Legal
Privacy Policy
1. Data Controller
The data controller for personal data processed through this website is Pemuba Wefusu, with its registered address at Gołdapska 8/13, Białystok, Poland. You can contact us regarding any data protection matter at [email protected] or by telephone at +48 608 300 271.
This Privacy Policy applies to all personal data collected through the website pemuba-wefusu.info and through any communications with us. It is prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (the General Data Protection Regulation, "GDPR") and the Polish Act on Personal Data Protection of 10 May 2018 (Dz.U. 2018 poz. 1000).
2. What Data We Collect
We collect only the personal data that is necessary for the purposes described in this policy. The categories of data we may collect include:
- Contact information: email address, name (if voluntarily provided), telephone number (if voluntarily provided)
- Communication data: the content of messages sent to us through the contact form or by email
- Technical data: IP address, browser type and version, operating system, pages visited, time and duration of visit, referring URL
- Cookie data: as described in our Cookie Policy
- Program access data: information related to your use of the online program if you register
We do not collect special categories of personal data (sensitive data) as defined under Article 9 GDPR, and we do not knowingly collect data from individuals under the age of 16.
3. Legal Basis for Processing
We process your personal data on the following legal bases as set out in Article 6 GDPR:
- Consent (Art. 6(1)(a) GDPR): Where you have provided explicit consent, for example by ticking the privacy checkbox on our contact form or accepting optional cookies.
- Contractual necessity (Art. 6(1)(b) GDPR): Where processing is necessary to provide you with access to the program or respond to your inquiry.
- Legal obligation (Art. 6(1)(c) GDPR): Where we are required to process data to comply with applicable Polish or EU law.
- Legitimate interests (Art. 6(1)(f) GDPR): For the purposes of website analytics, security, and fraud prevention, where these interests are not overridden by your rights and freedoms.
4. How We Use Your Data
Your personal data is used for the following purposes:
- To respond to inquiries submitted through the contact form or by email
- To provide access to and support your use of the online program
- To improve the website and program based on aggregated usage data
- To maintain the security and integrity of our website and services
- To comply with legal obligations applicable to us under Polish and EU law
We do not use your personal data for automated decision-making or profiling within the meaning of Article 22 GDPR.
5. Data Sharing and Third Parties
We do not sell your personal data to third parties. We may share your data with trusted service providers who assist us in operating the website and delivering the program, including hosting providers, email service providers, and analytics platforms. All such providers are contractually bound to process your data only on our instructions and in compliance with applicable data protection law.
Where such providers are located outside the European Economic Area, we ensure appropriate safeguards are in place in accordance with Chapter V GDPR, including Standard Contractual Clauses approved by the European Commission.
We may also disclose your data to competent authorities where required to do so by law or by a valid court order.
6. Data Retention
We retain your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. Specifically:
- Contact form inquiries and correspondence: retained for up to 24 months from the date of last contact
- Program access data: retained for the duration of your access plus 12 months
- Technical and analytics data: retained in aggregated or anonymized form after 26 months
- Data retained for legal compliance purposes: retained for the period required by the applicable law, which in Poland may be up to 5 years for certain financial records
After the applicable retention period, data is securely deleted or anonymized.
7. Your Rights Under GDPR
As a data subject under GDPR, you have the following rights, which you may exercise by contacting us at [email protected]:
- Right of access (Art. 15 GDPR): You may request a copy of the personal data we hold about you.
- Right to rectification (Art. 16 GDPR): You may request correction of inaccurate or incomplete data.
- Right to erasure (Art. 17 GDPR): You may request deletion of your data where there is no legitimate reason for us to continue processing it.
- Right to restriction of processing (Art. 18 GDPR): You may request that we limit the processing of your data in certain circumstances.
- Right to data portability (Art. 20 GDPR): Where processing is based on consent or contract, you may request your data in a structured, machine-readable format.
- Right to object (Art. 21 GDPR): You may object to processing based on legitimate interests at any time.
- Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
You also have the right to lodge a complaint with the Polish supervisory authority, the Urząd Ochrony Danych Osobowych (UODO), at ul. Stawki 2, 00-193 Warsaw, website: uodo.gov.pl.
8. Cookies and Tracking Technologies
This website uses cookies and similar technologies. Full details of the cookies we use, their purpose, and how to manage your preferences are set out in our Cookie Policy, available at pemuba-wefusu.info/cookies.html.
You may withdraw your cookie consent at any time by adjusting your preferences through the cookie settings panel accessible on this site.
9. Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction, in accordance with Article 32 GDPR. These measures include encrypted data transmission (HTTPS), access controls, and regular security reviews. However, no method of transmission over the internet is entirely secure, and we cannot guarantee absolute security.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. The date at the top of this page indicates when the policy was last revised. We encourage you to review this policy periodically. Continued use of the website after a policy update constitutes acceptance of the revised policy.
For any questions about this Privacy Policy or our data practices, please contact us at [email protected].