Privacy Policy

Introduction

We care about your privacy. We collect and process your data only when it is necessary for the proper provision of our services. You can contact us by email at lc.albion@gmail.com or by phone at +48 574 065 884.

In accordance with the GDPR, below we present the data processing rules applied by the Data Controller.

I. Who is the Data Controller?

The Data Controller is Lc Albion Olena Kiriushkina (NIP: 1251785312, REGON: 541427716), registered at ul. Kruczej, Warsaw, 00-526 Poland.

II. Why do we collect your data, and for how long do we process it?

We may process your data for the following purposes:

Communication with you

Including answering questions submitted through the contact form, email, or during online meetings. Data will be processed based on the Controller’s legitimate interest in communicating with Website users (Art. 6(1)(f) GDPR). Your data will be processed no longer than until you object or the business purpose ceases to apply. Providing this data is voluntary but necessary for communication. Data may also be processed for internal archiving purposes based on the Controller’s legitimate interest (Art. 6(1)(f) GDPR) until objection or cessation of the business purpose.

Entering into and performing a contract

Concluding and performing a contract (placing an order); establishing, defending against, and pursuing claims; fulfilling legal obligations of the Controller (including tax and archiving obligations).

Data necessary to conclude and perform the contract will be processed for the duration of the contract, including the exercise of rights arising from it, such as warranty claims (Art. 6(1)(b) and (f) GDPR). Providing this data is voluntary but necessary for concluding and performing the contract.

Additional data provided to improve contract performance will be processed no longer than until you object or the business purpose ceases, based on the legitimate interest of customer service (Art. 6(1)(f) GDPR).

After this period, data will be processed for the statute-of-limitations period based on the Controller’s legitimate interest in defending against claims and establishing and pursuing claims (Art. 6(1)(f) GDPR).

Where data is necessary to fulfill the Controller’s legal obligations (e.g. issuing and storing invoices), the data will be processed for this purpose for no longer than 6 years (accounting archiving obligations), unless the law requires a longer period (Art. 6(1)(c) GDPR).

Data may also be archived for internal and statistical purposes until you object or the business purpose ceases, based on the Controller’s legitimate interest (Art. 6(1)(f) GDPR).

Marketing and commercial information

Providing marketing/commercial information (hereinafter “Marketing Information”), including sending newsletters and information about services, products, promotions, and free content via other tools (e.g. SMS, phone).

Data will be processed based on the Controller’s legitimate interest in marketing its products and services (Art. 6(1)(f) GDPR). Under Article 398 of the Electronic Communications Law, your consent is required to maintain commercial/marketing communication. You may withdraw it at any time:

• by clicking the link in the email footer or writing to us at lc.albion@gmail.com — for email communication,
• by contacting us directly at +48 574 065 884 or lc.albion@gmail.com — for consent given to receive commercial/marketing content via phone call and/or SMS.

Providing this data is voluntary but necessary to receive Marketing Information. Opting out of Marketing Information means we will no longer be able to send it to you.

Data processed in connection with your consent to receive Marketing Information, including data collected automatically (e.g. IP address), will also be processed based on the Controller’s legitimate interest (Art. 6(1)(f) GDPR) in analyzing behavior to optimize marketing activities. Data will be processed for analytical and statistical purposes.

Your data may also be archived for the purpose of establishing, pursuing, or defending against claims, including demonstrating that marketing activities were conducted lawfully, based on Art. 6(1)(f) GDPR.

Data processed under Art. 6(1)(f) GDPR will be processed no longer than until you object or the business purpose ceases, whichever occurs first.

Social media platforms

Administering and managing the page and groups on social media platforms (including Meta, Instagram) where data is processed on social platforms, including communicating with you and directing marketing content to you.

This data will only be processed if you choose to like the page / join the group / select “Follow,” or otherwise leave your data on a platform we manage, e.g. by posting or commenting. Data will be processed for the duration of the page/group’s existence or until you object, which may occur by unliking, unfollowing, deleting a comment/post, or in another way provided by the platform, or by contacting us directly.

