Privacy Policy

1. Data Controller

The data controller for personal data collected through the website wabacu.info is Wabacu, with its registered address at aleja Solidarności 15, Białystok, Poland. You may contact us regarding data protection matters at [email protected] or by telephone at +48 85 662 89 20.

This Privacy Policy is issued in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation, "GDPR") and the Polish Act of 10 May 2018 on the Protection of Personal Data (Ustawa z dnia 10 maja 2018 r. o ochronie danych osobowych, Dz.U. 2018 poz. 1000 as amended).

2. Data We Collect

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

• Contact data: full name, email address, telephone number, and any information you include in a message submitted through our contact form.
• Newsletter data: email address provided when subscribing to program update communications.
• Technical data: IP address, browser type, operating system, referring URL, and pages visited, collected automatically when you access our website. This data is collected in aggregated or pseudonymized form and is not used to identify individuals unless required by law.
• Cookie data: preferences and session information stored via cookies, as described in our Cookie Policy.

We do not collect special categories of personal data (sensitive data) as defined in Article 9 GDPR, and we do not collect data from individuals under the age of 16.

3. Legal Basis for Processing

We process your personal data on the following legal bases as set out in Article 6 GDPR:

• Article 6(1)(a) - Consent: where you have given explicit consent, for example when subscribing to program updates or accepting non-essential cookies.
• Article 6(1)(b) - Contract performance: where processing is necessary to respond to an inquiry or to perform a contract for training services.
• Article 6(1)(c) - Legal obligation: where we are required to process data to comply with applicable Polish and EU law.
• Article 6(1)(f) - Legitimate interests: for the purposes of website security, fraud prevention, and improving our services, where our interests do not override your fundamental rights and freedoms.

4. Purpose of Processing

We use collected data for the following purposes:

• Responding to inquiries submitted through the contact form.
• Sending program update communications to newsletter subscribers.
• Administering participation in the Wabacu training program where a contract has been agreed.
• Maintaining the security and performance of the website.
• Complying with legal obligations applicable to our activities in Poland.

We do not use your personal data for automated decision-making or profiling as defined in Article 22 GDPR.

5. Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by applicable law.

• Contact form inquiries: retained for up to 24 months from the date of last contact, unless a contractual relationship is established.
• Contractual data: retained for 5 years from the end of the contractual relationship in accordance with Polish civil law requirements (Kodeks cywilny).
• Newsletter subscriptions: retained until you withdraw consent by unsubscribing.
• Technical and cookie data: retained in accordance with the periods specified in our Cookie Policy.

6. Your Rights

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

• Right of access (Article 15 GDPR): you may request a copy of the personal data we hold about you.
• Right to rectification (Article 16 GDPR): you may request correction of inaccurate data.
• Right to erasure (Article 17 GDPR): you may request deletion of your data where there is no longer a lawful basis for processing.
• Right to restriction (Article 18 GDPR): you may request that we limit how we use your data in certain circumstances.
• Right to data portability (Article 20 GDPR): where processing is based on consent or contract and carried out by automated means, you may request your data in a machine-readable format.
• Right to object (Article 21 GDPR): 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, contact us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO), ul. Stawki 2, 00-193 Warsaw, Poland.

7. Sharing Personal Data

We do not sell, rent, or trade personal data. We may share data with third parties only in the following circumstances:

• Service providers: technical service providers who assist with website hosting, email delivery, or analytics, acting as data processors under Article 28 GDPR agreements.
• Legal requirements: where disclosure is required by Polish or EU law, court order, or regulatory authority.

Where data is transferred outside the European Economic Area, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

8. Cookies

Our website uses cookies. Detailed information about the types of cookies we use, their purposes, and how to manage your preferences is provided in our Cookie Policy. Non-essential cookies are only placed with your explicit consent, in accordance with Article 6(1)(a) GDPR and the Polish Telecommunications Law (Prawo telekomunikacyjne).

9. Security Measures

We implement appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures are reviewed and updated regularly. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Where changes are material, we will update the "Last Updated" date at the top of this document. We encourage you to review this policy periodically. Continued use of the website after changes are posted constitutes acceptance of the updated policy.

11. Contact

For any questions, requests, or concerns regarding this Privacy Policy or our data processing practices, please contact us: