Privacy Policy
Controller Identity and Contact Details
The controller of your personal data within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation, "GDPR") and the Polish Act on Personal Data Protection of 10 May 2018 (Ustawa z dnia 10 maja 2018 r. o ochronie danych osobowych, Dz.U. 2018 poz. 1000) is:
Dasoku Fucaco
Ksiedza Jana Konopczyńskiego 1
Bydgoszcz, Poland
Email: [email protected]
Phone: +48 525 847 030
You may contact the controller at any time using the details above with questions, requests, or complaints relating to the processing of your personal data.
Scope of Personal Data Collected
We collect personal data only to the extent necessary for the purposes described in this policy. The categories of data we may process include:
Contact data: name (where provided voluntarily), email address, and the content of messages submitted through our contact form or sent directly by email.
Technical data: IP address, browser type and version, operating system, referring URL, pages visited, and time of visit. This data is collected automatically through server logs and, where applicable, analytics tools.
Cookie data: data stored in cookies placed on your device in accordance with your consent preferences. See our Cookie Policy for full details.
We do not collect special categories of personal data (sensitive data) as defined in Article 9 GDPR, and we do not collect data from children under 16 years of age.
Purposes and Legal Bases for Processing
We process your personal data for the following purposes, each grounded in a specific legal basis under Article 6 GDPR:
Responding to inquiries (Article 6(1)(b) GDPR — performance of a contract or pre-contractual steps): When you contact us through our form or by email, we process your contact data to respond to your inquiry and, where relevant, to take steps at your request prior to entering into a consultancy engagement.
Website operation and security (Article 6(1)(f) GDPR — legitimate interests): We process technical data to maintain the security and proper functioning of our website. Our legitimate interest is in protecting our systems and ensuring service availability.
Analytics (Article 6(1)(a) GDPR — consent): Where you have consented to analytics cookies, we process data about your website usage to understand how visitors navigate our site and to improve its content and structure.
Marketing communications (Article 6(1)(a) GDPR — consent): Where you have consented to marketing cookies or communications, we may process data for this purpose. You may withdraw consent at any time without affecting the lawfulness of prior processing.
Legal obligations (Article 6(1)(c) GDPR): We may process data where required to comply with applicable Polish or EU law, including tax and accounting obligations.
Data Retention Periods
We retain personal data only for as long as necessary for the purposes for which it was collected, taking into account applicable legal requirements:
Inquiry and correspondence data is retained for a period of three years from the date of last contact, after which it is securely deleted unless a contractual relationship has been established, in which case retention follows the terms applicable to that relationship.
Technical log data is retained for a maximum of 12 months, after which it is deleted or anonymized.
Analytics data is retained in accordance with the terms of the analytics service used and your consent preferences, typically not exceeding 26 months.
Accounting and tax records containing personal data are retained for the period required by Polish tax law, currently five years from the end of the tax year in which the relevant transaction occurred.
Data Sharing and Recipients
We do not sell your personal data to third parties. We share data only in the following circumstances:
Service providers: We use third-party service providers for website hosting, email delivery, and analytics. These providers act as data processors and are bound by data processing agreements requiring them to process data only on our instructions and in accordance with GDPR.
Legal requirements: We may disclose data to public authorities (including Polish tax authorities, courts, or law enforcement) where required by applicable law or a binding legal order.
Business transfers: In the event of a merger, acquisition, or transfer of our business, personal data may be transferred as part of that transaction, subject to equivalent data protection obligations.
Where data is transferred outside the European Economic Area, we ensure appropriate safeguards are in place in accordance with Chapter V GDPR, such as standard contractual clauses approved by the European Commission.
Your Rights Under GDPR
As a data subject, you have the following rights under the GDPR, which you may exercise by contacting us at [email protected]:
Right of access (Article 15 GDPR): You have the right to obtain confirmation of whether we process data about you, and if so, to receive a copy of that data along with information about how it is processed.
Right to rectification (Article 16 GDPR): You have the right to request correction of inaccurate personal data or completion of incomplete data.
Right to erasure (Article 17 GDPR): You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful.
Right to restriction of processing (Article 18 GDPR): You have the right to request that we restrict processing of your data in certain circumstances.
Right to data portability (Article 20 GDPR): Where processing is based on consent or contract and carried out by automated means, you have the right to receive your data in a structured, commonly used, machine-readable format.
Right to object (Article 21 GDPR): You have the right to object to processing based on legitimate interests, including profiling. You also have the right to object to direct marketing at any time.
Right to withdraw consent: Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
We will respond to requests within one month. This period may be extended by two further months where necessary, in which case we will inform you of the extension and its reasons within the initial one-month period.
Right to Lodge a Complaint
If you believe that our processing of your personal data infringes the GDPR or applicable Polish data protection law, you have the right to lodge a complaint with the supervisory authority. In Poland, the supervisory authority is:
Prezes Urzędu Ochrony Danych Osobowych (PUODO)
Stawki 2
00-193 Warsaw, Poland
Website: uodo.gov.pl
Email: [email protected]
We encourage you to contact us first so that we can address any concerns directly before you approach the supervisory authority.
Data Security
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, accidental loss, destruction, or alteration. These measures include encrypted data transmission (HTTPS), access controls limiting data access to authorized personnel, and regular review of our security practices.
No transmission of data over the internet can be guaranteed as completely secure. While we take reasonable precautions, we cannot guarantee absolute security of data transmitted to our website.
Automated Decision-Making and Profiling
We do not use automated decision-making processes, including profiling, that produce legal effects or similarly significant effects on individuals. Decisions about our consultancy services are made by human consultants based on information you provide.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or the structure of our website. Where changes are material, we will take reasonable steps to inform you. The date at the top of this policy indicates when it was last revised. Continued use of our website following publication of a revised policy constitutes acceptance of the updated terms.