Privacy Policy

This Privacy Policy describes how Huviji Cocuni, operating at Nowina 12/1, Poznań, Poland ("we", "us", or "our"), collects, uses, stores, and protects personal data obtained through the website huviji-cocuni.info and any related contact or enquiry processes. We are committed to handling personal data responsibly and in full compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation, "GDPR"), and with the Polish Act of 10 May 2018 on the Protection of Personal Data (Ustawa z dnia 10 maja 2018 r. o ochronie danych osobowych), which supplements and implements the GDPR in the Polish legal order.

The data controller for personal data processed in connection with this website is Huviji Cocuni, Nowina 12/1, Poznań, Poland. You may contact us at any time regarding data protection matters by email at [email protected] or by telephone at +48 501 083 970.

1. What Data We Collect and Why

We collect personal data only where there is a lawful basis for doing so under Article 6 of the GDPR. The data we collect falls into the following categories.

When you complete and submit a contact form or a programme enquiry form on this website, you provide us with your name, email address, telephone number, and the content of your message. We process this data on the basis of our legitimate interest in responding to enquiries about our educational programme (Article 6(1)(f) GDPR), and where you have given explicit consent by ticking the required privacy checkbox, additionally on the basis of Article 6(1)(a) GDPR. This data is used solely to respond to your enquiry and, where relevant, to provide you with information about the programme you have asked about. We do not use contact form submissions for marketing purposes without separate, explicit consent.

When you access this website, certain technical data is collected automatically by the web server and, where you have consented, by analytics tools. This includes your IP address, browser type and version, the pages you visit, the time and date of your visit, and referring URLs. Technical data collected by the server is processed on the basis of our legitimate interest in maintaining the security and proper functioning of the website (Article 6(1)(f) GDPR). Analytics data is collected only where you have given consent through our cookie consent mechanism (Article 6(1)(a) GDPR).

We do not collect special categories of personal data as defined in Article 9 of the GDPR, and we do not knowingly collect personal data from individuals under the age of 18.

2. How Long We Retain Your Data

Personal data collected through contact forms is retained for as long as necessary to handle your enquiry and for a reasonable period thereafter in case of follow-up questions, typically no longer than 24 months from the date of your last communication with us. After this period, contact data is securely deleted unless we are required to retain it for longer by applicable law, for example for accounting or tax purposes under Polish fiscal regulations.

Technical server logs are retained for a period not exceeding 12 months. Analytics data retention periods are determined by the relevant analytics provider and are subject to the consent settings you have chosen through our cookie consent tool.

3. Sharing of Personal Data

We do not sell, rent, or trade personal data to third parties. We may share data with service providers who assist us in operating this website and delivering our programme, such as hosting providers and email service providers. These providers act as data processors under Article 28 of the GDPR and are bound by data processing agreements that require them to process data only on our instructions and in accordance with applicable data protection law. We ensure that any processors we engage provide sufficient guarantees regarding their technical and organisational security measures.

We may also disclose personal data where required to do so by applicable law, by a court order, or by a competent supervisory authority. The supervisory authority for data protection in Poland is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO), ul. Stawki 2, 00-193 Warsaw.

We do not transfer personal data to countries outside the European Economic Area unless appropriate safeguards are in place as required by Chapter V of the GDPR, such as standard contractual clauses approved by the European Commission or an adequacy decision covering the recipient country.

4. Your Rights Under GDPR

As a data subject under the GDPR, you have a number of rights in relation to your personal data. You have the right to access the personal data we hold about you and to receive a copy of it (Article 15 GDPR). You have the right to request correction of inaccurate data (Article 16 GDPR). You have the right to request erasure of your data in certain circumstances, for example where the data is no longer necessary for the purpose for which it was collected (Article 17 GDPR). You have the right to restrict processing in certain circumstances (Article 18 GDPR). You have the right to data portability where processing is based on consent or a contract and is carried out by automated means (Article 20 GDPR). You have the right to object to processing based on legitimate interests (Article 21 GDPR).

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that took place before the withdrawal. To exercise any of these rights, please contact us at [email protected]. We will respond to your request within one month as required by Article 12 of the GDPR, and without charge in ordinary circumstances.

If you believe that we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the UODO. Contact details for the UODO are available at www.uodo.gov.pl.

5. Cookies and Tracking Technologies

This website uses cookies and similar technologies. Our use of cookies is governed by our Cookie Policy, which is available at cookies.html. The Cookie Policy provides full details of the categories of cookies we use, their purposes, and how you can manage your preferences. We operate a consent-based approach to non-essential cookies in accordance with Article 5(3) of Directive 2002/58/EC as amended (the ePrivacy Directive) and the implementing Polish legislation.

6. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction, in accordance with Article 32 of the GDPR. These measures include encrypted transmission of data via HTTPS, access controls limiting who within our organisation can access personal data, and regular review of our security practices. No method of transmission over the internet or electronic storage is entirely secure, and we cannot guarantee absolute security, but we take our obligations under Article 32 seriously and review our measures regularly.

7. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing practices or in applicable law. When we make material changes, we will update the "Last Updated" date at the top of this document. We encourage you to review this policy periodically. Continued use of this website after any changes constitutes acceptance of the updated policy to the extent permitted by applicable law.

For any questions about this Privacy Policy or about how we handle your personal data, please contact us at [email protected] or at our postal address: Huviji Cocuni, Nowina 12/1, Poznań, Poland.