the Campaign.

Comments, comments, complaints

Any comments, comments and questions regarding the operation of the Website can be sent to the address of the Administrator’s seat and at the following e-mail address:

The User has the right to file a complaint regarding the functioning of the Website.

Complaints about the Website should be directed to:

– via e-mail to the e-mail address;

– by letter to the following address: Averton Sterling limited liability company, ul. Poznańska 37, 00-689 Warsaw

Immediately after considering the complaint, but not later than within 30 days from the date of its receipt, the Administrator shall notify in writing or in another form agreed with the User about the method of its consideration.


The Regulations act as general terms and conditions of contracts within the meaning of the Civil Code.

We reserve the right to make changes to these Regulations. In the event of a change to the Regulations, its delivery to the User will take place by posting the new content of the Regulations on the Website. The changes are effective from the moment they are introduced.

The Regulations are made available free of charge to Website users who can obtain, reproduce and save them via the Internet.

These Regulations and the use of the Website by Users are subject to the provisions of Polish law.

Disputes arising in connection with the implementation of these Regulations will be settled amicably, however, in the event of failure to reach an agreement, they shall be settled by the competent court.


1. General provisions

The Policy defines the rules for the protection and processing of Personal Data of Averton Sterling Users and Associates by the Personal Data Administrator (Website Operator) in connection with the provision of services by him in the field of fund manager activities, including the Website with all its functionalities.

2. Personal data processed by the Administrator

The User may provide personal data by:

By giving your details orally during a phone call

By sending an e-mail to the contact address

Other forms available on the Website.

Depending on the method and circumstances of providing, the User provides the following Personal Data: name, surname, login, e-mail address, correspondence address, bank account number, addresses of profiles on social networks, own website address, tax identification number, company name, form legal company, photo.

The administrator may also process personal data provided by persons sending him CVs, cover letters and other similar documents for the purposes of the recruitment process.

In addition, we can process the so-called operational data that characterize the way you use our websites, such as: IP address; digital logs; information about the use of the Websites; browser type; domain name; operating system type.


1. General principles

The cookies policy of the website is addressed to the Users of this website and defines the method of using cookies .

The administrator of cookies (hereinafter also: “Service Provider”) is Averton Sterling Sp. z o. o. entered into the National Court Register under the number 0000845226.

Files Cookies (so-called. “Cookies”) are computer data, including text files, which are stored in the terminal’s website. Files Cookies contain the name of the website from which time store them on a terminal device and a unique number.

Files Cookies remember user preferences. This allows you to improve the quality of services provided, improve search results and the accuracy of the information displayed, and track User preferences. The user may opt out of cookies by selecting the appropriate settings in the web browser used by him. These settings can be changed in particular in such a way as to block the automatic handling of these Files in the web browser settings or to inform about their every posting on the Website User’s device. Detailed information on the possibilities and methods of handling Cookies is available in the settings of the appropriate web browser.

Consent to store or access Cookies by Averton Sterling Sp. z oo on the User’s device, the User expresses it by means of the browser settings that are installed on the User’s end device.

The entity placing Cookies on the User’s end device and at the same time the administrator of these files is Averton Sterling Sp. z o. o. (KRS 0000845226).

Files Cookies are used to:

– adjusting the content of the website of Averton Sterling Sp. z o. o. to the User’s preferences and to optimize the use of the website;

– creating statistics that help to understand how Users use the Averton Sterling Sp. z o. o., which enables the website content to be improved;

– recording potential errors and responding to them.

The website uses the following types of Cookies , i.e .:

– session files, which are temporary files and are stored on the User’s end device until they leave the website or turn off the software;

– permanent, which are stored on the User’s end device for the time specified in the parameters of Cookies or until they are deleted by the User.

The condition for the operation of Cookies is their acceptance in the browser and not deleting them. In many cases, the software used for browsing websites allows cookies to be stored on the User’s end device by default . The Website Users can change their cookie settings at any time .

Our Websites may use cookies ( cookies ), which are used to identify the visitor’s browser while using the Administrator to see the Administrator, which page to the visitor. Cookies also allow you to customize services and content to the individual needs and preferences of Users (including the remarketing service ), as well as to develop general statistics on the use of our Sites by visitors.

The user can specify the conditions for the use of cookies and completely disable the option to save cookies using the settings of your web browser. Disabling the option in the web browser that allows you to save ” cookies ” or specifying the conditions for their use does not generally prevent the use of our Sites, but may cause some difficulties. To opt out of the Google Network cookie, you must opt ​​out of Google’s third-party service on the Network Advertising page .

