Privacy Policy

Effective from: 2026-11-09. This is a translation of the Polish version, which prevails in case of any discrepancy.

1. Data controller

The controller of personal data provided through hetmancapital.com is JDN Justyna Dawidowicz, Moderska 12A, 62-062 Strykowo, NIP 7773356501, trading as Hetman Capital (the “Controller”). For any matter related to personal data, contact kontakt@hetmancapital.com (ideally with “GDPR” in the subject).

2. What data we process and why

Providing data is voluntary, but without an e-mail address we cannot reply to a contact form message.

3. How long we keep data

Club account data is kept for as long as the account exists, and billing records for the period required by tax law (usually 5 years from the end of the year). Correspondence data is kept for as long as needed to handle it, and then until any claims become time-barred or until you withdraw consent. Server logs are kept by the hosting provider according to its settings, usually no longer than several dozen days. Terminal, journal and Hetman and King package data is kept for the duration of the membership; on request we can export your journal before deleting it. Broadcast recordings remain available in the archive for as long as the Club operates. Affiliate programme data and payout records are kept for the period required by tax law (usually 5 years from the end of the year). Your Sierra Chart account name is kept for the duration of the membership and 30 days after it ends.

4. Recipients

Data may be shared with providers of technical services to the Controller: website and e-mail hosting (Hostinger International Ltd.), domain services, bot protection for forms and anonymous visit statistics (Cloudflare, Inc.), the Club community platform (Circle.so, Inc.), newsletter delivery (UAB “MailerLite”, Vilnius, Lithuania), payments (Stripe Payments Europe, Ltd.), video hosting (Vimeo.com, Inc.), connections to the Terminal and the voice room (Cloudflare, Inc.) and, in the King package, the provider of the video call tool agreed with the Participant. They process data only on the Controller’s instructions. We pass your Sierra Chart account name (only the name, without your e-mail address) to Sierra Chart Engineering (USA) solely to grant access to the Hetman Studies; Sierra Chart processes it under its own rules as the provider of the software you have an agreement with. Notifications for the Controller (name or nickname, e-mail address, package, amount, period) are sent via the Telegram messenger, which processes them under its own privacy policy.

5. Cookies and third-party content

hetmancapital.com does not use analytics or marketing cookies and does not track visitors. That is why there is no cookie banner.

Visit statistics. We measure visits to hetmancapital.com and the Club (club.hetmancapital.com) with Cloudflare Web Analytics (Cloudflare, Inc.). It sets no cookies, uses no browser storage and creates no profiles or identifiers of individual people. We see only aggregate data: the number of visits and page views, pages viewed, the referring site, country, and device and browser type. To produce them, Cloudflare processes technical connection data (including IP address and browser headers), which we do not receive. Legal basis: the Controller’s legitimate interest in understanding which content is useful and improving the website (Art. 6(1)(f) GDPR).

The preview of our latest YouTube, Instagram and TikTok posts consists of cover images stored on our own server, so viewing the page does not connect you to those services. Only clicking a post, or the “Show posts” button (when the preview is unavailable), connects your browser to Meta Platforms (Instagram) or TikTok servers, which may set their own cookies and process your data under their privacy policies. Social media links lead to external services.

Hetman Capital Club runs on the Circle platform at club.hetmancapital.com. The platform uses its own cookies that are necessary for logging in and running your account, and the Vimeo player in the Club may store cookies needed for playback. Club use is governed by the Terms.

The ♛ Hetman Terminal (panel.hetmancapital.com) stores Terminal settings and data needed to maintain the connection in your browser’s storage (localStorage). They are necessary for the service you request, so no separate consent is required. We do not use them for statistics or advertising. You can delete them in your browser settings; the Terminal will then restore its default settings.

6. YouTube API Services

We use the tool “Hetman Media Publisher”, which uses YouTube API Services, to publish our own videos to the Hetman Capital YouTube channel and to read that channel’s statistics. By using it we are bound by the YouTube Terms of Service; data processed by Google is subject to the Google Privacy Policy. The tool only accesses our own channel and does not collect or store data of other YouTube users. Channel statistics (views, watch time, retention) are stored locally on the owner’s computer for no longer than 30 days. Access can be revoked at any time at security.google.com/settings/security/permissions.

7. Transfers outside the EEA

Some providers (e.g. Circle, Stripe, Vimeo, Cloudflare, Google (YouTube), Meta (Facebook, Instagram), TikTok, Twitch, Kick, WhatsApp, Telegram) may process data outside the European Economic Area. Such transfers are based on a European Commission adequacy decision (EU-US Data Privacy Framework) or standard contractual clauses. Your Sierra Chart account name is transferred to Sierra Chart Engineering in the USA under Art. 49(1)(b) GDPR – the transfer is necessary for the performance of a contract at your request (granting access to the Studies you request in the form).

8. Your rights

You have the right to access your data, rectify it, erase it, restrict processing, data portability, object to processing based on legitimate interests and withdraw consent at any time (without affecting the lawfulness of processing before withdrawal). To exercise your rights, write to kontakt@hetmancapital.com.

You may also lodge a complaint with the Polish supervisory authority, the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl), or with the authority in your country of residence.

9. Automated decisions

We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you. The Terminal automatically refuses a third device on the same personal link; this is a technical access safeguard, and if it causes a problem just write to kontakt@hetmancapital.com.

10. Changes

We may update this policy, e.g. when website features change. The current version is always available on this page, and we inform members of significant changes in a post in the Club space “📣 Announcements”.

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