Article 1 Principle of Privacy Protection

1. The purpose of the present Privacy Policy of the Apart Group is to comprehensively determine the activities concerning the processing and protection of personal data collected in relation to the provision of services or sale of products, undertaken by:

1. Mennica Apart Sp. z o.o., with its registered office in Suchy Las (62-002), Stara Droga 3,

2. Apart sp. z o.o. with its registered office in Suchy Las (62-002), Stara Droga 3,

3. R2 Center sp. z o.o. with its registered office in Suchy Las (62-002), Akacjowa 1A,

4. E-R2 sp. z o.o. S.K.A., with its registered office in Suchy Las (62-002), Stara Droga 3,

5. E-R2 sp. z o.o. with its registered office in Suchy Las (62-002), Stara Droga 3,

6. R2 Investment Sp. z o.o. S.K.A. with its registered office in Suchy Las (62-002), Stara Droga 3,

7. R2 Investment Sp. z o.o. with its registered office in Suchy Las (62-002), Stara Droga 3,

8. APART Czech Republic s.r.o., Vavrečkova 7074, 760 01 Zlín, Czech Republic

9. Gold Mint sp. z o.o. with its registered office in Suchy Las (62-002), Akacjowa 1A,

10. Palladium Mint sp. z o.o. with its registered office in Suchy Las (62-002), Akacjowa 1A,

11. Platinum Mint sp. z o.o. with its registered office in Suchy Las (62-002), Akacjowa 1A,

12. Silver Mint sp. z o.o. with its registered office in Suchy Las (62-002), Akacjowa 1A;

(hereinafter referred to collectively as the "Apart Group"), (and each individually as an Administrator).

Definitions:

Administrator - each of the companies belonging to the Apart Group which, individually or jointly with others, determines the purposes and methods of personal data processing.

User (including the Client) - a person visiting Apart Group's websites, registering an account, making purchases, lodging complaints, receiving ordered commercial information/direct marketing from Apart Group, corresponding with Apart Group.

Data recipient - entities acting on behalf of Apart Group or entities entitled to receive the data by virtue of the binding legal regulations.

Personal data - described in detail in Article 2.

Apart Group runs the websites under the domains: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch governed by the present Privacy Policy.

1. The personal data controller, i.e. the Apart Group entity which decides how the personal data will be used, is each time the entity providing a given service (or sale). In case of any doubts as to the identification of the entity, a specific indication of the Personal Data Administrator is given in the regulations determining the principles of providing the service (or sale).

2. The Administrator shall exercise due care in selecting and applying appropriate technical and organizational measures to ensure the protection of the processed personal data. Personal data concerning the Users and other persons, whose data was reported by the User, are protected by the Administrator against their disclosure to unauthorized persons, as well as against other cases of their disclosure or loss or unauthorized modification of said data and information.

3. The recipients of the personal data are entities acting on behalf of the Apart Group and responsible for operating the websites under the domains: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch as well as entities rendering services to the Apart Group in this respect (e.g. entities providing Internet delivery services, entities rendering access to the server). Recipients may also include entities authorised to receive data pursuant to the binding provisions of law, including the competent judicial authorities.

Article 2 Basis, purpose and duration of the processing of personal data

1. Provision of personal data is voluntary, but failure to provide data may impede or prevent the proper performance of services, sales or after-sales support.

2. The scope of data collection

Personal data is indispensable for rendering services of the highest quality and for their development; therefore, Apart Group companies make every effort to secure your data properly and to process it only on the basis of relevant legal grounds. The scope of the collected data strictly depends on the type of service provided, i.e:

In addition, in order to adapt and develop the website's functionality, including its structure and content to the individual needs of Users and to maintain the safety and quality of services provided by the website, technology is used which collects and processes data stored in cookies, including the IP address (details described in Article 5 of the Privacy Policy).

3. Purposes and legal basis of data processing

Personal data are processed for the following purposes:

1. registering an account on the website and verifying the User's identity related to secure login - on the basis of the User's acceptance of the Terms and Conditions (Article 6 (1) (b) GDPR),

2. taking action at the User's request prior to concluding an agreement and performing the concluded purchase-sale agreement, including handling payments, delivery and information about the status of the order (in the form of SMS messages and/or e-mails), product reservations via the online shop in accordance with the Product Reservation Regulations and handling the complaint process - on the basis of acceptance of the terms and conditions of the online stores: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch (Article 6 (1) (b) of the GDPR)

3. making online purchases without registering a User account, including execution of online payment, sending information about the status of an order (in the form of SMS and/or e-mail) its delivery and handling the complaint process - on the basis of acceptance of the regulations of the websites: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch (Article 6 (1) (b) of the GDPR);