Rules relating to the page/fan page/group are set by the Controller, while the rules for using the social media platform on which the page/fan page/group is hosted are set by the entity managing that platform.

Comments

Data visible on our Website alongside a posted comment is processed by us to administer and operate the Website and to communicate with you, based on the Controller’s legitimate interest (Art. 6(1)(f)) for as long as necessary to achieve business purposes or until objection.

Sensitive data

Sensitive data is collected to perform and properly execute the contract, based on your informed and voluntary consent (Art. 9(2)(a) GDPR), until the business purpose ceases or consent is withdrawn. Providing this data is voluntary but necessary for the proper performance of the contract (e.g. information about your language level).

III. Who may we share your data with?

We only share your data with other entities when necessary to achieve the processing purposes described in Section II.

Where necessary, your data may be shared with entities we cooperate with to achieve the above purposes: hosting providers, IT companies/website administrators, accounting service providers, invoicing software providers, school management (CRM) software providers, newsletter service providers, cloud service providers, advertising agencies, virtual assistants, subcontractors, lawyers, couriers or postal operators, training platforms, customer service platforms, and other entities that support us in achieving processing purposes.

As a rule, data will not be transferred outside the EEA. If it is transferred outside the EEA, this will occur based on your consent, standard contractual clauses, or other safeguards provided by the GDPR, after fulfilling the relevant information obligations. Your data may be transferred to:

• Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
• HubSpot, 25 First Street, 2nd Floor, Cambridge, MA 02141, USA
• Dropbox International Unlimited Company, One Park Place, Floor 5, Upper Hatch Street, Dublin
• Canva, 110 Kippax St, Level 1, Surry Hills, NSW 2010, Australia

IV. What rights do you have?

Under the GDPR, you have the right to:

• access your personal data,
• rectify your personal data,
• erase your personal data,
• restrict the processing of your personal data,
• object to the processing of your personal data,
• data portability,
• withdraw consent; withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

If you believe your personal data is being processed unlawfully, you have the right to lodge a complaint with the President of the Personal Data Protection Office. In such a case, we encourage you to first contact us to clarify any concerns.

V. Applicable law regarding personal data

In matters not regulated herein, the relevant provisions of law apply, including European law, in particular the GDPR.

VI. Cookie Policy

The Controller uses technologies that track the actions of Users on the Website:

• Facebook (Meta) conversion pixel — to manage ads on Meta and conduct remarketing activities;
• Google Analytics code — to analyze Website statistics;
• Google LLC;
• Vimeo Inc.;
• TikTok FTechnology Limited.

Google Analytics uses its own cookies to analyze the actions and behavior of Website Users. These files store information such as which page a User arrived from. They help improve the Website.

The Website does not automatically collect any information except that contained in cookies.

Cookies are IT data, in particular text files, stored on the User’s end device and intended for use of the Website. Cookies usually contain the name of the website they originate from, their storage time on the end device, and a unique number.

Cookies are used to adapt the Website’s content to User preferences and optimize use of the Website; and to create statistics that help understand how Users use the Website, allowing us to improve its structure and content.

You can change your cookie settings yourself. In many cases, web browsers allow the storage of cookies on the User’s end device by default. Detailed information on managing cookies is available in your browser’s settings.

Refusing to consent to cookies may limit the functionality of certain features on the Website.

VII. Social media plugins

The Website uses plugins and other social tools provided by platforms such as Facebook, Google, Instagram, TikTok, and LinkedIn. The rules regarding personal data processing are described directly on the websites of these social media service providers.

VIII. Joint controllership

The controller of data processed for statistics collected within the Facebook (Meta) platform is Lc Albion Olena Kiriushkina, hereinafter the Controller, and Meta Platforms Ireland Limited, registered at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, hereinafter the Joint Controller. This data is processed based on joint controllership by the above entities. Detailed rules on joint controllership, including information about applicable rights, are described on the Page Insights information page.

The Controller processes data based on its legitimate interest in analyzing User activity and preferences in order to improve the functionalities and services provided. For matters relating to personal data, you may contact either the Controller or the Joint Controller.

