Privacy Policy

1. Data Controller

The data controller responsible for your personal data is Aptivy, with its registered address at Teofila Firlika 41, 71-637 Szczecin, Poland. You may contact us regarding data protection matters at: info@aptivypl.com or by phone at +48 600 888 068.

2. What Personal Data We Collect

We collect personal data only when you actively provide it to us. The categories of data we may collect include:

• Contact information: your name, email address, and phone number when you submit our contact form or request materials.
• Communication content: the content of messages you send us through our contact form or by email.
• Technical data: IP address, browser type, operating system, and pages visited, collected automatically when you visit our website via cookies and similar technologies.
• Consultation-related information: information you choose to share during educational consultation sessions, which is used solely to conduct those sessions.

We do not collect sensitive personal data such as financial account numbers, health information, or government identification numbers.

3. Legal Basis for Processing

We process your personal data on the following legal bases under the General Data Protection Regulation (GDPR) and Polish law:

• Consent (Article 6(1)(a) GDPR): when you submit the contact form and check the consent checkbox, or when you accept non-essential cookies.
• Legitimate interests (Article 6(1)(f) GDPR): for website security, fraud prevention, and improving our services.
• Performance of a contract or pre-contractual steps (Article 6(1)(b) GDPR): when processing your inquiry about our services.

4. How We Use Your Data

We use the personal data we collect for the following purposes:

• To respond to your inquiries and provide information about our services.
• To send you requested educational materials.
• To conduct educational consultation sessions you have arranged with us.
• To improve the functionality and content of our website.
• To comply with legal obligations.

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

5. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected:

• Contact form submissions and correspondence: up to 3 years from the date of last contact, unless a longer retention period is required by law.
• Consultation records: up to 5 years from the date of the last session, in accordance with standard business record-keeping requirements.
• Technical/cookie data: as specified in our Cookie Policy.

6. Data Sharing and Transfers

We do not sell, rent, or share your personal data with third parties for their own marketing purposes. We may share data with:

• Service providers who assist in operating our website (hosting, email delivery), bound by data processing agreements.
• Competent authorities when required by law.

We do not transfer personal data outside the European Economic Area (EEA) without appropriate safeguards in place.

7. Your Rights

Under GDPR and applicable Polish law, you have the following rights regarding your personal data:

• Right of access: you may request a copy of the personal data we hold about you.
• Right to rectification: you may request correction of inaccurate or incomplete data.
• Right to erasure: you may request deletion of your data where there is no longer a legal basis for processing it.
• Right to restriction: you may request that we limit the processing of your data in certain circumstances.
• Right to data portability: you may request your data in a structured, commonly used, machine-readable format.
• Right to object: you may object to processing based on legitimate interests.
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at info@aptivypl.com. We will respond within 30 days.

You also have the right to lodge a complaint with the Polish supervisory authority: Urząd Ochrony Danych Osobowych (UODO), ul. Stawki 2, 00-193 Warsaw, Poland. Website: uodo.gov.pl.

8. Website Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or disclosure. Our website uses HTTPS encryption for data transmission.

9. Cookies

Our website uses cookies. For detailed information about the cookies we use and how to manage them, please see our Cookie Policy.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we make significant changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically.

11. Contact

For any questions or concerns about this Privacy Policy or our data practices, please contact us at:

• Email: info@aptivypl.com
• Phone: +48 600 888 068
• Post: Teofila Firlika 41, 71-637 Szczecin, Poland