Privacy Policy

Last updated: 20 July 2026 Governed by Polish law and GDPR
Section 1

Data Controller

The data controller responsible for processing personal data collected through this website is Xedobo Rutumu, located at Zachodnia 70, Łódź, Poland. For all matters relating to the processing of your personal data, you may contact us at: [email protected] or by telephone at +48 601 636 040.

This Privacy Policy describes how we collect, use, store, and protect personal data 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 (Dz.U. 2018 poz. 1000, as amended).

Section 2

What Data We Collect

We collect only the personal data that you voluntarily provide to us, or that is automatically collected during your use of this website. This includes:

  • Contact data: When you submit an enquiry through our contact form, we collect your name, email address, telephone number, and the content of your message.
  • Technical data: We may collect IP address, browser type, operating system, referring URLs, and pages visited, collected automatically via server logs or analytics tools where you have consented to their use.
  • Cookie data: As described in our Cookie Policy, we may set and read cookies on your device, subject to your consent preferences.

We do not collect sensitive personal data as defined under Article 9 GDPR (such as health data, racial origin, or biometric identifiers) through this website.

Section 3

Legal Basis for Processing

We process your personal data on the following legal bases, as specified under Article 6 GDPR:

  • Article 6(1)(b) GDPR — Processing is necessary to take steps at your request prior to entering into a contract, or to perform a contract to which you are a party. This applies when you enquire about sessions or request information about our services.
  • Article 6(1)(c) GDPR — Processing is necessary for compliance with a legal obligation under Polish or EU law.
  • Article 6(1)(a) GDPR — Where you have given consent to processing, such as for optional analytics or marketing cookies.
  • Article 6(1)(f) GDPR — Where processing is necessary for the purposes of legitimate interests pursued by us, provided that those interests are not overridden by your fundamental rights. This applies to basic server logging for security and performance purposes.
Section 4

Purposes of Processing

Personal data collected via this website is processed for the following purposes:

  • Responding to enquiries submitted through the contact form
  • Providing information about sessions, the platform's educational content, and related services
  • Maintaining the technical operation and security of this website
  • Improving website content and user experience, where analytics consent has been granted
  • Compliance with applicable legal obligations

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

Section 5

Data Retention

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

Enquiry data submitted via the contact form is retained for a period of up to 24 months from the date of submission, unless a longer retention period is required by law or by the nature of an ongoing relationship. Technical log data is retained for up to 12 months. Cookie preference records are stored for the duration specified in our Cookie Policy.

Once the retention period expires, personal data is securely deleted or anonymized in a manner that prevents re-identification.

Section 6

Sharing and Disclosure of Data

We do not sell, rent, or trade your personal data with third parties. We may share data with:

  • Service providers: Third-party vendors who assist with website hosting, email delivery, or analytics, where they act as data processors under a data processing agreement and provide appropriate safeguards.
  • Legal authorities: Where required by applicable Polish or EU law, court order, or government authority, we may disclose personal data to the extent required.

Where data is shared with processors outside the European Economic Area, we ensure appropriate safeguards are in place in accordance with Chapter V GDPR (such as Standard Contractual Clauses approved by the European Commission).

Section 7

Your Rights Under GDPR

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

  • Right of access (Article 15): You may request a copy of the personal data we hold about you.
  • Right to rectification (Article 16): You may request correction of inaccurate or incomplete data.
  • Right to erasure (Article 17): You may request deletion of your personal data in certain circumstances.
  • Right to restriction of processing (Article 18): You may request that we restrict processing in certain circumstances.
  • Right to data portability (Article 20): Where processing is based on consent or contract, you may request your data in a structured, machine-readable format.
  • Right to object (Article 21): You may object to processing based on legitimate interests.
  • Right to withdraw consent (Article 7(3)): Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

You also have the right to lodge a complaint with the President of the Office for Personal Data Protection (UODO) — Urząd Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, Poland — if you believe your rights have been infringed.

Section 8

Data Security

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 in line with industry standards and the requirements of Article 32 GDPR.

While we take reasonable precautions, no transmission of data over the internet is entirely secure. If you become aware of any security concern related to this website, please notify us promptly at [email protected].

Section 9

Third-Party Links

This website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any third-party sites you visit.

Section 10

Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. We encourage you to review this policy periodically. Continued use of this website following any changes constitutes your acknowledgment of the updated policy.

For questions about this Privacy Policy, contact us at [email protected] or at our postal address: Zachodnia 70, Łódź, Poland.