1. GENERAL PROVISIONS

1.1. This Balmain Group Privacy Policy (hereinafter: the “Privacy Policy”) provides information on the fundamental principles of processing and protecting personal data collected by the companies belonging to the Balmain Group from data subjects. The Privacy Policy is for information purposes only, which means that it does not constitute a source of obligations for individuals whose personal data are processed in accordance with its provisions. One of its main purposes is to fulfil the information obligation referred to in Articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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, hereinafter the “GDPR”).

1.2. The Balmain Group, i.e. Balmain Asset Management CEE sp. z o.o., with its registered office in Warsaw, ul. Sienna 39, 00-121 Warsaw, entered into the Register of Entrepreneurs of the National Court Register under number 0000249204, NIP (Tax ID): 1070002915, REGON: 140321307, and Balmain Property Management sp. z o.o., with its registered office in Warsaw, ul. Sienna 39, 00-121 Warsaw, entered into the Register of Entrepreneurs of the National Court Register under number 0000635690, NIP (Tax ID): 5252675289, REGON: 365366942 (hereinafter jointly referred to as the “Balmain Group”), act as joint controllers of personal data within the meaning of the GDPR.

This applies to data collected from users of the website available at https://balmain-am.com/ including through tracking user activity on the website, as well as in any other situation where personal data are voluntarily provided in connection with the use of Balmain Group’s services, entering into contracts with any of the Balmain Group companies, submitting enquiries to the Balmain Group, exchanging correspondence, or using services made available via the website.

1.3. For any matters related to the processing of personal data by the Balmain Group, you may contact us by sending an email to: warsaw@balmain-am.com

1.4. This Privacy Policy is of a supplementary nature in cases where, when collecting your personal data, the Balmain Group provides you with a specific information clause containing detailed information on the processing of personal data obtained in a particular context. In the event of any discrepancies, such specific information clauses shall prevail.

2. PURPOSES AND LEGAL BASES OF PERSONAL DATA PROCESSING

2.1. The Balmain Group collects only such personal data as are necessary to achieve the purposes for which the data have been obtained. If additional, optional information is required, the Balmain Group will inform you of this before collecting such information.

2.2. Personal data collected by the Balmain Group — including the personal data of all users of the website (such as IP addresses or other identifiers, as well as information collected through cookies or similar technologies) — are processed by the Balmain Group depending on the context in which the data were provided, namely:

a. for the purpose of establishing, shaping the content of, amending, terminating, and properly performing contracts (including contracts for the provision of electronic services available via the Balmain Group’s website) concluded with the Balmain Group, or to take steps at your request prior to entering into a contract (including the process of preparing an offer) — in such cases, the legal basis for processing is the necessity of processing for the performance of a contract with the Balmain Group (Article 6(1)(b) GDPR);

b. for the purpose of handling any complaints you may submit — the legal basis for processing is likewise the necessity of processing for the performance of a contract with the Balmain Group, under which the complaint is made (Article 6(1)(b) GDPR);

c. for the purpose of fulfilling legal obligations to which the Balmain Group is subject (e.g. obligations arising under accounting, VAT or CIT regulations) — the legal basis for processing is Article 6(1)(c) GDPR;

d. for analytical and statistical purposes (e.g. creating reports and analyses for the Balmain Group concerning the functioning of its websites, including page view statistics, and adapting the websites to user needs) — the legal basis for processing is the legitimate interest of the Balmain Group (Article 6(1)(f) GDPR), consisting of analysing user activity and preferences in order to improve the functionalities and services provided;

e. for the establishment, exercise, or defence of legal claims — the legal basis for processing is the legitimate interest of the Balmain Group (Article 6(1)(f) GDPR), consisting of protecting its rights;

f. for marketing purposes of the Balmain Group and other entities — the legal basis for processing is consent (Article 6(1)(a) GDPR), which you may withdraw at any time.

2.3. Personal data shall not be used for purposes other than those specified in this Privacy Policy, unless the Balmain Group obtains your additional consent to process the data for other specified purposes or unless such further use is required or permitted by law.

2.4. Consent may take the form of ticking a checkbox when submitting a form via the website, selecting appropriate technical settings for the use of information society services, or any other clear affirmative action indicating that you accept the proposed processing of your personal data (e.g. providing your contact details to receive a response to your enquiry).

2.5. The provision of personal data is voluntary; however, failure to provide such data may prevent the Balmain Group from carrying out the actions for which the data are required.

2.6. The Balmain Group will not make automated decisions, including those based on profiling, in relation to you, subject to the provisions below.

