Privacy Policy

This is a translation for convenience. The Polish version (Polityka Prywatności) is the binding one.

1. General provisions

This Privacy Policy sets out how we process and protect the personal data of people who use the renacode.com website and who contact us by e-mail.

We care about our users' privacy, and personal data is processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and the Polish Personal Data Protection Act.

2. Data controller

The controller of the personal data processed in connection with the operation of the Website and the provision of IT consulting services is RenaCode, a sole proprietorship registered in Poland:

• address: ul. Wolbromska 18/1b, Wrocław, Poland,
• Polish tax ID (NIP): 8992692240,
• e-mail: contact@renacode.com.

The controller has not appointed a data protection officer. Please send any questions about privacy and your rights to the e-mail address above.

3. Purposes and legal bases of processing

Your personal data (such as your e-mail address, first name, last name, company name and the content of your e-mail enquiry) may be processed for the following purposes:

• Replying to enquiries you send us (legal basis: Art. 6(1)(b) GDPR – steps taken before entering into a contract).
• Performing B2B contracts and ongoing business contact (legal basis: Art. 6(1)(b) and (f) GDPR – performance of a contract and the controller's legitimate interest in contacting the people who represent a contractor and in establishing, exercising or defending legal claims).
• Complying with legal obligations, including accounting and tax obligations (legal basis: Art. 6(1)(c) GDPR).
• Keeping the Website secure and working properly using the server logs described in section 4 (legal basis: Art. 6(1)(f) GDPR – the controller's legitimate interest).

Providing data in an e-mail is voluntary, but without an e-mail address we cannot reply to your enquiry. Providing the data necessary to conclude a contract is a condition of concluding it, and providing the data required by tax law is a statutory obligation. The data is not used for automated decision-making or profiling.

4. Server logs

Each time the Website is visited, the server logs: the device's IP address, the date and time of the request, the address of the requested page or file, the response code and the size of the data sent, the referring page (if the browser sends it) and the browser identifier (User-Agent).

The logs are used only to diagnose errors and protect against abuse (legal basis: Art. 6(1)(f) GDPR). We do not combine them with other data and do not use them for profiling or to identify visitors.

The logs are not archived or moved to a separate system. They are deleted automatically: with every update of the Website (usually at least once a week), or earlier when they exceed the size limit set on the server. At current traffic this means they are kept for no longer than about 3 weeks.

5. Cookies and analytics

The Website does not store cookies or use any other technology that stores information on the user's device. We do not use analytics tools, tracking pixels or social media plugins. All of the Website's resources (including fonts) are served only from the renacode.com server.

6. Retention periods

• E-mail correspondence – until the conversation ends, and if a contract is concluded, for its duration and until claims arising from it become time-barred.
• Accounting and tax documents – for 5 years from the end of the calendar year in which the tax payment deadline passed.
• Server logs – as described in section 4, for no longer than about 3 weeks.

7. Recipients and transfers of data

Users' personal data is not sold or passed on to third parties for marketing purposes. Access to the data may be given only to entities providing the controller with services necessary to run the business (e.g. hosting, e-mail, accounting).

The server that runs the Website and produces the logs is located in Poland. E-mail is handled by Apple's iCloud+ service (provided to users in the European Union by Apple Distribution International Ltd., Ireland). Apple may also process data in the United States, i.e. outside the European Economic Area. Such transfers are based on the standard contractual clauses adopted by the European Commission (Art. 46(2)(c) GDPR), which Apple relies on in its privacy policy. Information about these safeguards and a copy of them can be obtained by writing to the controller's e-mail address.

8. Rights of data subjects

Every data subject has the right to:

• Access their personal data and receive a copy of it.
• Rectify (correct) or complete inaccurate data.
• Erasure of data ("right to be forgotten") where permitted by law.
• Restriction of processing of their personal data.
• Data portability (Art. 20 GDPR) – for data processed on the basis of a contract.
• Object to processing based on legitimate interest (Art. 6(1)(f) GDPR), including logging in the server logs (details below).
• Lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, Poland) if you believe that the processing infringes the GDPR.

Right to object (Art. 21 GDPR). You may at any time object, on grounds relating to your particular situation, to the processing of your data based on the controller's legitimate interest (Art. 6(1)(f) GDPR). After an objection, the controller stops processing that data unless it demonstrates compelling legitimate grounds that override your interests, rights and freedoms, or grounds for establishing, exercising or defending legal claims.

To exercise your rights, contact us by e-mail.

9. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy. All changes will be published on this page and take effect on the day they are published.