Information Clause

In fulfillment of the information obligation arising from the Act on Providing Services by Electronic Means, the Act of 30 May 2014 on Consumer Rights, and GDPR provisions, below we provide the most important information.

Information obligation under the GDPR

The Data Controller is Lc Albion Olena Kiriushkina (NIP: 1251785312, REGON: 541427716), registered at ul. Kruczej 16/22, Warsaw, 00-526 Poland, hereinafter the Organizer. You may contact the Organizer by email at lc.albion@gmail.com or by phone at +48 574 065 884.

Your data will be processed:

• to conclude and perform the contract (Art. 6(1)(b) GDPR); where additional data is provided that may improve contract performance, processing will be based on the Controller’s legitimate interest until the business purpose ceases or objection is raised (Art. 6(1)(f) GDPR);
• to fulfill a legal obligation on the Controller (Art. 6(1)(c) GDPR), including tax and accounting regulations and the Act of 13 May 2016 on Counteracting Sexual Offence Threats and Protecting Minors, in connection with maintaining documentation related to activities aimed at protecting minors — including receiving reports of incidents endangering a minor and providing support, and documenting and storing disclosed or reported incidents endangering a minor’s welfare. These child-protection activities are also carried out for reasons of important public interest under Art. 9(2)(b) GDPR;
• to pursue the Controller’s legitimate interest (including establishing or pursuing claims/defending against claims/marketing the company’s services, products, and reviews) — until the claims become statute-barred, the business purpose ceases, or objection is raised.

To achieve the above purposes, data may be entrusted to, among others: a hosting company, an accounting services provider, instructors, a customer service platform, couriers, postal offices, and a lawyer.

You have the right to request access to your personal data, rectification, erasure, or restriction of processing, and to object to processing, as well as the right to data portability and the right to lodge a complaint with the supervisory authority. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before its withdrawal. To the extent that data processing is necessary to conclude and perform the contract, fulfill legal obligations, or establish/pursue/defend against claims, providing the data is voluntary, but may prevent the conclusion of the contract (this does not apply to optional data).

Information obligation under the Act on Providing Services by Electronic Means and the Act on Consumer Rights

The public nature of the Internet and the use of electronic services may involve the risk of unauthorized access to or modification of data, so appropriate technical measures should be used to minimize these risks, in particular antivirus software and identity-protection tools. The Organizer will never ask you to disclose your Password in any form. Providing content of an unlawful nature is prohibited within the scope of the services provided. Complaints regarding electronically provided services may be directed to the Organizer.

We inform you that in the case of a distance contract or a contract concluded away from the Organizer’s premises, a Customer who is a consumer or an entrepreneur with consumer rights within the meaning of Article 385⁵ of the Civil Code has the statutory right to withdraw from the contract without giving a reason within 14 days of concluding the contract, subject to the exceptions below. To exercise the right of withdrawal, the Customer must inform us, e.g. by email or letter to the Organizer’s address (template: “I withdraw from the contract dated …”). To meet the deadline, it is sufficient to send the withdrawal notice before it expires.

The Customer does not have the statutory right to withdraw if the Organizer has fully performed the service, or has begun providing a service involving the delivery of digital content with the Customer’s explicit and prior consent, having been informed before the service began that they would lose the right of withdrawal once the service was performed, and acknowledged this. In the case of digital content services, the Organizer provides the Customer with confirmation of receipt of consent.

In the event of withdrawal from the Contract, all payments received from the Customer will be refunded promptly, no later than 14 days from the day the Organizer was informed of the withdrawal. The refund will be made using the same payment method used in the original transaction, unless the Customer expressly agrees to a different solution; the Customer will not incur any fees in connection with the refund.

The Customer may apply to a permanent amicable consumer court to resolve a dispute arising from the contract, to the regional inspector of the Trade Inspection to request mediation proceedings, to the district (municipal) consumer rights ombudsman, or to a social organization whose statutory tasks include consumer protection, and obtain assistance regarding the contract, or may use the ODR platform (http://ec.europa.eu/consumers/odr).