Reklamator

Privacy Policy

Version of 10 July 2026

This document has been prepared in accordance with Art. 13(1)–(2) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR). The binding version of this document is the Polish-language original.

1. Data controller

  1. The data controller is DNA01, Warsaw, ul. Jana Kochanowskiego 14/30, VAT ID: 8641610311.
  2. The controller has not appointed a Data Protection Officer. For all matters concerning the processing of personal data, contact us at rodo@dna01.pl.

2. Purposes of data collection

  1. Provision of services and performance of contracts — legal basis: Art. 6(1)(a) and (b) GDPR.
  2. Accounting and tax purposes — legal basis: Art. 6(1)(c) GDPR.
  3. Communication with the user — legal basis: Art. 6(1)(f) GDPR.
  4. Sending commercial information — legal basis: Art. 10 and Art. 18(4) of the Act on the provision of electronic services.

3. Scope of data collected

  1. First and last name.
  2. Contact details: email address, phone number.
  3. Location data (GPS) — only with the user's consent.
  4. Content of communications with the controller.
  5. Information about website visits collected via cookies.

4. How data is processed

  1. Notifying users of changes to the Terms and payment status.
  2. Responding to user enquiries and support requests.
  3. Managing the user's account profile.
  4. Conducting satisfaction surveys to improve service quality.

5. Whether providing data is required

  1. Providing contact details in the form is voluntary, but necessary for us to answer your enquiry. Without them we have no way to reach you.
  2. Providing data when entering into a contract is a contractual requirement — without it we cannot deliver the service.
  3. Providing data to the extent required by tax and accounting law is a statutory requirement.
  4. Consenting to analytics cookies is entirely voluntary. Refusing does not restrict your access to the site or any of its features in any way.

6. User rights

  1. The right to access personal data.
  2. The right to rectification of data.
  3. The right to erasure (the right to be forgotten).
  4. The right to restriction of processing.
  5. The right to data portability.
  6. The right to withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
  7. Requests to exercise the above rights should be sent to: rodo@dna01.pl.
  8. The right to lodge a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw, Poland).
  9. Your data is not used for automated decision-making or profiling.

7. Data retention period

  1. Data is retained until the agreement is terminated or until a deletion request is submitted.
  2. Obligations arising from applicable law (e.g. tax regulations) may require certain data to be retained for a longer period.

8. Recipients of personal data

  1. The provider of the server infrastructure hosting the site, the Matomo analytics system, and the consent register.
  2. The provider of the email service through which we conduct correspondence.
  3. Our accounting office and invoicing system provider — to the extent necessary to meet accounting and tax obligations.
  4. Bodies authorised under the law, in particular tax authorities, courts, and law enforcement — solely upon their request and to the extent they specify.
  5. Every processor acting on our behalf does so under a data processing agreement and strictly in line with our documented instructions.
  6. Analytics data collected by Matomo is not shared with any third party.

9. Cookies

  1. The site uses cookies to remember your consent preferences and — only with your consent — to analyse site traffic.
  2. Analytics is powered by Matomo, which we self-host on our own infrastructure within the European Economic Area. Analytics data is never shared with third parties.
  3. Until you give consent, Matomo collects nothing — it sends no request and stores no cookies.
  4. cc_cookie — a necessary cookie, stored for 182 days. It records your consent choices and your consent ID. No consent is required, because without it we could not remember your decision.
  5. _pk_id — a Matomo analytics cookie, stored for 13 months. It recognises returning visitors. Set only after you consent to the analytics category.
  6. _pk_ses — a Matomo analytics cookie, stored for 30 minutes. It maintains the current session. Set only after you consent to the analytics category.
  7. _pk_ref — a Matomo analytics cookie, stored for 6 months. It records the source that referred you to the site. Set only after you consent to the analytics category.
  8. You can change or withdraw your consent at any time by clicking “Cookie settings” in the site footer. Withdrawing consent is as easy as giving it and immediately deletes the cookies of the affected service.
  9. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.
  10. Independently of the above, you can manage cookies in your browser settings.

10. Consent register

  1. Every consent decision you make — granting, changing or withdrawing — is recorded as proof. The legal basis is Article 7(1) GDPR (the obligation to demonstrate consent) and Article 5(2) GDPR (accountability).
  2. We record: the consent ID assigned to your browser, the version of this policy, the categories and services you selected, the page language, your browser information (User-Agent), the page address without query parameters, a timestamp, and a hash of your IP address.
  3. The IP address is stored only as an irreversible cryptographic hash salted with a secret value. The raw IP address is never stored.
  4. Register entries are kept for 5 years from the last change to a given consent, after which they are deleted.
  5. The register is pseudonymous — it contains no data that lets us identify you directly. You can read your consent ID in the “Cookie settings” panel. By providing it, you can request access to your recorded consents or their deletion.

11. Third-party tools

  1. Matomo — website traffic analytics. Self-hosted on our own infrastructure, with no third parties involved. Requires your consent.
  2. We do not use Google Analytics, Google Tag Manager, or any advertising tools that set cookies.

12. Transfers outside the EEA

  1. We do not transfer personal data to third countries or to international organisations.
  2. Both the Matomo analytics system and the consent register run on infrastructure located within the European Economic Area.

13. DNA01 as a data processor

  1. In respect of data entrusted by Customers when using the Reklamator system, DNA01 acts as a data processor under a data processing agreement (DPA).
  2. Such data is processed solely for the purpose of providing the services and in accordance with the Customer's documented instructions.

14. Changes to this privacy policy

  1. This policy may change — in particular when the tools we use, the purposes of processing, or the applicable law change.
  2. Every version of the policy carries a date, shown below the document title.
  3. With every consent you give, we record the version of the policy in force at that moment. Previous versions are available on request — just write to rodo@dna01.pl.

15. Contact

  1. For matters related to personal data protection, please contact: rodo@dna01.pl.
  2. Phone: +48 507 058 755.