4. to enable sales on www.mennica.apart.pl in accordance with the applicable Buying Regulations of https://mennica.apart.pl/zakupy-online/regulamin-skupu (Article 6 (1) (b) of the GDPR);

5. to fulfil the Apart Group's legal obligations, in particular those related to preventing money laundering and terrorism financing pursuant to the AML Act, accounting and taxation, as well as for archiving purposes (Article 6(1)(c) of the GDPR);

6. sending marketing content via the communication channel the User has voluntarily agreed to, i.e. via electronic message to the e-mail address provided, for the purpose of presenting commercial offers and sending personalized information about the products and services of the Apart Group - based on the legally justified interest of the Administrator's legally justified interest (Article 6 par. 1 pt. f GDPR);

7. communicating with the User and replying to the messages sent using the contact form available on the websites: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch - based on the Administrator's legally justified interest consisting in building and developing relations with the Users (Article 6 par. 1 letter f GDPR);

8. adjusting and developing website functionalities, including its structures and content to Users' needs, creating aggregated statistics and maintaining safety and quality of services provided by the websites - based on the Administrator's legally justified interest (Article 6(1)(f) GDPR);

9. asserting or securing claims, delivering a purchase to a third party (other than the buyer) or adjusting and developing the websites: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch, including their structure and content to individual User needs as well as maintaining security and quality of provided services - which constitutes a legitimate interest of the Administrator (art. 6 par. 1 letter f GDPR);

10. to protect the interests of Users or to clarify the facts when dealing with disputes, irregularities or abuse, and technical issues related to server administration (IP addresses collected during Internet connections). Moreover, IP addresses are used to collect general, statistical information allowing, among other things, to determine the region from which the connection is made in order to determine the default language of the service interface and to adjust marketing content to individual User preferences;

11. consideration and execution of a complaint, or other notification of the Customer (e.g. in connection with planned purchases of goods or purchased goods) is carried out on the basis of performance of the contract (Article 6(1)(b) GDPR) or the legitimate interest of the Administrator (in the case of providing data to a third party (Article 6(1)(f) GDPR.

    Processed data may include: name, surname, address, e-mail address, telephone number, ADC loyalty card number. The data will be processed for the period necessary for the execution of the concluded agreement and the fulfillment of legal obligations incumbent on the administrator, and after that time for the period required by law or for the realization of possible claims;

12. The Administrator may process third party data provided by the Users for the purposes of communication, recommendation, use of the Administrator's services, including in particular conclusion or performance of the agreement concluded through the tools made available on the apart.pl website. By entering such data, the User declares that he/she has obtained the necessary consent from the person whose data is entered to make his/her data available to the Administrator;

13. Data of the Users can be made available to other Users in the case when it is necessary for the performance of the agreement.

4. Period of personal data processing

1. Personal data will be processed for the period in which a person remains a registered user of the websites: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch, and after this period for the time necessary to comply with the law or to assert or defend against possible claims.

2. Personal data collected for the purposes of executing a sales contract will be processed for 5 years calculated from the end of the calendar year in which the purchase was made.

3. Data collected for the purposes of AML processes will be processed for 5 years from the first day of the year following the year in which transactions or business relations with the User in question ceased.

4. Purchases made on-line, which are not paid within 7 days of completing the purchase form on the websites: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch, will be cancelled, while personal data indicated in the forms will be processed for the time of defense or investigation of possible claims in accordance with applicable law.

5. Personal data of persons who contacted us via the contact form available at: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch will be processed for a period of 1 year counting from the end of the calendar year in which the contact was made.

6. Data collected during communication with the User via the Online Chat application will be processed until the chat session ends/archived to demonstrate the conversation in the future.

7. Data collected for the purpose of sending marketing content will be processed until raising an objection to the processing or until withdrawal of consent for the chosen communication channel, in respect of which such consent has been granted.

8. Data collected for the purposes of adapting and developing the functionality of the websites: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch will be processed until the moment the User raises an objection to processing or until they become obsolete.

9. If the processing is based on the consent given by the User, the data will be processed until the purpose for which it was collected is fulfilled or until the consent is revoked, depending on which of the events occurs first.

Article 3 Control over processing of personal data

1. The controller shall ensure that persons whose personal data are processed by the controller exercise their rights under the law, including the right of access to the content of their own personal data, their rectification, amendment, erasure or transfer, and also the right to request restriction of the processing of personal data and to object to such processing on the terms specified by the relevant legislation.

2. In the case of voluntary consent to data processing, each person whose data are processed has the right to withdraw consent to data processing.

3. Each person whose data are being processed has the right to lodge a complaint to the President of the Office for Personal Data Protection.

4. The Administrator appointed the Data Protection Inspector, which is Natalia Dzieciuchowicz. The Data Protection Inspector can be contacted in any matter concerning the processing of personal data via e-mail: iod@apart.pl.

