Privacy Policy

1. Personal Data Controller

The controller of personal data is:

TURBICONIX LIMITED LIABILITY COMPANY

Address: UL. OSTROBRAMSKA 101 / BIURO1, 04-041 WARSAW

Tax ID (NIP): 1133189497

E-mail: team@turbiconix.pl

2. Scope of Processed Data

When using the website, the following data may be processed:

• IP address (in anonymized form),
• data regarding device and browser,
• statistical data regarding how the site is used,
• cookies and similar technologies.

3. Purposes of Data Processing

Personal data is processed for the purpose of:

• conducting statistics and analyzing site traffic,
• improving site functionality and content,
• ensuring site security and proper operation.

4. Legal Basis for Processing

Personal data is processed based on:

• Article 6(1)(a) GDPR – user consent to process analytics data (Google Analytics).
• Article 6(1)(f) GDPR – legitimate interest of the controller (protection against abuse, reCAPTCHA).

Consent can be withdrawn at any time.

5. Google Analytics

The site uses Google Analytics 4, provided by Google LLC.

• IP address anonymization is applied,
• data is not used for advertising purposes,
• no data that directly identifies the user is collected.

6. Google reCAPTCHA

The site uses Google reCAPTCHA v3 to protect forms from spam and abuse. reCAPTCHA analyzes user behavior (interaction signals) to distinguish humans from bots.

Google LLC acts as a data processor and processes data on behalf of the controller.

Processing is based on the Google Cloud Data Processing Addendum, and any transfers outside the EEA rely on the EU–US Data Privacy Framework and/or Standard Contractual Clauses (SCC).

Data may include: IP address, device and browser information, and interaction signals.

7. Data Transfer Outside the EU

Data may be transferred to Google LLC (USA) in connection with Google Analytics and reCAPTCHA.

The transfer is based on:

• EU–US Data Privacy Framework or
• Standard Contractual Clauses (SCC).

8. Data Retention Period

Analytics data is retained for up to 14 months, according to Google Analytics settings.

9. User Rights

The user has the right to:

• access to data,
• rectification,
• erasure,
• restriction of processing,
• data portability,
• withdraw consent at any time,
• lodge a complaint with the President of the Office for Personal Data Protection (UODO).

10. Cookies

The site uses cookies:

• analytics (Google Analytics),
• essential for proper site operation.

You can manage cookies through browser settings or the consent panel.

11. Changes to Privacy Policy

The controller reserves the right to make changes to the Privacy Policy.