This Privacy Policy describes how Xikowu Vuyotu, operating at Wronia 31, Warszawa, Poland ("we", "us", "our"), collects, processes, and protects personal data in connection with the website xikowu-vuyotu.info and the educational programs available through it. We process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, commonly known as the General Data Protection Regulation (GDPR), as well as the Polish Act of 10 May 2018 on the Protection of Personal Data (Ustawa z dnia 10 maja 2018 r. o ochronie danych osobowych). Reading this document will help you understand what data we hold about you and how you can exercise your rights.
1. Who is the data controller
The controller of your personal data is Xikowu Vuyotu, with registered address at Wronia 31, Warszawa, Poland. You can contact us regarding data protection matters at [email protected] or by post at the address above. We do not have a designated Data Protection Officer, as our processing activities do not meet the thresholds requiring one under Article 37 of the GDPR, but all data-related enquiries are handled directly by our management.
2. What data we collect and why
We collect personal data in several contexts. When you use our contact form or send us an email, we collect your name, email address, phone number, and the content of your message. This data is processed on the basis of Article 6(1)(b) of the GDPR — processing necessary to take steps at your request prior to entering into a contract — or, where no contract is contemplated, on the basis of Article 6(1)(f), which is our legitimate interest in responding to correspondence directed to us.
When you enrol in one of our educational programs, we collect information necessary to provide access to that program. This includes contact details, payment information processed via our payment provider, and your progress data within the program. This processing is based on Article 6(1)(b) GDPR, as it is necessary for the performance of a contract with you.
We also collect technical data automatically when you visit our website. This includes your IP address, browser type, operating system, pages visited, and time spent on the site. This data is collected through cookies and similar technologies and is processed on the basis of your consent (Article 6(1)(a) GDPR) for analytics and marketing cookies, and on the basis of our legitimate interest (Article 6(1)(f) GDPR) for cookies strictly necessary for the operation of the website. You can manage cookie preferences at any time through the cookie consent tool on this site.
3. How long we keep your data
We retain contact enquiry data for a period of up to three years from the date of last contact, unless a longer retention period is required by law or by the nature of the relationship. Program access data is retained for the duration of your access and for a period of five years thereafter, in line with our obligations under Polish accounting law (Ustawa o rachunkowości). Technical and analytics data is retained in accordance with the settings of the tools we use, generally for a period not exceeding twenty-six months. After these periods, data is deleted or anonymised.
4. Who we share your data with
We do not sell your personal data. We share data only where necessary to deliver our services. This includes our hosting provider, our payment processing partner, and our email service provider. All third-party processors are bound by data processing agreements and are required to handle data in accordance with the GDPR. Where any processor is located outside the European Economic Area, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission. We may also disclose personal data if required to do so by Polish law or by a binding order of a competent authority.
5. Your rights under GDPR
As a data subject under the GDPR, you have a number of rights that you can exercise at any time. You have the right to access the personal data we hold about you (Article 15 GDPR). You have the right to request correction of inaccurate data (Article 16 GDPR). You have the right to request deletion of your data where it is no longer necessary for the purposes for which it was collected, subject to any legal retention obligations we have (Article 17 GDPR). You have the right to restrict processing in certain circumstances (Article 18 GDPR) and to receive your data in a portable format (Article 20 GDPR). Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
You also have the right to object to processing based on legitimate interests (Article 21 GDPR). To exercise any of these rights, please contact us at [email protected]. We will respond within one month of receiving your request, as required by Article 12(3) GDPR. If you believe your rights have not been respected, you have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO), ul. Stawki 2, 00-193 Warszawa, Poland.
6. Security measures
We take the security of your personal data seriously. Our website is served over HTTPS. Access to personal data is restricted to those team members who require it to perform their work. We use password management practices and access controls appropriate to the sensitivity of the data we hold. While no system is entirely immune from security risks, we take reasonable and proportionate measures to protect the data in our care.
7. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the services we offer. 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 the website after changes are published constitutes your acknowledgment of the updated policy.
For any questions about this Privacy Policy or our data practices, contact us at [email protected] or write to us at Wronia 31, Warszawa, Poland.