Article 4 Transfer and sharing of personal data

1. Users' data may be made available to entities entitled to receive them under the applicable provisions of law, including the competent judicial authorities.

2. Personal data may be provided to Data Recipients who are service providers performing specific tasks on behalf of Apart. These include entities which provide Apart with:

   • technology-related services (e.g. support of the Apart Website, Mobile Applications),

   • payment processing in the on-line store,

   • courier services.

3. Personal data processed by an entity belonging to the Apart Group may be transferred between the companies belonging to the Apart Group on the basis of a co-management agreement.

4. The Users' personal data may be transferred to PayPo sp. z o.o. with its seat in Warsaw, 39 Domaniewska Street, Warsaw (postal code: 02-672) in the event of the User's wish to use the "Smart Plan" service available through the Apart Application or the "Zapłać 30 Days" service available in the Apart online shop. The data is transferred on the basis of the User's consent, and at the moment of its receipt, PayPo sp. z o.o. becomes its separate administrator and processes it for its own purposes.

5. Users' personal data may be transferred to third parties in cases not indicated by the Administrator or legal regulations, only upon the consent of the data subject.

6. Personal data may be transferred to third countries (outside the countries belonging to the European Union) in connection with the delivery of Products ordered by the Users.

Article 5 Cookie Policy

1. The controller automatically collects information contained in cookies, i.e. small text information, such as the date of connection to the website and the IP address of the device, stored on the terminal equipment (e.g. computer, laptop, tablet or smartphone) of persons using the websites: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch.

2. The purpose of cookies is:

   • adapting the content of the websites: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch to individual preferences and needs of the User,

   • optimizing the use of the sites,

   • creation of aggregated statistics in order to improve website functionality, its structure and content,

   • ensuring safe provision of services by electronic means, including maintaining a session of a User of the Services after logging in and recognizing the User of the Services at the next session,

   • facilitating browsing through the resources of the websites during subsequent visits,

   • display behavioral advertising to provide Users with advertising content tailored to their interests or profiles, may also be used to display advertisements outside the Services (also using so-called third party cookies).

Third party cookies are used for retargeting advertising and behavioral advertising. By adding tags to a page, advertisers can track a User online as they visit different websites. This allows advertisers to create a profile of the User based on their search habits so they can deliver more relevant content.

3. Due to the necessity to provide the service, Apart Group uses 3 types of cookie files:

• Necessary - absolutely necessary for the proper functioning of the website or the functionalities the User wants to use. They are stored on the device for one day.

• Analytical - called statistical - collect information on how often the website is visited and how it is used. This aggregated and anonymous information is used to improve the content and performance of the website - without consent this is not possible. Stored on your device for up to 2 years.

• Advertising - also known as marketing - allows us to display ads tailored to the profile of the user visiting the site. Based on browsing history, profiles are built that are shared with advertising partners so that personalized ads can be displayed on other sites. They are stored for 1 year.

4. Due to the time for which a cookie will be placed in the User's end device:

• Session - temporary, which remain in the memory of User's browser until the moment of leaving apart.pl website - they are obligatory for proper operation of selected applications and proper display of the website content,

• Permanent - used in order to make the website more attractive for the User, they are not deleted after closing and are stored on the User's device between sessions. They are used, among others, to remember User preferences while using the website or to display personalized advertising.

5. Cookies do not contain contact data of the User: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch,

6. The User decides which cookies and how they are stored by himself through the settings of his web browser (commonly used: Mozilla Firefox, Internet Explorer, Google Chrome, Opera, Safari). The default settings of browsers allow you to store cookies.

7. Deleting cookies - by default, the software used for web browsing allows you to place "cookies" on your terminal device. These settings can be changed in such a way as to block the automatic handling of cookies in the web browser settings or inform on their sending to the user's device each time. Detailed information on the possibility and the ways of handling "cookie" files is available in the software (internet browser) settings.

8. Apart Group informs that restricting or blocking the cookies files may adversely affect the selected functionalities available on the following websites: www.apart.pl, www.mennica.apart.pl, www.apart.cz, www.apart.eu, www.artelioni.pl, www.artelioni.com, www.aztorin.com, www.elixa.net, www.ampm-watches.com, www.albertriele.ch, www.bergstern.ch.

The cookie files recorded in the website User's terminal equipment may be used by trusted entities cooperating with the Apart Group.

GOOGLE ANALYTICS

The website uses Google Analytics, a website viewer analysis service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use it. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in various countries around the world. More about Google's privacy policy can be found at https://policies.google.com/technologies/partner-sites. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

If the User wishes to disable the transmission of information to this service, he/she can use a free Browser Add-on to block Google Analytics..

This privacy and cookie policy is subject to change due to:

• obligation to make changes,

• change of legal regulations,

• scope of cookies used by this website.