1. Controller Identity
The controller of personal data processed through this website is the operator of nugeye.info, reachable at: Walerego Sławka 3a, Kraków, Poland; email: [email protected]; telephone: +48 535 055 110.
This Privacy Policy applies to all personal data collected through the website nugeye.info and through any communications initiated via the contact details provided on this site. It has been prepared 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 (Ustawa z dnia 10 maja 2018 r. o ochronie danych osobowych, Dz.U. 2018 poz. 1000).
2. Legal Basis for Processing
Personal data collected through this website is processed on the following legal bases as defined in Article 6 of the GDPR:
Consent (Art. 6(1)(a) GDPR): Where you have provided explicit consent, such as when submitting the contact form and ticking the privacy checkbox, or when accepting non-essential cookies through the cookie consent mechanism.
Legitimate interests (Art. 6(1)(f) GDPR): For the purpose of maintaining the security and proper functioning of the website, and for basic analytics that help the platform improve its educational content. The controller has assessed that these interests do not override the fundamental rights and freedoms of data subjects.
Performance of a contract or pre-contractual steps (Art. 6(1)(b) GDPR): Where contact is initiated in relation to a potential consultation or engagement with the platform, processing of contact details is necessary to respond to the enquiry.
3. Categories of Personal Data Collected
The following categories of personal data may be collected through use of this website:
Contact form data: Name, email address, telephone number, and the content of any message submitted through the contact form on the contact page.
Technical data: IP address, browser type and version, operating system, referral URL, pages visited, time and date of visit. This data is collected automatically when you access the website and is used for security and basic operational purposes.
Cookie data: Data collected through cookies placed on your device, subject to your consent choices. The nature of cookie data collected depends on which cookie categories you have accepted. See Section 9 and the separate Cookie Policy for full details.
The platform does not collect sensitive personal data (special categories under Art. 9 GDPR) and does not knowingly collect data from individuals under the age of 16.
4. Purposes of Processing
Personal data is processed for the following purposes:
Responding to enquiries: Contact form submissions and direct communications are processed for the purpose of responding to questions, booking consultations, and providing information about the platform.
Website operation and security: Technical data is processed to maintain the security, integrity, and proper functioning of the website.
Analytics and platform improvement: Where analytics cookies have been accepted, aggregated data is used to understand how visitors navigate the platform and to improve the quality of educational content.
Marketing communications: Where marketing cookies have been accepted, data may be used to understand the effectiveness of content and to present relevant information to visitors. No direct marketing emails are sent without separate explicit consent.
5. Data Retention Periods
Contact form data is retained for a period of no longer than 24 months from the date of submission, unless a longer retention period is required to fulfil a contractual or legal obligation, or unless the data subject has requested deletion earlier.
Technical access log data is retained for no longer than 12 months for security and diagnostic purposes.
Cookie consent records are retained for the duration necessary to demonstrate compliance with consent requirements, typically aligned with the cookie consent expiry period of 12 months.
Where data has been processed on the basis of consent, it will be deleted promptly upon withdrawal of that consent, provided no other legal basis exists for its continued processing.
6. Data Recipients and Third Parties
Personal data collected through this website is not sold to third parties. Data may be shared with the following categories of recipients under appropriate data processing agreements:
Hosting and infrastructure providers: The website is hosted on third-party infrastructure. The hosting provider processes technical data as a data processor acting under the controller's instructions.
Email service providers: Where contact form submissions are routed through email, the email service provider processes the message content as a data processor.
Analytics service providers: Where analytics cookies have been accepted, aggregated usage data may be processed by analytics platforms. These providers act as data processors or independent controllers depending on the service configuration.
All third-party processors engaged by the controller are required to process personal data only in accordance with documented instructions and in compliance with the GDPR.
7. International Data Transfers
Where personal data is transferred outside the European Economic Area (EEA), the controller ensures that appropriate safeguards are in place in accordance with Chapter V of the GDPR. These safeguards may include Standard Contractual Clauses adopted by the European Commission, adequacy decisions, or other mechanisms recognised under applicable data protection law.
Data subjects have the right to obtain information about the specific safeguards in place for any such transfer by contacting the controller at the address provided in Section 10.
8. Your Rights Under GDPR
Under the GDPR, you have the following rights in relation to your personal data:
Right of access (Art. 15): You may request confirmation of whether personal data concerning you is being processed and, if so, access to that data and related information.
Right to rectification (Art. 16): You may request correction of inaccurate personal data and completion of incomplete data.
Right to erasure (Art. 17): You may request deletion of your personal data where the conditions of this right are met, including where the data is no longer necessary for the purposes for which it was collected.
Right to restriction of processing (Art. 18): You may request that processing of your data be restricted in certain circumstances.
Right to data portability (Art. 20): Where processing is based on consent or contract and carried out by automated means, you may request a copy of your data in a structured, commonly used, machine-readable format.
Right to object (Art. 21): You may object to processing based on legitimate interests, including for direct marketing purposes.
Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, contact the controller using the details in Section 10. You also have the right to lodge a complaint with the Polish supervisory authority, the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO), ul. Stawki 2, 00-193 Warsaw, Poland.
9. Cookies
This website uses cookies and similar tracking technologies. A cookie is a small text file placed on your device by the website. Cookies serve various purposes including ensuring the website functions correctly, understanding how it is used, and delivering relevant content.
The website uses a consent management mechanism that allows you to accept or decline non-essential cookie categories before they are placed on your device. Necessary cookies are placed without consent as they are required for the website to function. Non-essential cookies (analytics and marketing) are placed only where you have given explicit consent.
Full details of the cookies used, their purposes, and their retention periods are set out in the Cookie Policy.
10. Contact for Data Protection Matters
For any questions, requests, or concerns relating to the processing of your personal data or to exercise your rights under the GDPR, please contact:
NugEye
Walerego Sławka 3a
Kraków, Poland
Email: [email protected]
Telephone: +48 535 055 110
The controller will respond to requests within the timeframes required by applicable law, typically within one calendar month of receipt of the request. This period may be extended by up to two additional months where the request is complex or numerous, in which case the controller will inform you of the extension and the reasons for it.