Privacy and Cookie Policy

Effective from: 21 October 2026

1. Data controller

The controller of your personal data is KSWS Investment sp. z o.o., ul. Nowomiejska 40, 44-251 Rybnik, Poland, entered in the Register of Entrepreneurs of the National Court Register (KRS) under number 0001182645, tax ID (NIP) 6423262934, REGON 542209944, operating under the DataClarity brand (“DataClarity” or “we”).

For any matters concerning personal data, you can contact us by email at kontakt@dataclarity.pl or by post at our registered office address. We have not appointed a Data Protection Officer.

2. What data we process, why, and on what legal basis

2.1. Contact form and email correspondence

• Data: your name, email address, the subject and content of your message, and any other information you include in it.
• Purpose: replying to your enquiry, preparing an offer and further correspondence.
• Legal basis: our legitimate interest in responding to enquiries and communicating with clients (Art. 6(1)(f) GDPR) and, where your enquiry concerns entering into a contract, steps taken at your request prior to entering into a contract (Art. 6(1)(b) GDPR).

Providing your data is voluntary, but without your name, email address and message we cannot reply. Messages from the form are sent through Amazon Web Services (servers in Frankfurt, Germany) directly to our email inbox. We do not store them in a website database.

2.2. Measuring Google Ads performance (only with your consent)

If you accept cookies in the banner, we use Google Ads (loaded via Google Tag Manager) to measure whether our ads lead to contact with us, for example a contact form submission, and to tailor ads to people who have visited our website (remarketing).

• Legal basis: your consent (Art. 6(1)(a) GDPR and Art. 399 of the Polish Electronic Communications Law).
• Withdrawing consent: at any time via the “Cookie settings” link in the page footer. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

If you do not consent, Google does not set advertising cookies. We use Google Consent Mode, in which Google may then receive only basic cookieless signals without advertising identifiers (e.g. that a visit took place), used in aggregated form to estimate ad performance.

2.3. Displaying the website and security

When you use the website, technical data such as your IP address, browser type and the address of the page you visit is processed automatically. This is necessary to display the website and keep it secure, which is our legitimate interest (Art. 6(1)(f) GDPR). This data is processed by our hosting provider (section 4) and by providers of external resources (section 5).

3. Cookies

Cookies are small files stored in your browser. Essential cookies are always active because the website cannot work properly without them. We only set advertising cookies after you give consent in the banner.

Once you consent, Google may also set its own cookies on its domains (e.g. google.com, doubleclick.net). Google explains this here: how Google uses cookies in advertising.

You can change your decision at any time via the “Cookie settings” link in the page footer. You can also delete or block cookies in your browser settings.

4. Who we share data with

We use trusted providers that process data on our behalf under data processing agreements:

• Amazon Web Services EMEA SARL (Luxembourg): website hosting and delivery of contact form messages (servers in the European Union, Frankfurt).
• Google Ireland Limited (Ireland): Google Workspace email, where messages are delivered, and, with your consent, Google Ads and Google Tag Manager.

Data may also be disclosed to public authorities where required by law.

The parent companies of Google and Amazon are based in the USA, so data may be transferred outside the European Economic Area. Such transfers are based on the European Commission's adequacy decision under the EU-US Data Privacy Framework and on standard contractual clauses approved by the European Commission.

5. External resources loaded by the website

To display the website, your browser downloads some elements from external providers' servers and shares your IP address with them:

• fonts: Google Fonts (Google),
• scripts: cdn.tailwindcss.com and cdnjs.cloudflare.com (Cloudflare),
• language flag icons: flagcdn.com,
• client reviews widget: Clutch.co (home page only).

6. How long we keep data

• Contact form and email correspondence: up to 12 months after the last contact and, if we start working together, for the duration of the cooperation and until any claims become time-barred.
• Technical logs of the contact form: 30 days. They do not contain message content.
• Cookies: for the periods listed in the table in section 3.
• Data processed based on consent: until consent is withdrawn.

7. Your rights

You have the right to:

• access your data and obtain a copy,
• rectify your data,
• have your data erased,
• restrict processing,
• data portability,
• object to processing based on our legitimate interest,
• withdraw your consent at any time,
• lodge a complaint with the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, Poland, uodo.gov.pl.

To exercise your rights, email us at kontakt@dataclarity.pl. We do not make decisions based solely on automated processing that would produce legal effects concerning you.

8. Changes to this policy

We update this policy when the tools we use or the law change. The current version is always available on this page, and the date at the top shows when it took effect.