Privacy Policy
Last updated: 21 July 2026
This policy describes what data implse.eu collects, why, and on what legal basis. It is written to meet the requirements of Regulation (EU) 2016/679 (GDPR).
Data controller: Oleg Afanasenko, Warsaw, Poland.
Contact for any data-related question: implseteam@gmail.com.
No Data Protection Officer has been appointed: the scale and nature of our processing does not meet the criteria of Art. 37 GDPR.
1. What data we collect
Data you provide yourself — in the request form:
- name;
- email;
- Telegram or phone;
- business area;
- message text.
Data collected automatically — only if you consent via the cookie banner: an anonymous visitor identifier, pages and events on the site, referral source, device and browser type, country and city derived from IP (the IP address is truncated — anonymize_ip is enabled).
We do not collect special categories of data (Art. 9 GDPR) and do not knowingly process data of minors.
2. Purposes and legal bases
| Purpose | Legal basis | Retention |
|---|---|---|
| Responding to your request, preparing a proposal | Art. 6(1)(b) — steps taken at your request prior to entering a contract | 24 months from last contact |
| Performance of a contract and accounting | Art. 6(1)(b) and 6(1)(c) — obligations under Polish law | 5 years after the end of the tax year |
| Website analytics (Google Analytics 4) | Art. 6(1)(a) — your consent | 14 months |
| Advertising audiences (Meta Pixel) | Art. 6(1)(a) — your consent | up to 180 days |
We do not sell your data and do not pass it to third parties for their own marketing.
3. Who receives the data
We use external services. They act as processors on our instructions:
- Formspree Inc. (USA) — receiving and forwarding form submissions. Transfers outside the EEA are based on the EU Standard Contractual Clauses (SCC).
- Cloudflare, Inc. (USA) — website hosting and protection. SCC.
- Google Ireland Ltd. — Google Analytics 4. Only with your consent.
- Meta Platforms Ireland Ltd. — Meta Pixel. Only with your consent.
- Google LLC — the corporate mailbox that receives submissions.
4. Your rights
Under the GDPR you have the right to access your data (Art. 15), rectify it (16), erase it (17), restrict processing (18), receive it in a machine-readable format (20), object to processing (21), and withdraw consent at any time (7(3)).
To exercise any of these rights, write to implseteam@gmail.com. We respond within 30 days.
If you believe we have infringed your rights, you may lodge a complaint with a supervisory authority. In Poland this is the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl.
5. Cookies
Essential — they remember your consent choice. Always set; the site does not work without them. Basis: Art. 6(1)(f), legitimate interest.
Analytics and advertising — Google Analytics 4 and Meta Pixel. Loaded only after your explicit consent in the banner on first visit. Before consent, Google Consent Mode v2 runs in denied state: the scripts set no cookies and send no data.
You can change or withdraw consent at any time — the “Cookie settings” link in the footer of every page. Withdrawal does not affect the lawfulness of processing carried out before it.
6. Is providing data mandatory
Filling in the form is voluntary. But without a name and a way to reach you we cannot respond. Consent to analytics is entirely optional and does not affect access to the site.
7. Automated decision-making
We do not take decisions about you based solely on automated processing and do not carry out profiling within the meaning of Art. 22 GDPR.
8. Changes to this policy
We may update this policy. The current version is always available on this page; the update date is shown at the top.