3. MARKETING

3.1. The Balmain Group may process personal data of website users for marketing purposes, which may include:

a. displaying marketing content tailored to the user’s interests (behavioural advertising);

b. conducting other types of analytical and statistical activities, as well as direct marketing of goods and services (including sending commercial information by electronic means and conducting telemarketing activities).

3.2. For marketing purposes, the Balmain Group may, in certain cases, use profiling. This means that, through the automated processing of your data, the Balmain Group may evaluate selected factors relating to users of the Balmain Group website in order to analyse their behaviour or make predictions about their future preferences. This enables better personalisation of displayed content according to your individual preferences and interests. In all other respects, the Balmain Group will not make automated decisions regarding you, including those based on profiling, using personal data.

4. COOKIES

4.1. The Balmain Group uses cookies primarily to provide users with electronic services and to improve their quality. Accordingly, the Balmain Group uses cookies to store or gain access to information already stored on the user’s terminal device (computer, phone, tablet, etc.). The use of cookies within the website is not intended to identify users.

4.2. Currently, the Balmain Group uses only essential cookies, primarily to deliver the website functionalities that the user wishes to use. Essential cookies may be installed solely by the Balmain Group via its website.

4.3. Since essential cookies are crucial for the proper functioning of the website, they cannot be disabled without affecting the website’s usability.

4.4. Technical data related to essential cookies are not shared with any external third parties for marketing or analytical purposes. Such data may be shared only with hosting service providers to the extent necessary to maintain the website.

4.5. Essential cookies do not collect data that would allow the identification of the website user.

4.6. The legal basis for processing data in connection with the use of essential cookies is the necessity of processing for the performance of a contract for the provision of electronic services (Article 6(1)(b) GDPR).

4.7. You may change your cookie settings at any time by clicking the cookie settings icon (usually located in the bottom corner of the website) or in your web browser settings. Blocking all cookies may affect the website’s functionality.

5. SOCIAL MEDIA

5.1. The Balmain Group maintains profiles on social media platforms, and the website contains plugins redirecting to these profiles. The Balmain Group acts as the data controller of its profile on a given platform and processes personal data contained on your profile (data related to your use of the social media platform) for the purpose of managing the profile, building a community, and interacting with followers.

5.2. The legal basis for such processing is Article 6(1)(f) GDPR (the legitimate interest of the Balmain Group in managing its profile, including marketing and communication activities) and your consent (Article 6(1)(a) GDPR), which you provide, for example, by joining the community of followers/fans created by the Balmain Group on the given platform.

5.3. The Balmain Group has no control over what data are collected by the providers of plugins or social media platforms and how they process them. To obtain information on the purpose and scope of data collection — including cookies used by such providers — as well as on further data processing, use, and users’ rights and privacy protection options, please refer to the respective providers’ privacy policies, including:

LinkedIn: https://www.linkedin.com/company/balmain-asset-management/

LinkedIn Privacy Policy: https://pl.linkedin.com/legal/privacy-policy

5.4. If you do not wish social media platforms to associate data collected during your visit to our website directly with your profile on such platforms, you must log out of the respective platform before visiting the website. You may also prevent plugins from loading entirely by using appropriate browser extensions, such as script blockers.

6. GOOGLE MAPS

6.1. Our website uses the Google Maps service, provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), to help users locate our premises more easily.

6.2. The use of Google Maps may result in the processing of user personal data by Google, such as IP address, location data (if enabled in your browser or device settings), and technical data regarding website usage. These data are processed by Google under its own responsibility, in accordance with its privacy policy.

6.3. Detailed information on how Google processes personal data can be found in the Google Privacy Policy: https://policies.google.com/privacy

6.4. By using our website, the user consents to the display of the embedded Google Map and the related processing of data.

7. RECIPIENTS OF PERSONAL DATA

7.1. Balmain Group may disclose your personal data to companies within the Balmain Group as well as to recipients (depending on the nature of your legal relationship with Balmain Group or the consents granted) responsible for marketing services, IT support, legal and financial services, debt collection, and postal or courier services.

7.2. Balmain Group may also disclose personal data upon request from public authorities or law enforcement agencies, or when required by applicable laws, court orders, or other governmental regulations. The need to disclose personal data may also arise in connection with privacy or security audits and/or when handling complaints or addressing security threats. Balmain Group does not sell personal data to any third parties.

