Table of Contents

Privacy policy – GovSpeed.ai

Privacy Policy version 1.0 effective from 10.06.2025

§ 1 General Information

  1. The Privacy Policy of the Online Service does not constitute a source of obligations for the Visitor or the Customer of the Online Service. It is of an informative nature and is not a contract or set of regulations.
  2. All expressions and words written with a Capital Letter (e.g., Online Service, Customer, etc.) should be understood in accordance with the content of the Regulations of the Online Service.
  3. In the event of any discrepancies between this Privacy Policy and the consents for personal data processing granted by a natural person, the legal basis for determining the scope of the Controller’s actions shall be the voluntarily expressed consents or the provisions of law applicable to the given factual situation.
  4. In specific situations, while performing Service Agreements, the Controller may process the Customer’s personal data as a processor. In such a case, the Controller enables the Customer to conclude a personal data entrustment agreement regarding the entrusted personal data. If the Customer decides to conclude an entrustment agreement, they should contact the Controller via the email address [email protected].

§ 2 Personal data controller

  1. The Controller of your personal data is Piotr Trąbski conducting business activity under the company name GovSpeed.ai by Trabsky Piotr Trąbski at the address ul. K.E.N. 53/48, 02-797 Warszawa, NIP: 9241910458, REGON: 369837858, BDO: 000595892 (hereinafter: Controller).
  2. For all matters related to personal data protection, we encourage you to contact us at the address indicated above or via the e-mail address: [email protected].
  3. You may also send a request to the indicated address to provide information about what personal data concerning you we possess and for what purposes we process it.
  4. The Controller informs that correspondence is stored for statistical purposes and to improve the GDPR assistance system, as well as regarding complaint resolutions and potential decisions on administrative interventions taken based on reports within the indicated Customer Account. Addresses and data collected in this manner will not be used for communication for purposes other than handling the report; in particular, they will not be used for marketing purposes or transferred to third parties.
  5. In the event of contacting the Controller to perform specific actions (e.g., submitting a complaint, making a return), the Controller may again ask the given person to provide data, including personal data, e.g., in the form of name, surname, residence address, e-mail address, to confirm their identity and enable return contact regarding the matter and the performance of the requested action. Providing this data is not mandatory but may be necessary to perform the action or obtain information of interest to the given person.
  6. If you have expressed additional consent for our use of cookies, the controllers of data obtained based on your activity on the Internet may also be our trusted partners.

§ 3 Data Acquisition and purpose of processing

  1. We process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter: GDPR) and other currently applicable laws on personal data protection during the processing of specific data.
  2. In accordance with the content of the indicated legal acts, personal data is considered to be information about an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  3. We ensure that the data obtained from you is confidential, secure, and processed only when necessary. We process data lawfully, fairly, and in a transparent manner for the data subject. We process only such data and only with such content as is necessary due to a legitimate purpose, i.e., the reason for processing. Personal data is collected with due diligence and properly protected against access by unauthorised persons. We apply appropriate and adequate security measures and technical knowledge to protect personal data against accidental loss, unauthorised access, use, alteration, or disclosure. We store personal data in a form which permits identification of the data subject for no longer than is necessary for the purposes for which the data is processed.
  4. The Controller acquires information about personal data in the following ways:
    1. through the conclusion of a License or Service Agreement in the Online Service by the Customer;
    2. through the registration of a Customer Account;
    3. through voluntary subscription to the Newsletter service;
    4. through information voluntarily entered in an e-mail message, contact form, or chat;
    5. through the submission of a complaint, application, inquiry, or letter of another nature;
    6. through information voluntarily entered in an e-mail message sent in connection with a desire to establish cooperation;
    7. through posting a product review;
    8. through cookies, pixels, or similar internet technologies;
    9. through the implementation of a concluded Service Agreement, if the provision of services results in the entrustment of personal data collected in the Customer’s dataset.
  5. We inform you that the purpose and scope of data processed by the Controller result from the consent of the Visitor to the Website or the Customer or from provisions of law and, in selected cases, are further specified as a result of actions taken by these persons in the Online Service or within other communication channels.
  6. Providing personal data by the Visitor or Customer of the Online Service is voluntary, but necessary to use specific functionalities of the Online Service (e.g., placing an Order by the Customer and its settlement, registering a Customer Account, or using contact forms).
  7. In each case, the scope of data required to conclude the appropriate agreement is indicated beforehand in the Online Service (we mark data the provision of which is necessary to conclude an agreement/use a specific functionality), within other communication channels with the Visitor or Customer, or in the Regulations. The consequence of not providing personal data may be the inability to effectively use the functionality of the Website, e.g., the inability to place an order.
  8. Your personal data is acquired by the Controller for the following purpose:
Purpose of processing Legal basis Legitimate purpose, if any
Conducting statistics. Art. 6(1)(f) GDPR. Possessing information about statistics of our actions, which allows us to improve our business activity.
Conducting marketing activities for own products and services without the use of electronic communication means. Art. 6(1)(f) GDPR. Conducting marketing activities promoting the business activity.
Conducting marketing activities for own products and services using electronic communication means. Art. 6(1)(f) GDPR, whereby due to other applicable regulations, these activities are conducted only based on held consents (Art. 6(1)(a) GDPR). Conducting marketing activities promoting the business activity using e-mail addresses.
Posting a review in the Online Service. Art. 6(1)(a) GDPR. Product satisfaction research.
Handling reports directed via the contact form, chat, e-mail messages, complaints, and other applications. Art. 6(1)(a) GDPR;
Art. 6(1)(c) GDPR.
Responding to reports and inquiries directed via the contact form or in another form, including storing sensitive applications and responses provided to maintain the principle of accountability. Handling applications, responding to consumer complaints. Pursuing claims, including from third parties, defense against them.
Handling the Customer Account. Art. 6(1)(b) GDPR. Conclusion and performance of the Agreement for the provision of electronic services (Account) or taking action at the request of a prospective Customer prior to its conclusion.
Conclusion and performance of a License or Service Agreement. Art. 6(1)(b) GDPR. Conclusion and performance of a License or Service Agreement or taking action at the request of a prospective Customer prior to its conclusion.
Archiving sales documents. Art. 6(1)(c) GDPR. Fulfillment of legal obligations resulting from regulations, e.g., tax and accounting, especially in the case of paid contracts.

