Privacy Policy

Data Controller

The data controller responsible for your personal data is Gawemu Jibojo, with its registered address at Techniczna 3A, Lublin, Poland. You may contact us at [email protected] or by telephone at +48 22 479 57 74. All data processing described in this policy is carried out under the authority and responsibility of this entity.

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 information: name and email address submitted through our contact form.
• Communication content: the text of messages you send to us.
• Technical data: IP address, browser type, operating system, referring URL, and pages visited, collected automatically when you access the website.
• Cookie-related data: preferences stored in cookies placed on your device with your consent, as described in our Cookie Policy.

We do not collect sensitive personal data (special categories under Article 9 GDPR), financial data, or data relating to minors.

Legal Bases for Processing

Each processing activity rests on a specific legal basis under Article 6 GDPR:

• Article 6(1)(b) GDPR – processing necessary to respond to your enquiry or to take steps at your request prior to entering into a service relationship.
• Article 6(1)(a) GDPR – processing based on your freely given, specific, informed, and unambiguous consent, for example when you accept optional cookies or submit the contact form with the privacy checkbox selected.
• Article 6(1)(f) GDPR – processing based on our legitimate interests, specifically the interest in maintaining the security and proper technical functioning of the website, and in understanding aggregate usage patterns to improve the educational content we offer.
• Article 6(1)(c) GDPR – processing necessary to comply with a legal obligation, for example retention of records required under Polish tax or accounting law.

Purposes of Processing

We process personal data for the following purposes:

• Responding to enquiries submitted through the contact form on this website.
• Operating and maintaining the technical infrastructure of the website, including server logs for security purposes.
• Analysing aggregate, anonymised usage data to improve the educational content and navigation of the website (only where analytics cookies are consented to).
• Complying with applicable legal obligations, including data retention requirements under Polish law.
• Delivering targeted advertising content through third-party advertising platforms where you have consented to marketing cookies.

We do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects on you.

Data Retention

We retain personal data for the minimum period necessary for the purpose for which it was collected:

• Contact form submissions are retained for up to 24 months from the date of receipt, after which they are deleted unless a longer retention period is required by law.
• Server log data (technical data) is retained for a maximum of 90 days for security and operational purposes.
• Cookie consent records are retained for 12 months, consistent with the consent validity period.
• Records required for compliance with Polish accounting or tax law are retained for the period prescribed by those laws, typically 5 years from the end of the financial year to which they relate.

Sharing and Transfers of Data

We do not sell personal data to third parties. We may share data in the following limited circumstances:

• Hosting and infrastructure providers: our website is hosted by a third-party provider who processes technical data on our behalf under a data processing agreement.
• Email service providers: messages submitted via the contact form are transmitted through email infrastructure. The provider acts as a processor under an appropriate agreement.
• Analytics providers: where you have consented to analytics cookies, aggregated usage data may be processed by a third-party analytics platform.
• Legal requirements: we may disclose data to Polish authorities (including the Urząd Ochrony Danych Osobowych, UODO) or courts if required by applicable law or a binding legal order.

Where personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place in accordance with Chapter V of the GDPR, such as standard contractual clauses approved by the European Commission.

Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights, which you may exercise by contacting us at [email protected]:

• Right of access (Article 15 GDPR): you may request confirmation of whether we process your personal data and, if so, a copy of that data.
• Right to rectification (Article 16 GDPR): you may request correction of inaccurate or incomplete data.
• Right to erasure (Article 17 GDPR): you may request deletion of your data where the processing no longer has a legal basis.
• Right to restriction of processing (Article 18 GDPR): you may request that we limit processing of your data in certain circumstances.
• Right to data portability (Article 20 GDPR): where processing is based on consent or contract, you may request your data in a structured, machine-readable format.
• Right to object (Article 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.

We will respond to rights requests within one calendar month of receipt. In complex cases, this period may be extended by a further two months, of which we will inform you.

Right to Lodge a Complaint

If you believe that our processing of your personal data infringes the GDPR or Polish data protection law, you have the right to lodge a complaint with the supervisory authority in Poland:

Urząd Ochrony Danych Osobowych (UODO)
ul. Stawki 2, 00-193 Warsaw, Poland
Website: uodo.gov.pl
Email: [email protected]

You may also lodge a complaint with the supervisory authority in the EU member state where you habitually reside or work.

Security Measures

We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include encrypted transmission (HTTPS), access controls, and regular review of processing activities. No method of transmission over the internet is completely secure; while we take data security seriously, we cannot provide an absolute guarantee of security.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing activities, applicable law, or regulatory guidance. Material changes will be indicated by a revised "Last Updated" date at the top of this page. We encourage you to review this policy periodically. Continued use of the website after a revision constitutes acknowledgement of the updated policy.

Contact

For any questions relating to this policy or our data processing practices, please contact us:

Gawemu Jibojo
Techniczna 3A, Lublin, Poland
Email: [email protected]
Phone: +48 22 479 57 74