8. TRANSFER OF DATA OUTSIDE THE EEA

8.1. The level of protection for personal data outside the European Economic Area (EEA) differs from that provided under European law. Therefore, Balmain Group transfers personal data outside the EEA only when necessary and with an adequate level of protection ensured, primarily by:

a. cooperating with data processors located in countries for which the European Commission has issued an adequacy decision confirming an appropriate level of data protection;

b. in the case of transfers to the United States – cooperating with entities certified under the EU–US Data Privacy Framework;

c. applying Standard Contractual Clauses issued by the European Commission;

d. implementing Binding Corporate Rules approved by the competent supervisory authority.

8.2. Balmain Group makes every effort to ensure that entities entrusted with data outside the EEA provide a level of protection equivalent to that required under the GDPR.

9. RIGHTS OF DATA SUBJECTS

9.1. Every individual whose personal data is processed by Balmain Group has the right to access their personal data and to request immediate rectification of any inaccurate data. Taking into account the purposes of processing, the individual also has the right to request the completion of incomplete personal data.

9.2. If you have given consent for your data to be processed for marketing purposes, you may withdraw this consent at any time. A user receiving specific information or services, such as an electronic newsletter, may unsubscribe at any time by following the instructions provided in each such communication.

9.3. Any individual providing their personal data to Balmain Group has the right to request the immediate erasure of their personal data, and Balmain Group is obliged to delete such data without undue delay if one of the circumstances set out in Article 17(1) of the GDPR applies.

9.4. Individuals providing their personal data to Balmain Group have the right to request the restriction of processing in cases specified in Article 18(1) of the GDPR.

9.5. You have the right to object to the processing of your personal data based on Article 6(1)(e) or (f) of the GDPR. In such a case, Balmain Group will cease processing your data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or where processing is necessary for the establishment, exercise, or defence of legal claims.

9.6. Where personal data is processed by Balmain Group by automated means based on consent or a contract, the data subject has the right to receive their personal data, which they have provided to Balmain Group, in a structured, commonly used, and machine-readable format, and has the right to transmit those data to another controller. The data subject also has the right to request that the personal data be transmitted directly from Balmain Group to another controller, where technically feasible.

9.7. To exercise any of the rights referred to above, you may contact Balmain Group in the manner indicated in section 1.3 above.

9.8. Balmain Group shall inform each recipient to whom personal data has been disclosed of any rectification or erasure of personal data or restriction of processing carried out at your request, unless this proves impossible or requires disproportionate effort.

9.9. In connection with the processing of your personal data by Balmain Group, you have the right to lodge a complaint with the supervisory authority (the President of the Personal Data Protection Office).

10. RETENTION PERIOD OF PERSONAL DATA

10.1. The period during which your personal data is processed by Balmain Group depends on the purpose of processing. As a rule, your personal data is processed for the duration of the electronic service for which the data was collected, or for as long as Balmain Group is subject to legal obligations requiring such processing. The processing period may be extended where processing is necessary for the establishment, exercise, or defence of potential legal claims, and thereafter only where and to the extent required by law.

Where processing is based on Balmain Group’s legitimate interest, personal data shall be processed until a valid objection to such processing is raised. Where processing is based on your consent, personal data shall be processed until such consent is withdrawn.

10.2. Upon expiry of the processing period, your personal data will be irreversibly deleted or anonymised.

11. SECURITY OF PERSONAL DATA

11.1. Balmain Group complies with the privacy protection principles set out in the GDPR and the Polish Act of 18 July 2002 on the Provision of Electronic Services (consolidated text: Journal of Laws of 2020, item 344, as amended).

11.2. Balmain Group declares that it takes appropriate measures to ensure a high level of security for the personal data it processes.

11.3. Balmain Group applies technical and organisational measures appropriate to the risks and categories of data processed, in particular protecting data from unauthorised access, unauthorised acquisition, unlawful processing, alteration, loss, damage, or destruction.

11.4. Personal data is stored in databases that are protected by technical and organisational measures in accordance with applicable legal requirements concerning personal data protection. Access to these databases is restricted to individuals authorised by the data controller.

11.5. Balmain Group maintains appropriate procedures to safeguard personal data against unauthorised loss, misuse, alteration, or destruction. Balmain Group endeavours to ensure that access to users’ personal data is limited only to those persons who need to know such information. Individuals with access to the data are obliged to maintain confidentiality.

12. FINAL PROVISIONS

12.1. Balmain Group may amend this Privacy Policy to reflect current data processing practices within Balmain Group. In the event of modifications, the “last updated” date displayed on the final page of this document will also change.

12.2. If you have any questions or comments regarding how Balmain Group manages personal data, please contact us at warsaw@balmain-am.com

Any concerns or comments regarding compliance with this Privacy Policy may also be submitted to this address.

Date of last update of the Privacy Policy: 14.01.2026

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