Privacy Policy

Controller Identity and Contact

The controller of your personal data within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation, hereinafter "GDPR") and the Polish Act of 10 May 2018 on the Protection of Personal Data (Dz.U. 2018 poz. 1000, as amended) is the operator of the Vafihe Munuro mentoring program, with a registered place of business at Zaolziańska 8/lok. 5, Wrocław, Poland.

You may contact the data controller regarding any matter related to the processing of your personal data by writing to: [email protected] or by post to the address above. We aim to respond to data-related enquiries within 30 days of receipt.

Scope of Personal Data Collected

We collect personal data that you voluntarily provide to us when using this website. This includes:

• Identification data: full name, as provided through our contact form.
• Contact data: email address, as provided through our contact or newsletter forms.
• Communication data: the content of messages sent through our contact form, including any personal information you choose to include in the body of your message.
• Technical data: IP address, browser type, device type, pages visited, time and date of visit, and referral source, collected automatically through server logs and, where consent is given, through analytics tools.
• Cookie data: as described in our Cookie Policy, available at cookies.html.

We do not collect special categories of personal data as defined in Article 9 of the GDPR (such as health data, racial or ethnic origin, or political opinions) and we request that you do not submit such data through our forms.

Legal Bases and Purposes of Processing

We process your personal data on the following legal bases as set out in Article 6 of the GDPR:

• Article 6(1)(a) GDPR — Consent: We process your email address for the purpose of sending our newsletter where you have expressly subscribed and provided consent. You may withdraw this consent at any time by contacting us at [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
• Article 6(1)(b) GDPR — Performance of a pre-contractual or contractual obligation: Where you engage with us regarding the mentoring program and we enter into any form of service arrangement, processing of your data may be necessary to fulfill that arrangement.
• Article 6(1)(f) GDPR — Legitimate interests: We process technical data (server logs) on the basis of our legitimate interest in operating and maintaining the security of this website. This processing is proportionate and does not override your fundamental rights and freedoms.
• Article 6(1)(c) GDPR — Legal obligation: We may process your data to the extent necessary to comply with applicable Polish and EU law, including accounting, tax, and archiving obligations.

Retention Periods

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to any legal obligations that require longer retention:

• Contact form data (name, email, message content): retained for up to 24 months from the date of last communication, unless a longer retention period is required by law or by the nature of the service relationship.
• Newsletter subscriber data: retained for as long as you remain subscribed, and for a period of up to 12 months after unsubscription for archival and suppression list purposes.
• Server log data: retained for up to 12 months from the date of collection, in line with standard security and audit practices.
• Accounting and tax records: retained for 5 years from the end of the financial year to which they relate, as required under Polish accounting law (Ustawa o rachunkowości of 29 September 1994).

Recipients and Transfers of Personal Data

We do not sell your personal data to third parties. We may share your data with the following categories of recipients to the extent necessary to operate our services:

• Email and hosting service providers acting as processors under data processing agreements compliant with Article 28 of the GDPR.
• Analytics service providers where consent has been given for analytics cookies.
• Public authorities and law enforcement bodies where we are legally required to disclose data.

Where any transfer of personal data to a country outside the European Economic Area (EEA) occurs, such transfer is made only where adequate safeguards exist as described in Chapter V of the GDPR, including Standard Contractual Clauses approved by the European Commission.

Your Rights Under GDPR

Under the GDPR and applicable Polish data protection law, you have the following rights regarding your personal data:

• Right of access (Article 15 GDPR): You have the right to obtain confirmation of whether we process your personal data and, if so, to access that data and information about how it is processed.
• Right to rectification (Article 16 GDPR): You have the right to have inaccurate personal data corrected without undue delay.
• Right to erasure (Article 17 GDPR): You have the right to request the deletion of your personal data where one of the grounds listed in Article 17(1) applies, subject to the exceptions in Article 17(3).
• Right to restriction of processing (Article 18 GDPR): You have the right to request that we restrict processing of your data in certain circumstances.
• Right to data portability (Article 20 GDPR): Where processing is based on consent or contract and carried out by automated means, you have the right to receive your data in a structured, commonly used, machine-readable format.
• Right to object (Article 21 GDPR): You have the right to object to processing based on legitimate interests at any time. Where processing is for direct marketing purposes, you have an absolute right to object.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. If you are not satisfied with our response, 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, www.uodo.gov.pl.

Cookies and Tracking Technologies

This website uses cookies and similar tracking technologies. Essential cookies are necessary for the website to function and are placed without requiring consent. Non-essential cookies (including analytics and marketing cookies) are placed only with your prior consent, which you provide through our cookie consent mechanism. Full details of the cookies used, their purpose, and duration are set out in our Cookie Policy at cookies.html.

Security of Personal Data

We implement appropriate technical and organizational measures as required by Article 32 of the GDPR to protect personal data against unauthorized access, accidental loss, destruction, or alteration. These measures include encrypted communications (HTTPS), access controls, and regular review of our data security practices. No transmission over the internet is entirely secure; however, we take reasonable steps to protect your information.

Automated Decision-Making and Profiling

We do not engage in automated decision-making or profiling as defined in Article 22 of the GDPR that would produce legal effects or similarly significant effects on individuals.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. The date of the most recent revision is shown at the top of this document. We encourage you to review this policy periodically. Where changes are material, we will take reasonable steps to notify you.

This Privacy Policy was last updated on 22 July 2026.