(Table based on source)

  1. In the case of an adult Customer or an adult Visitor to the Website, with their additional consent, Personal Data may also be processed for the purpose of presenting, creating, granting, and implementing advertisements, offers, or promotions (discounts) dedicated to the given Customer regarding products or services of the Controller and its partners, adjusted to their preferences to the highest possible degree (profiling), as a result of automated decision-making, which may produce legal effects concerning them or similarly significantly affect them, e.g., through a short-term discount dedicated exclusively to such a person for a specific product they recently viewed in our Online Store (this option is unavailable to persons who are not adults or are adults but have not consented to such action).
  2. Newsletter. If you wish to subscribe to our newsletter, you must mandatorily provide us with your e-mail address via the newsletter subscription form. Providing data is voluntary but necessary to use the newsletter service. Data provided to us during subscription to the newsletter is used for the purpose of sending you the newsletter, in which we inform you about the company’s activities, current collection, promotions, and discounts. The legal basis for processing in this situation is your voluntary consent expressed while subscribing to the newsletter. In this case, your data is processed for the purpose of cyclically sending the newsletter, and the basis for processing is Art. 6(1)(a) GDPR, i.e., your consent resulting from the desire to receive the service. The data will be processed for the duration of the newsletter’s operation unless you resign from receiving it earlier, which will result in the permanent deletion of your data from the database. Furthermore, you can rectify your data saved in the newsletter database at any time, as well as request its deletion by resigning from receiving the newsletter. You also have the right to data portability, contained in Art. 20 GDPR. The newsletter database is appropriately secured by the Controller. The newsletter as a database is handled by an external entity. Sent e-mail messages contain links to hidden images (so-called tracking pixel). Apart from its basic function, which is counting email openings, it optionally also serves to identify the Customer and conduct marketing activities.
  3. Email contact, contact form, chat. By contacting us via electronic mail, contact form, or chat, you provide us with your e-mail address as the sender’s address. Moreover, you may include other personal data in the content of the message. Providing data is voluntary but necessary to establish contact with us. In this case, your data is processed for the purpose of contacting you, and the basis for processing is Art. 6(1)(a) GDPR, i.e., your consent resulting from the desire to contact us. The legal basis for processing after the contact ends is a legitimate purpose in the form of archiving correspondence for internal needs (Art. 6(1)(c) GDPR). The content of correspondence may be subject to archiving, and we are unable to clearly determine when it will be deleted; however, this will be a period no longer than 5 years. You have the right to demand the presentation of the history of correspondence you have conducted with us (if it was subject to archiving), as well as to demand its deletion unless its archiving is justified due to our overriding interests.
  4. Reviews. To add your review about a product/entry, you must fill out a form. In this case, your data is processed for the purpose of enabling the posting of the Review, and the basis for processing is Art. 6(1)(a) GDPR, i.e., your consent resulting from the desire to post your entry on our website. Data will be processed for the duration of the review’s presence on the website unless you request the removal of the review earlier, which will result in the removal of your data related to the review from the database. You can rectify your data in the review at any time, as well as request its deletion. You also have the right to data portability, contained in Art. 20 GDPR.
  5. Customer Account. By setting up a Customer Account on our Website, you provide us with your e-mail address, first name, and surname. This is voluntary but necessary to effectively register a Customer Account. Subsequently, in the Customer Panel, you may also provide billing data. In this case, your data is processed for the purpose of maintaining the Customer Account, and the basis for processing is Art. 6(1)(a) GDPR, i.e., your consent resulting from the desire to set it up. Data will be processed for the duration of possessing the Customer Account unless you request its deletion earlier, which will result in the removal of your data from the database. You can rectify your data assigned to the Customer Account at any time, as well as request its deletion. You also have the right to data portability, contained in Art. 20 GDPR. As part of setting up a Customer Account, you may – but do not have to – consent to subscribe to the newsletter service.