The use of Cookies does not change the User’s telecommunications end device (i.e. a computer) and the software installed on this device. Cookies do not contain any personal data.

2. For what purposes are personal data processed?

The User’s Personal Data is processed in order to:

– Use the functionality of the Website in accordance with the Regulations of the Website

– Contact with the User

– Concluding and performing contracts with the User

– Conducting competitions

– Marketing, i.e. for the purposes of advertising, market research and User behavior and preferences, with the purpose of the results of these studies for the purpose of improving the quality of services provided by the Website Operator

– Sending a free newsletter containing commercial information, if the User agrees

– Sending the User commercial information regarding the services offered by the Website Operator and by entities cooperating with him – if the User agrees to it

– Participation in the loyalty program run by the Website Operator – if the User agrees.

The Administrator may send to the User, by e-mail or via SMS, regardless of the fact that the User agrees to receive commercial information, information that does not constitute commercial information or marketing materials, and necessary for the User to use the services of the Website Operator, enforce legal regulations, fulfill the obligation resulting from legal provisions or a contract, as well as information about new functionalities of the Website, as well as information about Averton Sterling projects .

In addition, the User’s Personal Data may be processed by the Administrator in order to:

– conducting contests, e.g. to notify about the victory and to promote other products – if the Contests are organized – if the User agrees;

– sending commercial information to the User – if the User agrees;

– marketing, i.e. for the purposes of advertising, market research and user behavior and preferences, with the purpose of the results of these studies for the purpose of improving the quality of services provided by the Administrator and participation in the loyalty program – if the User agrees.

The consent referred to in paragraph 1. 3, the User may cancel at any time by sending an e-mail to the address

In addition, the personal data of the Associates are processed in order to conclude and perform contracts.

3. Who can access personal data?

The User’s Personal Data is accessed by:

– Administrator;

– State authorities for the purposes of their proceedings, if these authorities are entitled to do so on the basis of separate regulations (e.g. the prosecutor’s office, court, Police, Ombudsman) and in other situations, when we are obliged to do so by mandatory provisions of law;

– Administrator’s employees and persons or entities providing services to him (e.g. programmers, IT specialists, security administrators, system administration and maintenance entity, financial advisors, trainers) – to the extent specified by the Administrator.

4. What happens to Personal Data if the User stops using Averton Sterling’s services ?

As a rule, the Administrator does not delete the User’s Personal Data, unless he receives a clear message with a request to delete it.

Exceptionally, in accordance with the applicable law, the Administrator may process the Personal Data that:

– they are necessary to settle the Service and pursue claims for payments for using the Service. The settlement of the Service presented to the User will not disclose the type, duration, frequency and other technical parameters of the individual Services he used, unless the User has requested detailed information in this regard;

– are necessary to explain the circumstances of unauthorized use of the Services;

– are allowed for processing on the basis of separate laws or contracts;

– in the case of operational data – they are necessary to detect technical faults and errors in the transmission of messages.

In addition, in the event of unauthorized use of the Services by the User (i.e. contrary to the Regulations or applicable regulations), the Administrator may process the User’s Personal Data to the extent necessary to determine liability, however, for evidence purposes, the Administrator is obliged to record the fact of obtaining and the content of the message about unauthorized use of the Services.

5. What are the rights of the user regarding his Personal Data?

The user has the right to request the deletion of his personal data. For this purpose, please send an e-mail to: In certain cases (when these data are necessary to use the Services), such a request is tantamount to reporting the intention to terminate the use of the Services. The user will be informed about this before the irretrievable deletion of his personal data. In addition, deleting some data may make it difficult to use some Services (e.g. failure to provide a phone number will result in the inability to contact by phone).

The user always has the right to request access to the content of his data, supplementing, changing or deleting it, subject to the data that we will remain entitled to process under the law. He also has the right to request the restriction of processing and transfer of his personal data. He will do this by sending an e-mail to the following address:

The user always has the right to lodge a complaint with the supervisory authority (GIODO / PUODO).

If the processing is based on consent, the User has the right to withdraw it at any time without affecting the lawfulness of the processing which was carried out on the basis of consent before its withdrawal. This will be done by sending an e-mail to the following address:

If the processing is based on the justified purpose of the data controller, which is direct marketing, the User always has the right to object to this processing. This will be done by sending an e-mail to the following address: