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Date: 01 October 2010
ITI Group Legal and Privacy Policy
ITI Newsletter Regulation

The following privacy policy relates to the use of International Trading and Investments Holdings SA Luxembourg (“ITI Group”) on the internet websites under the URL www.itiholdings.com or www.iti.pl (each of them hereinafter is called “the Website” and jointly called “the Websites”) and ITI Group’s subscription-based information service “ITI Newsletter”.

By using the Websites and/or registering for providing ITI Newsletter the users signify agreements to these terms and conditions of ITI Group Legal and Privacy Policy and ITI Newsletter

Regulations.

I. Content disclaimer

1. The information held on the Websites are presented by ITI Group for general information purposes only. Such information does not purport to constitute any type of professional advice. ITI Group does not make any representations or give any warranties or undertakings in relation to the content of our Websites, including ITI Newsletter service and all other subscription services offered on the Websites. Furthermore ITI Group does not give any warranties in relation to the quality, accuracy, completeness or fitness for purpose of any content or service presented or offered on the Websites.

2. ITI Group shall not be liable for any losses or damages whatsoever, arising from reliance on information contained in the Websites, including information obtained during using ITI Newsletter or other subscription services offered on the Websites. In particular ITI Group shall not be liable for any losses or damages whatsoever coming from any interruption or delay in access to the Websites for whatever reason.

II. Copyright

1. All rights, including copyrights to the Websites and content on this Websites are owned only by ITI Group. ITI Group, any other names, images and logos identifying ITI Group and services are registered trademarks of ITI Group.

2. Neither our Websites nor any part of our site may be otherwise copied, stored, reproduced, modified, publicly displayed or distributed in any media (including without limitation via any other websites) without our prior written permission. Requests for permission should be addressed to info@itiholdings.com.

3. Any unlawful usage of the Websites and content on the Websites shall be treated as the infringement of ITI Group rights and shall involve the liability.

III. Privacy Policy

1. Introduction

Our aim is to safeguard the security and privacy of personal information obtained from the users during visits to the Websites and through use of ITI Newsletter.

2. Purpose

The purpose of the following privacy statement of ITI Group is to inform customers and the Websites users about the philosophy and handling of their data as well as data protection on the Websites.

3. Registration. Access to the services

3.1. In order to (a) access certain services; or (b) subscribe ITI Newsletter; or (c) send questions or comments, or (d) register for any other services featured on the Websites, an user must first fill out and submit a form available on the Websites.

3.2. During this registration process the user may be asked to provide relevant “personal information” and must type in contact information (such as electronic mail address, name, mailing address, telephone etc.).

3.3. This personal information provided upon registration allows ITI Group to deliver ITI Newsletter, as well as to confirm identity of the users.

4. Data storage and use

4.1. When you register for subscription of ITI Newsletter or any other services, the information you provide is for ITI Group purposes only.

4.2. ITI Group is the exclusive owner of all information collected under the Websites. This information will neither be sold nor rented to or exchanged with third parties, however ITI Group may use third party processors to conduct research, process data, maintain the Websites or services connected with preparation and delivery of ITI Newsletter on behalf of ITI Group.

4.3. On registration your information is stored in ITI Group database. It is also copied to ITI Group firmwide database so that authorized ITI Group staff throughout our Luxembourg, Polish and international offices can see who is registered for ITI Newsletter services.

4.4. As ITI Group is the organization of European and non-European companies, we may share your information with staff from these firms too. This means that your personal information will be transferred outside the European Economic Area (EEA) to jurisdictions that may not provide the same level of protection and security procedures as Luxembourg or Republic of Poland. Through the Websites you may get an up-to-date information on ITI Group companies.

