Privacy Policy

1. Who is the controller of your data

The controller of your personal data is APSTER spółka z ograniczoną odpowiedzialnością (APSTER sp. z o.o.), with its registered seat at ul. Cisowa 17, 70-896 Załom, Poland, entered in the register of entrepreneurs of the National Court Register (KRS) under number 0000447036 by the Sąd Rejonowy Szczecin-Centrum w Szczecinie, XIII Wydział Gospodarczy Krajowego Rejestru Sądowego, NIP 8522600861, REGON 321324518, share capital PLN 5,000.00.

We have not appointed a data protection officer. In every matter concerning your personal data write to biuro@apster.net or to the postal address above.

2. What data we process

Data you give us yourself in the contact form:

• name
• email address
• company name (optional)
• phone number (optional)
• the type of help requested and the optional budget range
• the content of your message — please do not send us special categories of data

Data our server records on its own:

• your IP address, held for a few minutes to rate-limit the form and block automated abuse;
• standard web server logs kept by our hosting provider (IP address, time, requested address, browser identification), used for security and diagnostics.

3. Why we process it, and on what legal basis

• To answer your inquiry and discuss possible cooperation — art. 6(1)(b) GDPR (steps taken at your request before entering into a contract) and, where your message concerns someone else's business rather than your own, art. 6(1)(f) GDPR, our legitimate interest in responding to business correspondence.
• Because you ticked the consent box — art. 6(1)(a) GDPR, to the extent the processing goes beyond the two grounds above. You may withdraw this consent at any time, which does not affect the lawfulness of processing carried out before the withdrawal.
• To keep the website secure and prevent abuse of the form — art. 6(1)(f) GDPR, our legitimate interest in the integrity and availability of the service.
• To establish, exercise or defend legal claims, and to meet accounting duties if cooperation actually starts — art. 6(1)(f) and art. 6(1)(c) GDPR in connection with Polish tax and accounting law.

Providing the data is voluntary, but without a name, an email address and a message we cannot reply to you.

4. How long we keep it

• Inquiries that do not lead to cooperation: up to 12 months from the last exchange of messages, after which they are deleted.
• Inquiries that lead to a contract: for the duration of the cooperation and then for the limitation period for claims, and for 5 years from the end of the tax year for documents covered by accounting obligations.
• Rate-limiting data: minutes — it is discarded when the time window expires.
• Server logs: for the retention period applied by our hosting provider.
• Data processed on the basis of your consent: until you withdraw it, unless another ground above applies.

5. Who receives your data

We do not sell personal data, we do not share it for advertising, and we do not use it to build profiles. Your data may be entrusted to the providers we need in order to operate:

• Hosting — cyber_Folks S.A., ul. Wierzbięcice 1B, 61-569 Poznań, Poland (the zenbox.pl service), which stores the website and delivers the inquiry email. It processes the data on our documented instructions under a data processing agreement.
• Public authorities, where we are obliged to disclose data under generally applicable law.

6. Transfers outside the European Economic Area

We do not transfer your data outside the European Economic Area. Should that change — for example if we start using an email delivery provider based outside the EEA — we will update this policy and rely on the Standard Contractual Clauses adopted by the European Commission or another mechanism permitted by Chapter V of the GDPR.

7. Your rights

Under the GDPR you have the right to:

• access your data and obtain a copy of it (art. 15);
• have inaccurate data corrected (art. 16);
• have your data erased (art. 17);
• restrict processing (art. 18);
• receive the data you provided in a structured, machine-readable format and have it transmitted to another controller (art. 20);
• object to processing based on our legitimate interest, on grounds relating to your particular situation (art. 21);
• withdraw your consent at any time, where processing is based on consent (art. 7(3)).

To exercise any of them, write to biuro@apster.net. You also have the right to lodge a complaint with the supervisory authority: the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warszawa, Poland.

8. Automated decision-making

We do not make decisions about you by automated means and we do not profile you. The only automated step is the rate limit that decides whether a request to the contact form is accepted, which produces no legal effects for you.

9. Cookies and analytics

apster.net uses no advertising, profiling or analytics cookies and loads no third-party scripts. See our cookie information for details.

10. Changes to this policy

If we change how we process personal data, we will update this page and the date shown above. The current version always applies to data processed from the moment it is published.