Privacy Policy

1. Definitions

1.1. Administrator – Kyrylo Taranenko PdM, headquartered in Poznań, at Droga Dębińska 5/41, Poznań.

1.2. Personal Data – Information about an identified or identifiable natural person, including physical, physiological, genetic, mental, economic, cultural, or social identity characteristics, including device IP, location data, online identifiers, and information collected via cookies or similar technology.

1.3. Policy – This Privacy Policy.

1.4. GDPR – 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 and on the free movement of such data, repealing Directive 95/46/EC.

1.5. Service – The online service operated by the Administrator.

1.6. User – Any natural person visiting the Service or using one or more of its functionalities described in this Policy.

2. Data Processing in Connection with Service Use

2.1. Currently, no private user data is collected or stored, except for applications for the Closed Beta. These applications are processed only to contact Users regarding their application status.

3. Purposes and Legal Basis for Data Processing

Service Usage

3.1. Personal Data of all persons using the Service (including IP addresses or other identifiers and information collected via cookies or similar technologies), who are not registered Users (i.e., individuals without a profile in the Service), are processed by the Administrator for the following purposes:

3.1.1. To provide electronic services by making content available to Users in the Service – the legal basis for processing is the necessity for the performance of the contract (Article 6(1)(b) GDPR).

3.1.2. For analytical and statistical purposes – the legal basis is the legitimate interest of the Administrator (Article 6(1)(f) GDPR), which involves analyzing User activity and preferences to improve functionalities and services.

3.1.3. To establish and pursue claims or defend against claims – the legal basis is the legitimate interest of the Administrator (Article 6(1)(f) GDPR), which involves protecting its rights.

3.1.4. For marketing purposes of the Administrator and other entities, particularly for behavioral advertising – detailed rules for Personal Data processing for marketing purposes are described in the Marketing section.

3.2. User activity in the Service, including Personal Data, is recorded in system logs (a special software program for chronological storage of event and activity data related to the IT system providing services). The data collected in the logs are primarily processed for service provision purposes. They are also processed for technical and administrative purposes, system security, and analytical and statistical purposes – the legal basis in this respect is the legitimate interest of the Administrator (Article 6(1)(f) GDPR).

4. Marketing

4.1. The Administrator processes Users' Personal Data for marketing purposes, which may involve:

4.1.1. Displaying marketing content not tailored to User preferences (contextual advertising).

4.1.2. Displaying marketing content matching User interests (behavioral advertising).

4.1.3. Other marketing-related activities, such as direct marketing of goods and services (sending commercial information electronically and telemarketing activities).

4.2. The Administrator may use profiling for marketing activities, involving the automated processing of data to evaluate certain factors about Users, analyze behavior, or predict future actions, enabling better-tailored content to User preferences.

5. Social Media

5.1. The Administrator processes Personal Data of Users visiting its profiles on social media platforms (Facebook, YouTube, Twitter, Google+). This data is processed to manage the profile, inform Users about the Administrator's activity, and promote events, services, and products. The legal basis is the legitimate interest of the Administrator (Article 6(1)(f) GDPR) in promoting its brand.

6. Cookies and Similar Technologies

6.1. Cookies are small text files installed on the User's device while browsing the Service. They collect information to facilitate website usage, e.g., remembering User visits and activities.

Service Cookies

6.2. The Administrator uses service cookies primarily to provide electronic services and improve service quality. Cookies used include:

  • User input cookies during a session (session ID).
  • Multimedia player session cookies (e.g., Flash Player cookies) during a session.
  • Persistent cookies for personalizing the User interface during or slightly longer than the session.

Marketing Cookies

6.3. The Administrator and trusted partners also use cookies for marketing purposes, such as behavioral advertising.

7. Data Recipients

7.1. Personal Data may be disclosed to external entities, including IT service providers, marketing agencies, and entities affiliated with the Administrator, such as group companies.

7.2. The Administrator reserves the right to disclose selected User information to authorized authorities or third parties requesting such information based on a valid legal basis.

8. International Data Transfers

8.1. Personal Data may be transferred outside the European Economic Area (EEA) with appropriate safeguards, including:

  • Cooperation with entities in countries with an adequate level of protection as determined by the European Commission.
  • Use of Standard Contractual Clauses approved by the European Commission.
  • Implementation of Binding Corporate Rules approved by the relevant supervisory authority.
  • Cooperation with U.S. entities participating in the EU-U.S. Data Privacy Framework.

8.2. Users will be informed about such transfers when data is collected.

9. User Rights

9.1. Users have the right to:

  • Access, rectify, erase, or restrict processing of their data.
  • Data portability in a structured format.
  • Object to processing based on legitimate interests or marketing.
  • Withdraw consent at any time by contacting the Administrator.

9.2. Response Time:
🕒 The Administrator will respond to requests within one month under GDPR Article 12. If an extension is necessary, Users will be informed.