5. Cookies

To estimate this website's total audience size and traffic and to facilitate users' sessions within the Websites, Grupa ITI uses an industry-wide technology called "cookies". A cookie is a string of information that is sent by the Websites and stored on user's hard drive or temporarily in user computer's memory. Most browsers will allow users to erase cookies from their hard drives, block acceptance of cookies, or receive a warning before a cookie is stored. Users who do not accept cookies from the Websites can still access most of its content. ITI Group advises users to refer to their browser instructions or "help" screen to learn more about cookies.

6. Log file

ITI Group stores log file data in order to detect trends on the Website and to manage and optimize its services. This information is and will not be linked to any personal data of the users.

7. Use of data by third parties

ITI Group does not pass the personal information provided by the users of the Websites to third parties, unless (a) an user grants its consent for data transfer; or (b) the data is transferred to other ITI Group companies; or (c) transferring data is necessary in order to allow its proper storage or proper operation of the Websites; or (d) data transferring is required by law or court order.

8. Links and third party websites

8.1. The Websites may contain links to other websites which are outside ITI Group control and are not covered by this privacy policy.

8.2. ITI Group cannot control the use of personal data on these external sites. If the users access other sites using the links provided, the operators of these sites may collect information from the users which will be used by them in accordance with their data protection policy, which may differ from ITI Group privacy policy.

8.3. ITI Group recommends that users check the privacy statements of the external sites if and when filling out any form or registration.

8.4. This privacy statement applies only to the Websites of ITI Group under the addresses www.itiholdings.com and www.iti.pl including continuation pages.

9. Inquiries

9.1. Occasionally ITI Group takes the liberty to run competitions, questionnaires and surveys. The participation in such activities is free of charge.

9.2. These competitions, questionnaires and surveys may contain some contact, social and demographic information.

9.3. This obtained information will only be used for the above-mentioned purposes and will not be distributed without the users’ permission.

9.4. Should any information obtained by ITI Group in the course of running competitions, questionnaires and surveys be published or made available to the public, the data will not be personalized.

10. Security

10.1. ITI Group protects the user data and takes a great care in maintaining the security of users' personal information and preventing unauthorized access to it through the use of appropriate technology and internal procedures, as required by the provisions of the Act of 29.08.1997 on protection of personal data (Journal of Laws No. 133, item 833, as subsequently amended), applicable in Poland.

10.2. If users send ITI Group their information, it is protected against online and offline third party access. Collected personal information is stored in limited access server behind a firewall.

10.3. All data is kept on the premises of ITI Group and only employees or coworkers working directly with the data have access to it. ITI Group employees and coworkers are obligated to treat all data in the strictest confidence and the devices of each employee and coworker are password-protected. All ITI Group employees and coworkers are constantly informed of and updated on the privacy policies and the security guidelines of ITI Group. All ITI Group employees and coworkers are aware of the importance of personal data protection and are obligated to deal with information and data accordingly. The IT infrastructure of ITI Group is protected and installed in a modern infrastructure.

10.4. Our security procedures also provide that we may request proof of identification before we will release personal information to you.

10.5. ITI Group undergoes periodic reviews of security policies and procedures to ensure that ITI Group systems are properly secure and protected.

11. Administration of Personal Data

11.1. International Trading and Investments Holdings SA Luxembourg, 5 rue Guillaume Kroll, L-1882 Luxembourg, is an administrator of users personal data and may assign this task to an administrator by virtue of a separate written agreement (“the Administrator”). The users may contact the Administrator by sending an electronic mail to: info@itiholdings.com or by mail sent to the above address.

11.2. Personal data may be released only in accordance with the ITI Group Privacy Policy available on the Websites and respective law provisions.

11.3. Personal data is collected and processed by Administrator in order to identify users, send ITI Newsletter, preparing questionnaires, surveys and competitions as well as in marketing purposes.

11.4. The users of the Websites are always informed about the way of data storage by ITI Group and purposes of usage of information.

11.5. Should ITI Group intend to use the data for purposes other than those mentioned in this private policy, it shall first obtain a consent from the appropriate user, sent via electronic mail. The user will retain the right to reject such a consent.