§ 4 Categories of personal data

  1. The personal data Controller may process the following categories of personal data:
    1. personal data provided in the form during Customer Account registration, placing Orders in the Online Service, in particular: e-mail address, first name and surname, telephone number;
    2. personal data supplemented by the user while using the Customer Account, in particular: first name and surname; e-mail address; residence address [street, house number, apartment number, postal code, city, country], and in the case of Customers who are not consumers, additionally the company name and tax identification number [NIP];
    3. personal data necessary to place an order, in particular: first name and surname; e-mail address; contact telephone number; billing address [street, house number, apartment number, postal code, city, country], and in the case of Customers who are not consumers, additionally the company name and tax identification number [NIP];
    4. personal data provided for the purpose of using the newsletter, provided while using the contact form or chat, posting reviews, and sent via e-mail; or transferred while submitting complaints, grievances, or applications, in particular: first name and surname; e-mail address; contact telephone number; address [street, house number, apartment number, postal code, city, country], bank account number;
    5. personal data provided for the purpose of taking part in competitions/promotional campaigns: first name and surname; e-mail address; contact telephone number; residence address [street, house number, apartment number, postal code, city, country];
    6. other data, in particular obtained based on the Customer’s activity on the Internet, including obtained via the Online Service or other communication channels with the Customer, using cookies and similar technologies.

§ 5 Recipients of personal data

  1. Your personal data may be processed by our partners and subcontractors, i.e., entities whose services we use when processing data and providing services to you. To the best of our knowledge, all entities to which we entrust the processing of personal data guarantee the application of appropriate personal data protection and security measures required by law.
  2. The Controller may transfer your personal data to:
    1. service providers who must receive the Customer’s personal data to perform civil law contracts concluded via the Website.
    2. state authorities or other entities entitled under the provisions of law, to fulfill obligations incumbent upon us;
    3. The Controller’s partners may participate in personal data processing to a limited extent, in particular those who technically help to efficiently run the Online Service (e.g., support us in sending e-mails, and in the case of advertising activities – also in marketing campaigns), hosting or ICT service providers, entities handling electronic payments or payment card payments in the Online Service, companies that service software, support the Controller in marketing campaigns, as well as legal and advisory service providers and external accounting;
    4. furthermore, we may share fully anonymised data (data that cannot identify you) with entities with whom we cooperate.
  3. As part of marketing (advertising) activity, the Controller uses the services of third parties that use cookies, pixels, or marketing functions similar to cookies in the Online Service. The catalogue of these entities is detailed in § 8 of this Policy.

§ 6 Archiving of personal data

  1. The Controller will store your personal data only as long as it is necessary for the purposes specified in this Privacy Policy and/or to meet legal and regulatory requirements. After this period, the Controller will securely delete your personal data.
  2. We store data for the periods indicated below:
Data related to the sales procedure. 10 years
Data for marketing purposes. In the case of data processing based on consent – until its withdrawal.
In the case of data processing based on a legitimate purpose – until an objection is raised.
Data transferred using the contact form, chat, e-mail. For a period of 3 years to maintain the principle of accountability.
Data contained in reviews. In the case of data processing based on consent – until its withdrawal. In the case of data processing based on a legitimate purpose – until an objection is raised.
Personal data related to cookies and similar functions. Until the deletion of these files using site / browser / device settings (whereby deletion of files is not always identical to the deletion of Personal Data obtained via these files – in that case, personal data will be deleted by the time an objection is raised).
Data transferred during the complaint procedure and other procedures related to Customer claims. 6 years.
Remaining category of data (except for data from cookies, more about which in our Cookie Policy). 5 years.
  1. In any case, personal data will also be stored when legal regulations (e.g., accounting or tax) oblige the Controller to process them; we will store personal data longer in the event that the Customer has any claims against the Controller, for the purpose of the Controller pursuing claims, or for the purpose of pursuing or defending against claims of third parties, for the limitation period defined by law, in particular the Civil Code.
  2. Depending on the scope of personal data and the purposes of their processing, they may therefore be stored for a different period. In each case, the longer period of personal data storage is decisive.

