Privacy Policy

Last updated: <date of approval>

This policy explains what happens to the personal data you send through this website: when you write to us, book a consultation, or allow analytics cookies.

DRAFT FOR LEGAL REVIEW, NOT LEGAL ADVICE

Who is responsible for your data

The controller of your personal data is <F-02 legal name>, <F-05 registered address>, entered in the National Court Register (KRS) under number <F-06 KRS>, NIP <F-06 NIP>. In this policy we call it "Unbelievable Software" or "we".

For anything about your personal data, write to <F-19 approved email address>.

[legal review: confirm whether a data protection officer is required; if not, no DPO is named]

Enquiries sent through the contact form

When you send an enquiry, the details you enter go to us as an email: your name, work email address, company, the service or topic you choose and your message, and, if you add them, your phone number and an approximate budget. The email also states the page you sent the form from, the language version of the site and the time it was sent.

The website does not keep its own copy of your enquiry. The form passes it to Google Workspace, which sends it to our company mailbox, and the enquiry is kept there as our record of the conversation. Your email address is set as the reply address so that we can answer you directly.

We use these details to read and answer your enquiry, to discuss possible work with you and to keep a record of the conversation. The legal bases are taking steps at your request before a possible contract (Article 6(1)(b) GDPR) and our legitimate interest in answering business enquiries and keeping records of them (Article 6(1)(f) GDPR).

If your enquiry concerns Google Ads, Meta Ads or analytics, we may share the details needed for the work with our marketing partner, an independent subcontractor who works under our management. [legal review: confirm whether enquiries are shared with the partner before any contract, and the agreement that covers it]

[legal review and engineering: if campaign details from the link you followed are added to the email, list them here with their legal basis]

Spam protection

The contact form uses Cloudflare Turnstile to check that a person, not an automated program, is sending it. To do that, Cloudflare processes technical information about your connection, browser and device, including your IP address. The form also checks every submission and limits its size, and Cloudflare may apply rate limits to requests from one connection. We use this on the basis of our legitimate interest in protecting the form from abuse (Article 6(1)(f) GDPR).

[legal review: confirm Cloudflare's role for Turnstile (processor or independent controller) and link to its privacy information]

Booking a consultation

When you choose a time for a consultation, you do so on a booking page run by Google as part of Google Calendar. Google collects the details you enter there, such as your name and email address, and passes them to us with the booking. Google's own privacy policy applies to how Google handles them.

We use the booking details to hold the conversation you asked for and to prepare for it. The legal bases are the same as for enquiries.

Analytics

With your consent, this website loads Google Analytics 4 under our measurement ID. It tells us how the site is used, for example which pages are visited, whether an enquiry was sent and whether someone opened the booking page.

Google Analytics never receives the contents of your enquiry, your name, your email address or other details you type into the form. The website uses no advertising cookies and no Google Tag Manager.

Until you make a choice, analytics stays off. You can give, refuse or withdraw consent at any time in the cookie settings, linked at the bottom of every page and on the Cookie Policy page. The legal basis is your consent (Article 6(1)(a) GDPR). [legal review: cite the Polish provision on storing and reading information on a user's device, and confirm the wording against the implemented consent configuration]

Hosting

The website is hosted on Cloudflare Pages, and the contact form runs as a small Cloudflare function, which handles the contents of your enquiry in transit and keeps none of them. Cloudflare processes technical information such as your IP address, the time of the request, the page requested and your browser type to deliver the site and keep it secure. Cloudflare acts as our processor for this, and we rely on our legitimate interest in running a secure website (Article 6(1)(f) GDPR).

[to be confirmed by the owner's legal review: where Cloudflare processes and stores this data, whether EU data handling applies to this plan, and which logs, if any, are kept and for how long]

Who receives your data

We use service providers who process data on our behalf under written agreements: Cloudflare (hosting, the contact form function and spam protection) and Google (Workspace email, Calendar and, with your consent, Analytics). We don't sell personal data.

[legal review: confirm the final list of recipients and their roles]

Transfers outside the European Economic Area

Cloudflare and Google are based in, or have parent companies in, the United States. Where personal data is transferred outside the European Economic Area, the transfer relies on <safeguard, for example the EU-US Data Privacy Framework or standard contractual clauses>. [legal review: confirm the safeguard for each provider]

How long we keep your data

Enquiries and booking details are kept in our company mailbox and calendar for <mailbox retention period to be set by the owner and legal adviser>, then deleted, or earlier if you ask. The website itself keeps no copy. Analytics data: <period configured in Google Analytics 4>. [legal review: confirm each period]

Your rights

You have the right to access your personal data, to have it corrected or deleted, to restrict its processing, to receive it in a portable format, and to object to processing based on our legitimate interest. Where processing is based on your consent, you can withdraw it at any time; this does not affect processing that took place before.

To use any of these rights, write to <F-19 approved email address>.

You also have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych) in Poland.

Do you have to give us your data?

You don't have to send an enquiry or book a consultation. If you do, we need your name, email address, company, topic and message to answer you. The phone number and budget are optional.

Automated decisions

We don't make decisions about you based solely on automated processing, and we don't use your data for profiling with legal or similarly significant effects.

Changes to this policy

If this policy changes, we update it on this page and change the date at the top.