12. Accessing, modifying and correcting your personal data

12.1. Personal data are passed voluntarily. The user does not have any legal obligation to make the personal data available to ITI Group.

12.2. The user have the right to access your personal data, modify and make corrections of personal data.

12.3. In the event of the need to modify or change user information e.g. change of address, ITI Group ensures the appropriate modifications, supplements and deletions.

12.4. The user may request a copy of the information that ITI Group holds about the user at any time by contacting via email sent to the following email address: info@itiholdings.com.

12.5. If the user data is changed, the user shall notify ITI Group. The user can amend and correct personal details online via the Websites or via email: info@itiholdings.com.

12.6. Personal information is retained by ITI Group for the period of time that the user is registered to one or more of services provided by ITI Group.

13. Selection and termination

13.1. Websites visitors and customers can, at any time, terminate services for which they are registered. The data is thereupon completely deleted, except for any data which ITI Group is required to save in compliance with legal requirements.

13.2. ITI Group reserves the right, in its sole discretion, to terminate the user access to all or part of Websites, or its range of ITI Newsletter services, with or without notice.

14. Information about modifications

14.1. Please note that our privacy policy may be amended from time to time. Should ITI Group deem necessary to modify ITI Group Privacy Policy, users will be informed by ITI Group via information on the Website or by sending an electronic mail.

14.2. In the absence of any published information on amendment to this privacy policy, this statement applies.

15. Contacting ITI Group

If you have any questions about this privacy policy, please contact: info@itiholdings.com.

16. Applicable law

Websites and ITI Group Privacy Policy are governed by Polish law. The Polish courts shall have exclusive jurisdiction over any disputes arising from the Websites.

IV. Regulations of ITI Newsletter of 01st October 2010 (“Regulations”)

I. General Information

§1

1. ITI Newsletter Service is a free of charge web information service operated by International Trading and Investments Holdings SA Luxembourg having its seat in Luxembourg at 5 rue Guillaume Kroll, L 1882 Luxembourg (hereinafter referred to as the “ITI Group” or “Operator”)

2. These Regulations have been developed pursuant to the Act of 18 July 2002 on rendering services electronically (Journal of Laws No. 144 item 1204) (hereinafter referred to as “the Act on Rendering Services Electronically”).

3. These Regulations stipulate the type of services, the terms and conditions for rendering of ITI Newsletter Service electronically, as well as for the terms and conditions for executing and terminating agreements on rendering of such services, and also for the procedure for resolving complaints.

4. In matters not provided for in these Regulations to the ITI Newsletter Service rendered electronically, in particular in the range of submitting representations of will electronically, provisions of the Act on Rendering Services Electronically, the Civil Code and other legislation shall apply.

§2

Terms used in these regulations shall have the following meanings:

1) User - any individual, legal person or organizational entity not having personality at law using ordered services made available electronically.

2) Operator or ITI Group – International Trading and Investments Holdings SA Luxembourg, 5 rue Guillaume Kroll, L- 1882 Luxembourg.

3) ITI Newsletter Service - services related with operation of the „ITI Newsletter” available through http://www.itiholdings.com/ and http://www.iti.pl/ made available by the Operator to the User free of charge after proper registration using a registration form available on the Websites.

4) Websites - websites managed by the Operator: http://www.itiholdings.com/ and http://www.iti.pl/.

5) Account - available to the User of ITI Newsletter Service after correct login part of the Websites allowing the accumulation and modification of User’s personal data as well as other data.

§3

By ordering the ITI Newsletter Service, the User confirms that he has acquainted with its description, terms and conditions and these Regulations, as well as that he accepts all terms and conditions of these Regulations.

II. Registration

§4

1. Agreement on rendering services electronically shall be concluded between the User and the Operator by registering the Account by the User using registration form available on the Websites (hereinafter referred to as “the Agreement”). The term of the Agreement is indefinite.