§ 7 RIGHTS, ACCESS AND UPDATE OF PERSONAL DATA, COMPLAINTS

In accordance with Art. 15 GDPR, you have the right to obtain information from the Controller of personal data as to whether your personal data is being processed.

If the Controller processes your personal data, then you have the right to:

  1. access personal data;
  2. obtain information about the purposes of processing, categories of processed personal data, recipients or categories of recipients of this data, the planned period of storage of your data or criteria for determining this period, rights to which you are entitled under GDPR, and the right to lodge a complaint with a supervisory authority, the source of this data, automated decision-making, including profiling, and safeguards applied in connection with the transfer of this data outside the European Union;
  3. obtain a copy of your personal data.

Furthermore, you may request the rectification of personal data (Art. 16 GDPR), erasure of personal data (Art. 17 GDPR), object to the processing of personal data (Art. 21 GDPR) and, if technically feasible, request the transfer of shared personal data to another organisation (Art. 20 GDPR).

In connection with the right to be forgotten, the Controller will update or delete your data unless they have a legal obligation to retain it for the purposes of conducting business or maintaining compliance with the law. In some cases, you have the right to request restriction of personal data processing (Art. 18 GDPR). You may also contact the Controller in case of reservations regarding the method of collecting, storing, or using personal data.

The Controller strives to promptly consider all requests regarding the above-mentioned operations on your personal data, however, no later than within 30 days from the moment of receiving the request. Due to the complicated nature of the request, the Controller has the right to consider your requests within a period exceeding 30 days, of which they will inform the User beforehand.

The Controller aims to finally resolve complaints, but if you are still dissatisfied with the response obtained, you may lodge a complaint with the supervisory authority dealing with personal data protection, the local data protection authority. In Poland, the supervisory authority within the meaning of GDPR is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych).

§ 8 AUTOMATED PERSONAL DATA PROCESSING, COOKIE POLICY

  1. Our Website, like almost all other websites, uses cookies. The cookie policy applies to both Customers of the Online Service and Visitors to the Online Service, i.e., users who browse the content of the Service but do not make purchases.
  2. The cookie policy constitutes a document that is an integral part of this Privacy Policy. The content of the Cookie Policy can be found here.
  3. The Website also uses functionalities similar to cookies. Therefore, individual provisions of the Cookie Policy should be referred to appropriately for these technologies as well.
  4. Selected cookies process your personal data. Processing of personal data coming from cookies or similar technologies on our Website takes place for the purposes of ensuring the functioning of the Site, adapting the Website to the preferences of the Visitor and Customer, or for analytical purposes. Processing takes place on the basis of our legitimate interest. The legal basis for processing personal data for advertising purposes will be your additional consent, expressed by making a choice and checking a checkbox during the process of consenting to cookies.
  5. When a Visitor uses the Online Service, cookies enabling the identification of their browser or device are used – cookies collect various types of information which, in principle, do not constitute personal data. However, some information, depending on its content and method of use, may be linked to a specific person – assigning certain behaviours to a specific Visitor or Customer, e.g., by linking them with data provided during Account registration in the Online Service, or a specific e-mail address – and thereby be considered personal data.
  6. In relation to information collected by cookies that can be linked to a specific person, the provisions of the Privacy Policy of the Online Service relating to personal data apply, in particular concerning the rights of the data subject.
  7. The Website uses profiling. Thanks to cookies used in the Online Service, it is possible for the Controller to learn about the preferences of the Visitor/Customer – e.g., by analyzing how often they visit the Online Service and whether and what products they buy. Analysis of behaviour on the Internet helps to better understand the habits and expectations of Customers and Visitors and to adapt to their needs and interests. Thanks to this technology, it is possible to present Visitors with advertisements tailored to their needs and interests and to prepare better promotions and surprises for adult Visitors who have agreed to this.

§ 9 CHANGES TO PRIVACY POLICY

  1. These principles of Privacy Policy 1.0 are effective from 10.06.2025.
  2. The Controller declares that they have the right to make changes to this document for important reasons, among others:
    1. changes in applicable regulations, in particular regarding GDPR, telecommunications law, services provided electronically, and regulating consumer rights, affecting the rights and obligations of the Controller or the rights and obligations of the data subject;
    2. development of functionalities or electronic services caused by the progress of internet technology, including the implementation of new IT, technological, or technical solutions on the Website, affecting the scope of this Privacy Policy.
  3. The Controller undertakes to inform Users about any changes with appropriate advance notice, allowing them to familiarize themselves with the content of the changed document, e.g., by placing the consolidated text of the Privacy Policy on the main page of the Online Service.
  4. In the case of users using the newsletter function, if the Controller makes fundamental changes to the content of the Privacy Policy, they will then inform Users about them via electronic mail. In the case of any reservations regarding the change of the Policy, the User has the right to stop using the newsletter by sending a request to unsubscribe from the newsletter or by requesting the deletion of their personal data.

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