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Privacy Policy

Website: efineo.com
Data Controller: Jakub Makurat, operating under the business name Jakub Makurat Efineo
Business address: ul. Polska 39, 81-595 Gdynia, Pomeranian Voivodeship, Poland
Tax ID (NIP) / REGON: 5860201901 / 221489866
Contact: [email protected]
Version: 18 September 2026

1. Data Controller

The controller of personal data processed in connection with the use of this Website is Jakub Makurat, operating under the business name Jakub Makurat Efineo, with its business address at ul. Polska 39, 81-595 Gdynia, Pomeranian Voivodeship, Poland, Tax ID: 5860201901, REGON: 221489866.

For any privacy and data protection matters, please contact us at [email protected]. We have not appointed a Data Protection Officer.

This Policy explains what data we collect, why we process it, the legal basis for doing so, how long we keep it, and your rights regarding your personal data.

2. Data Categories

  • Contact and identification data: first name and last name, work email address, company name, phone number if you choose to provide it.
  • Enquiry data: the topic you select, the content of your message, and any information you decide to include in it.
  • Newsletter data: email address, chosen briefing language, subscription and unsubscription dates, and consent history.
  • Technical data: IP address, the page an enquiry was sent from, the website you arrived from, campaign parameters in the address (utm_source, utm_medium, utm_campaign, utm_content, utm_term), event identifier, interface language, and server logs.

We do not ask for special category data and we do not process payment data through this Website.

3. Purposes, Legal Bases and Retention Periods

PurposeData scopeLegal basisRetention period
Handling enquiries sent through the contact formContact data, enquiry data, technical dataArt. 6(1)(f) GDPR (legitimate interest in responding to enquiries); Art. 6(1)(b) GDPR where the enquiry concerns a possible engagementUntil the correspondence ends, and no longer than 2 years from the last contact, unless another basis applies.
Sending the Efineo Briefing newsletterEmail address, language, consent historyArt. 6(1)(a) GDPR (consent)Until consent is withdrawn, and afterwards for the period needed to demonstrate accountability.
Website security, availability and performanceTechnical data, server logsArt. 6(1)(f) GDPR (legitimate interest in running the Website securely)For the duration of the log retention period at our hosting provider and content delivery network.
Establishing and defending claimsData related to the caseArt. 6(1)(f) GDPRUntil the statutory limitation period for claims expires.

4. Data Recipients

Your data may be shared with entities that provide us with technical and organisational support: our hosting provider, our email provider, the content delivery network protecting the Website, the agency maintaining the Website, and, where applicable, accounting and legal advisers. Data may also be disclosed to public authorities where the law requires it.

Enquiries sent through the contact form are stored in the Website database and forwarded to our email address. Newsletter subscriptions are stored in the mailing system installed on this Website.

5. Data Transfers Outside the EEA

The content delivery network we use to protect and speed up the Website may process technical data outside the European Economic Area. Such transfers are based on the legal mechanisms required by the GDPR, in particular Standard Contractual Clauses or an adequacy decision.

6. Cookies, Analytics and Marketing

This Website does not currently set any cookies. We do not run analytics or marketing tools on it at this time and we do not build advertising audiences. The only information kept on your device is a single browser session-storage entry remembering whether you collapsed the announcement bar; it is deleted when you close the tab and is never sent to us. Details are set out in the Cookie Policy.

Should analytics or marketing tools be introduced, they will only run after you give the appropriate consent, and this Policy together with the Cookie Policy will be updated beforehand.

We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.

7. Your Rights

  • Right to access your data
  • Right to rectify your data
  • Right to erase your data (right to be forgotten)
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing based on legitimate interest
  • Right to withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal
  • Right to lodge a complaint with the President of the Personal Data Protection Office (PUODO) in Poland

To exercise your rights, please contact us at [email protected].

8. Voluntary Provision of Data

Providing your data is voluntary, but it may be necessary to handle your enquiry or to subscribe to the newsletter. If the information required in a form is not provided, we may be unable to respond.

Please avoid sending confidential information, trade secrets or special category data through our forms unless it has been agreed in advance.

9. Data Security

We apply technical and organisational measures proportionate to the risk: restricted access to the administration panel and to the data, encrypted transmission (SSL/TLS), regular backups, and cooperation with professional service providers.

10. Changes to this Policy

This Policy may be updated to reflect changes in the law or in how the Website works, including new tools, forms or functionalities. The current version is always available on the Website.