2. The Agreement between the User and the Operator shall be dissolved by the User by resignation submitted by the User to the e-mail address: info@itiholdings.com within unsubscription procedure, pursuant to §8 of the Regulations.

3. The Operator is entitled to dissolve the Agreement:

a. with thirty (30) days notice; or

b. with immediate effect, if the User breaches terms and conditions of the Agreement, these Regulations, or any applicable laws; by sending a notice to the User’s email address indicated in the registration process.

§5

1. By registering the Account and using ITI Newsletter Service made available through the Websites, the User expresses his consent for gathering, accumulation, recording, storage, processing, making available and removing User’s personal data by the Operator for the following purposes:

a. rendering ITI Newsletter Service through the Websites;

b. marketing, statistical research purposes, market research, behavior and preference of service recipient research, allocating the results thereof to improvement of the quality of services rendered within the ITI Newsletter Service.

2. The User may be required to provide the following personal data during registration:

a. Name and Surname;

b. Identifier (Login);

c. E-mail address;

d. Telephone number;

e. Additional data of demographic or social nature.

3. The ITI Newsletter Service is ordered by way of registration of the Account on the Websites in the following manner:

a. Registration for the service is made on the new User page by filling-in the registration form.

b. The User has to fill-in all fields of the “Registration Data” section of the form and mark the field “I wish to receive the ITI Newsletter/information about ITI Group”.

c. Data entered into the form shall refer to the User ordering the service and shall be true.

d. The correctly filled-in and accepted by the User form is sent to the Operator and recorded in the http://www.itiholdings.com/ and http://www.iti.pl/ database.

e. The system shall send a confirmation of registration in the http://www.itiholdings.com/ and http://www.iti.pl/ services to the User’s e-mail address specified in the registration form.

f. Failure to correctly verify User’s e-mail address will cause data entered into the database to be removed fourteen (14) days after registration in the database.

5. Using of e-mail services requires the User to possess an active and correctly configured e-mail account.

6. Upon withdrawal by the User of its consent to receive ITI Newsletter Service, the Operators will immediately cease providing of the ITI Newsletter Service to the benefit of such User.

7. Sending of the ordered ITI Newsletter Service to the e-mail box address stated by the User constitutes a service rendered through e-mail.

8. The User expresses his consent for receiving commercial information included in ITI Newsletter Service, as defined in the Act on Rendering Services Electronically, to the e-mail address stated by the User.

9. ITI Newsletter Service shall be sent to User with frequency selected by the User when ordering ITI Newsletter Service; provided that such option is available. If no such option available, the ITI Newsletter Service shall be sent with a single frequency determined by the Operator, only.

10. The User expresses consent for the Operator to store small text files (“cookies”) on User’s computer, necessary for proper performing of the ITI Newsletter Services by the Operator. Such files do not collect User’s personal information, do not alter User’s computer configuration, are not used for installing or uninstalling any computer software, viruses or Trojans, do not interfere with integrity of the system or user data, are not processed by other Internet services and may be removed by the User at any time.

III. Personal Data

§6

1.. The Operator is personal data administrator. The Operator protects personal data of the User. Data made available by the User may be processed for purposes set forth in §5 clause 1 of the Regulations, only by the Operator and persons authorized by the Operator pursuant to provisions of the Act of 29 August 1997 on protection of personal data (Journal of Laws No. 101 item 926 of 2002, as subsequently amended) (hereinafter referred to as “the Act on protection of personal data”) in accordance with the ITI Group Legal and Privacy Policy.

2. On registration personal data is stored in the Operator database. It is also copied to the Operator firmwide database so that ITI Group staff throughout Luxembourg, Polish and international offices can see who is registered for ITI Newsletter Services.

3. As ITI Group is the organization of European and non-European companies, ITI Group may share information with staff from these firms too. This means that the User personal information will be transferred outside the European Economic Area (EEA) to jurisdictions that may not provide the same level of protection and security procedures as Luxembourg or Republic of Poland. On the Websites the User will find an up-to-date information on ITI Group companies.

