Privacy Policy | Vertiny

§ 1 Data Controller

The Data Controller of your personal data is [to be completed: first and last name], a sole proprietor conducting business under the name Vertiny at the address: ul. Żelazna 51, 00-841 Warsaw, and operating the website available at vertiny.com (hereinafter referred to as the “Website”).

The use of cookies is governed by the Cookie Policy, while the provision of the Newsletter service is governed by the Newsletter Terms.

Contact with the Data Controller:

NIP: [to be completed]
REGON: [to be completed]
E-mail: contact@vertiny.com
Address: ul. Żelazna 51, 00-841 Warsaw

§ 2 Purposes and Legal Basis for Data Processing

We process your personal data for the following purposes:

1.Responding to an inquiry submitted via the contact formLegal basis: Article 6(1)(b) and (f) GDPR (performance of a contract / legitimate interest)
2.Operating the Website and ensuring its proper functioningLegal basis: Article 6(1)(f) GDPR (legitimate interest — operation, maintenance, and security of the Website)
3.Providing the Newsletter service and delivering additional materialsLegal basis: Article 6(1)(b) GDPR (necessity for the performance of a contract for the provision of digital content, the terms of which are set out in the Newsletter Terms)
4.Analysis of traffic on the WebsiteLegal basis: Article 6(1)(a) GDPR (your consent given through the consent banner, which may be withdrawn at any time)
5.Compliance with obligations arising from applicable law (tax and accounting)Legal basis: Article 6(1)(c) GDPR (legal obligation)
6.Conducting recruitment for positions advertised on the WebsiteLegal basis: Article 6(1)(b) and (c) GDPR in conjunction with Article 22¹ of the Labour Code (steps prior to entering into a contract / legal obligation) and, for data provided on your own initiative beyond that scope, Article 6(1)(a) GDPR (consent)

We do not make decisions concerning you based solely on automated processing that would produce legal effects concerning you.

§ 3 Scope of Processed Data

Depending on how you use the Website, we may process:

Identification data: first and last name, company name, tax identification number (NIP)
Contact data: email address, telephone number, correspondence address
Technical data: IP address, browser type and version, operating system, time and source of visit
Subscriber data: email address, first name (if provided), communication preferences
Candidate data: information contained in CVs and recruitment correspondence

Providing data is voluntary. However, without contact details, we will not be able to respond to an inquiry submitted via the contact form; without an email address, we will not be able to send the Newsletter; and without the data contained in your application, we will not be able to consider your candidacy.

§ 4 Data Recipients

Your data may be disclosed to the following categories of recipients:

Hosting and cloud service providers (technical infrastructure of the Website)
Accounting firm or law firm (to the extent required by law)
Public authorities (solely on the basis of applicable law)

Third-party service providers:

Google LLC (Google Analytics 4) — traffic analytics, transfer of data to the United States under SCCs
MailerLite — delivery of the Newsletter and email communications
Web3Forms — forwarding messages from the contact form to the Data Controller’s email address
CookieYes — management of cookie consents and recording of consents given

§ 5 Transfers of Data to Third Countries

Some of our providers (including Google LLC and Web3Forms) are established outside the European Economic Area, including in the United States and India. Data transfers are carried out on the basis of standard contractual clauses approved by the European Commission (Article 46(2)(c) GDPR). You have the right to obtain a copy of the safeguards applied — please contact us.

§ 6 Data Retention Period

Data from the contact form: for up to 24 months from the last contact
Data necessary for the performance of a contract or order: for the duration of the contract + 3 years (limitation period for civil claims)
Data required for tax and accounting purposes: 5 years from the end of the tax year (Article 74 of the Accounting Act)
Newsletter subscriber data: until termination of the agreement for the provision of the Newsletter service (subscription cancellation)
Candidate data: until the end of the recruitment process in which the application was submitted
Data in system and analytics logs: for up to 24 months

§ 7 Your Rights

Under the GDPR, you have the following rights:

Right of access to data (Article 15 GDPR)
Right to rectification of inaccurate data (Article 16 GDPR)
Right to erasure of data (Article 17 GDPR) — the “right to be forgotten”
Right to restriction of processing (Article 18 GDPR)
Right to data portability (Article 20 GDPR)
Right to object to processing (Article 21 GDPR)
Right to withdraw consent at any time (without affecting the lawfulness of processing carried out before withdrawal)
Right to lodge a complaint with the President of the UODO (ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl/en)

To exercise your rights, please contact us: contact@vertiny.com

We will respond within one month. In particularly complex cases, this period may be extended by a further two months — we will inform you of this within the first month.

§ 8 Data Security

We implement appropriate technical and organisational measures to protect your personal data, including TLS/SSL encryption of connections, access controls for systems, regular backups, and security reviews.

§ 9 Changes to the Privacy Policy

We reserve the right to update this Policy. The date of the latest amendment is always shown in the document header. We will inform you of material changes through a prominent notice on the Website or by email.