Privacy Policy - Elemental Asia

Privacy Policy

Privacy Policy of Elemental Asia SA


At Elemental Asia Group – – we protect the privacy of those who contact us. This policy explains how we process personal data and the rights of the individuals whose personal data we process.


Updated on March 26, 2020


The data controller of the personal data provided to Elemental Asia S.A. is:
Elemental Asia S.A., located in Grodzisk Mazowiecki, at Traugutta 42A, 05-825 Grodzisk Mazowiecki, entered into the business registry maintained by the District Court for the Capital City of Warsaw in Warsaw, XIV Commercial Division of the National Court Register under the number KRS: 0000426498, Tax Identification Number NIP: 8971743506, National Business Registry Number REGON: 020739787 (hereinafter referred to as “the Data Controller”).


For any questions, comments, or requests regarding your personal data, please contact the above address of the Data Controller or by email at:


Personal Data.
The contact form on our website collects the following personal data:
first and last name, email address, phone number. Providing this personal data is entirely voluntary. If you do not provide your data, or if you provide incorrect data, the Data Controller will not be able to respond to the submitted information.


Legal Basis for Processing Personal Data
The Regulation of the European Parliament and of the Council (EU) 2016/679 of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”) – Article 6(1)(a), (c), (d), (f) GDPR.


Purpose of Processing Personal Data.
The Data Controller processes personal data for the purpose of:
A. responding to individuals who provide the Data Controller with information via the online contact form and have given their consent in this regard;
B. fulfilling legal obligations incumbent on the Data Controller, e.g., for detecting or preventing unlawful acts as per the law;
C. protecting the vital interests of the data subjects or another natural person in a situation that threatens those interests;
D. realizing the Data Controller’s legally justified interests, such as:
a. ensuring effective communication with the market environment, in particular with individuals who contact us;
b. ensuring the use of our website in accordance with the law and good practices, including establishing, investigating, or defending the Data Controller’s claims;
c. improving the quality and transparency of the website’s operations; and
d. maintaining efficient business management and relationships within the Data Controller’s capital group.


Period of Storing Personal Data.
Personal data is always stored or processed to the extent necessary to achieve the specific purpose of processing.
In the case of:
a) expressed consent, it will be stored or processed until you notify us of its withdrawal or restriction;
b) a legal obligation incumbent on the Data Controller (in Polish or EU law), it will be stored or processed in accordance with such a legal obligation;
c) necessary for the protection of vital interests of the person concerned or another natural person, it will be stored or processed until the threat to these vital interests or legally protected goods ceases;
d) legally justified interests pursued by the Data Controller, it will be stored or processed until an objection is raised or the pursuit of such an interest ends.


Rights of Individuals Whose Personal Data Is Processed by the Data Controller.
A. The right to access personal data – anyone can find out if their personal data is stored by the Data Controller, and if so, how.
B. The right to rectify personal data – anyone can correct, modify, update their personal data concerning them.
C. The right to be forgotten – the Data Controller deletes personal data and ceases their processing if the data are no longer necessary for the purposes for which they were collected or processed, if the person to whom the personal data relates withdraws their consent to their processing, requests a restriction of their processing, or expresses an objection to their processing. Exception – further retention of personal data by the Data Controller should be considered lawful if it is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for the performance of a task carried out in the public interest, on grounds of public interest in the public health sector, for archival purposes in the public interest, for scientific or historical research purposes or statistical purposes, or for the establishment, exercise or defense of legal claims.
D. The right to withdraw consent – at any time, one can withdraw or modify the consent granted for the processing of personal data.
E. The right to data portability – the data subject has the right to receive personal data concerning them, which they have provided to the Data Controller, and has the right to transmit those data to another controller.
F. The right to object – the person whose data the Data Controller processes may object to the further processing of their personal data concerning their particular situation. In the objection, it is necessary to provide information that will allow the Data Controller to assess whether the interests or fundamental rights and freedoms of the person have a priority over the Data Controller’s important legally justified interests.
G. The right to lodge a complaint with a supervisory authority – in case of reservations about the way we process personal data, a complaint can be made to the Personal Data Protection Office


The Data Controller will respond to inquiries or requests from the data subjects without undue delay – at the latest within one month of receiving the notification.


Cookies are text information stored on the device used to browse a website. Cookies on our site do not collect any personal data about users (they do not contain any tracking codes).


Types of cookies and the purpose of their use:
A. Functional.
By default, currently, the only consent stored in cookies is the consent to the use of cookies on the site and the choice of the website’s language. This consent is stored for 30 days. It is practically used only to avoid displaying the cookie consent notice each time and to display the site in the preferred language. This is to facilitate the use of our site for returning Users.
B. Analytical – Google Analytics. Google Analytics collects its own cookies, which are data related to the device and browser, IP address, and user actions on the site or application, to measure and report statistics of user interactions with websites or applications that use Google Analytics. Customers can customize cookies and collected data using features such as cookie settings, User-ID, Data Import, and the Measurement Protocol platform. More information:


Website users can block cookies at any time in their web browser settings.


Security of Transmitted Data.
We make every effort to ensure that data transmitted through our website is secure against unauthorized use (e.g., preventing impersonation). However, the security of data transmission over the Internet cannot be guaranteed 100%, so transmitting personal data to us involves a risk of unauthorized interception.


We ensure the protection of collected, stored, and processed personal data in accordance with the Personal Data Protection Policy of Elemental Asia Capital Group.


The Data Controller does not knowingly collect personal data from persons under the age of 16.


Changes to the Privacy Policy.
The Privacy Policy of Elemental may be changed from time to time. The current version is published on our website
We will contact individuals whose personal data we process if a change in privacy policy would imply any limitation of their rights, or in the event of a change in the Data Controller.

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