4. The User is entitled to review and correct the User’s personal data.

5. Disclosing of personal data by the User is made voluntarily and at sole discretion of the User.

6. The Operator does not review the disclosed personal data; however, the Operator reserves the right to refuse rendering of the ITI Newsletter Service where the User declines to disclose specific personal data. The User shall be notified separately of any requirement to disclose such personal data.

7. The User hereby expresses his consent for the collection, accumulation and processing of the following technical and technological data by the Operator:

a. IP address;

b. Internet address from which the User has entered the Websites

c. Other information transmitted over http protocol.

8. Pursuant to the Act on Protection of Personal Data and these Regulations, personal data protection does not include legal persons, i.e. companies, enterprises and entrepreneurs self-dependently carrying on business activities.

IV. Copyrights

§ 7

1. Property copyrights to content of the ITI Newsletter Service belong to ITI Group

2. Copyrights are protected as provided for in the Act of 04 February 1994 on copyrights and related rights (uniform text: Journal of Laws of 2006, No. 90 item 631, as subsequently amended). None of the works included in their entirety or part in the ITI Newsletter Service, as well as received by the User, may be copied and disseminated, or further disseminated in any form or manner (including but not limited to electronic or mechanical, or otherwise, on all and any other field of exploitation), including but not limited to copying, photocopying, also by placing within the Internet, without written consent of the ITI Group.

V. Unsubscription

§ 8

1. The User can unsubscribe from ITI Newsletter Service at any time. Unsubscribing from ITI Newsletter Service means that the User will no longer receive ITI Newsletter Service emails and will not have access to the ITI Newsletter Service archive on the Websites.

2. The user can unsubscribe in the following ways:

• Clicking on the unsubscribe link in ITI Newsletter Service emails or in the ITI Newsletter Service section of the Websites

• Sending an email to: to info@itiholdings.com.

3. The Operator will unsubscribe the User from ITI Newsletter Service within ten (10) working days of request.

4. The personal information will be removed from the databases. If the User is a client of ITI Group, or ITI Group has the details for reasons other than providing the ITI Newsletter Service, ITI Group will retain records in central database.

5. The personal information of the User is retained by the Operators for the period of time that the User is registered to one or more of services.

VI. Limitations to performing the ITI Newsletter Service

§9

1. The Operator shall not be liable for absence of access to the ITI Newsletter Service.

2. The Operator may announce technical breaks in operation of the ITI Newsletter Services in case of planned, current maintenance and technical servicing of the server and service software.

3. The Operator shall not be liable for consequences of adhering to information included in the ITI Newsletter Service.

4. The Operator do not make any representations or give any warranties or undertakings in relation to the content of ITI Newsletter Service in relation to the quality, accuracy, completeness or fitness for purpose of such content or service.

5. Except as required by statutory law provisions, the Operator shall not be liable for any losses or damages whatsoever, arising from reliance on information contained in ITI Newsletter Service, or from any interruption or delay in access to ITI Newsletter Service for whatever reason.

6. The recipient of ITI Newsletter Service may not supply content of illegal nature.

VII. Complaints procedure

§ 10

1. All and any complaints relating to the use of the ITI Newsletter Service shall be submitted by e-mail to the following address info@itiholdings.com.

2. Complaints shall be resolved within seven (7) business days.

3. Responses to complaints are sent to the User’s e-mail address.

VIII. Final provisions

§ 11

These Regulations are enforced as from the date of publishing on the Websites and constitute an integral part of the agreement with the User.

§ 12

These Regulations may be amended. The User shall be notified of any amendments to these Regulations electronically. It shall be deemed that the User has accepted such amendments if no representation of terminating the Agreement is submitted by the User within seven (7) days of being notified of any such amendment.

§ 13

The Operator reserves itself the right to vary provisions of these Regulations to benefit of the User.

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