cod·eticPrivacy Policy02

Privacy Policy

Privacy policy for codetic.eu. Rules for processing personal data of Users in line with the GDPR — controller, purposes, legal bases, recipients, retention and data subject rights.

Effective
Last updated
Jurisdiction
Poland · governed by Polish law
Related
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§ 1. Data controller

  1. The controller of your personal data is cod·etic — Bartłomiej Grochowski, a sole proprietorship registered in the Polish Central Registration and Information on Business (CEIDG), with registered address at ul. Chłopska 32, 87-152 Wybcz, Poland, Tax ID (NIP) 8792739965, REGON 522307823 (the "Controller").
  2. You can contact the Controller in matters concerning personal data at [email protected].
  3. This privacy policy (the "Policy") fulfils the information obligations of 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 (the "GDPR").

§ 2. Categories of data processed

The Controller processes data provided by the User on the Website:

  1. Contact Form: name, email address, optionally company name, message content.
  2. Brief Form: name, email address, optionally company name, project type, project stage, budget range, timeline, project description.
  3. Technical data collected automatically server-side: device IP address, submission timestamp — used solely to protect the Website against abuse (rate-limiting).

§ 3. Purposes and legal bases

PurposeLegal basisRetention
Responding to inquiries and business correspondenceArt. 6(1)(b) GDPR (steps prior to entering into a contract) and Art. 6(1)(f) GDPR (legitimate interest in conducting business correspondence)up to 24 months from the last contact
Securing the Website (rate-limiting, anti-spam)Art. 6(1)(f) GDPR (legitimate interest — Website security)30 days (rate-limit logs)
Web analytics (Google Analytics 4)Art. 6(1)(a) GDPR (consent)up to 14 months; until consent is withdrawn
Marketing and ad performance measurement (Meta Pixel, Google advertising signals)Art. 6(1)(a) GDPR (consent)up to 180 days; until consent is withdrawn
Compliance with legal obligations (e.g. responses to authorities)Art. 6(1)(c) GDPRfor the period required by applicable law

§ 4. Recipients — processors

The Controller engages the following processors under data processing agreements (Art. 28 GDPR):

  1. Resend, Inc. — based in the United States. Provides email relay (SMTP). Processes name, email address and message content to deliver messages to the Controller. Transfers outside the European Economic Area are based on Standard Contractual Clauses approved by the European Commission (Implementing Decision 2021/914) and, where applicable, the EU-U.S. Data Privacy Framework.
  2. SEOhost sp. z o.o. — based in Poland. Provides hosting and the Redis store used for rate-limiting.
  3. Google Ireland Limited (and Google LLC, USA) — provides Google Analytics 4 and Google Tag Manager. Processes cookie identifiers, IP address (truncated), device and behavioural data. Only after you give consent. We use Google Consent Mode v2 — before consent, no identifying data reaches Google.
  4. Meta Platforms Ireland Limited (and Meta Platforms, Inc., USA) — provides Meta Pixel, used for ad performance measurement and remarketing. Processes a cookie identifier, IP address and on-site events. Only after you give marketing consent.

Data may be disclosed to public authorities where required by law.

§ 5. Transfers outside the EEA

  1. Transfers to Resend, Inc. (USA) are based on Standard Contractual Clauses approved by the European Commission (Implementing Decision 2021/914) and additional technical safeguards.
  2. Google and Meta may transfer data to the United States. Both are certified under the EU-U.S. Data Privacy Framework (European Commission adequacy decision of 10 July 2023) and additionally rely on Standard Contractual Clauses.
  3. Transfers to Google and Meta happen only if you grant the relevant consent. Declining means no data is shared with them.
  4. Other recipients are based in the European Economic Area.

§ 6. Your rights

Under the GDPR you have the following rights:

  1. right of access to your personal data (Art. 15),
  2. right to rectification (Art. 16),
  3. right to erasure — "right to be forgotten" (Art. 17),
  4. right to restriction of processing (Art. 18),
  5. right to data portability (Art. 20),
  6. right to object to processing based on legitimate interests (Art. 21),
  7. right to lodge a complaint with the supervisory authority — the Polish Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warszawa, Poland.

To exercise these rights, contact the Controller at [email protected].

§ 7. Provision of data

Providing data via the Contact Form or Brief Form is voluntary, but necessary to respond to your inquiry. Without your data we cannot handle the request.

§ 8. Cookies and similar technologies

  1. Strictly necessary cookies — always active, no consent required (Art. 173(3) of the Polish Telecommunications Act):
    • NEXT_LOCALE — remembers your language choice,
    • codetic_consent — stores your consent decision, valid for 6 months.
  2. Analytics cookies — set only after you consent. Google Analytics 4 writes _ga and _ga_* cookies (up to 14 months) used to distinguish users and sessions.
  3. Marketing cookies — set only after you give marketing consent. Meta Pixel writes the _fbp cookie (up to 90 days) used for ad performance measurement and remarketing.
  4. We implement Google Consent Mode v2: until you consent, all signals (ad_storage, ad_user_data, ad_personalization, analytics_storage) are set to denied and the analytics and marketing scripts are not loaded at all.
  5. You can withdraw consent at any time by deleting the codetic_consent cookie in your browser settings — the banner will reappear and you can decide again. Withdrawal does not affect the lawfulness of processing carried out before it.
  6. Declining consent does not restrict access to any content or feature of the Website.
  7. You can block cookies in any browser's settings. Disabling strictly necessary cookies may break the Website.

§ 9. Automated decision-making

The Controller does not make automated decisions about Users, including profiling that produces legal effects.

§ 10. Changes to the Policy

The Controller may amend the Policy in case of changes in law, scope of processing, or processors. The updated version is published on the Website with the effective date.

The Policy enters into force on 4 May 2026.

Contact[email protected]
Entitycod·etic — Bartłomiej Grochowski · NIP 8792739965 · REGON 522307823
Addressul. Chłopska 32, 87-152 Wybcz, PL