DRAFT – pending legal review. This text is a working draft and is not yet legally binding. Items in [brackets] must be completed before launch.

Privacy Policy

Last updated: [date]. Version 0.1 (draft).

1. Controller

Virtumedia sp. z o.o., [registered address: PENDING], [NIP: PENDING], [KRS: PENDING], contact via our contact form, is the controller for personal data processed through this website.

2. What we process and why

Orders: name, email, country, order details. Our Merchant of Record [Paddle / Lemon Squeezy] processes payment data as an independent controller. We receive order details to deliver the product and provide support. Legal basis: performance of a contract (Art. 6(1)(b) GDPR) and legal obligations such as tax records (Art. 6(1)(c)).
Email list and free downloads (only with consent): email address, optional first name, which free calculator you asked for, and whether you open or click our emails. We use it to send the free download and our emails with tips and offers, through [email provider]. Legal basis: consent (Art. 6(1)(a) GDPR). Every email has an unsubscribe link, and you can withdraw consent at any time. [Legal review: confirm provider, tracking and double opt-in.]
Contact form and support emails: your name, email address and message, stored securely with our hosting provider Cloudflare so we can answer you. Legal basis: contract or legitimate interest (Art. 6(1)(b)/(f)).
Analytics (only with consent): if you accept analytics cookies, we use Google Analytics 4 to understand site usage in aggregate. Legal basis: consent (Art. 6(1)(a)). You can withdraw it at any time. Without consent, no analytics cookies are set.
Hosting and security: Cloudflare serves this website and processes technical data such as IP address and request logs for security and delivery. Legal basis: legitimate interest (Art. 6(1)(f)).

3. Recipients and transfers

Processors and partners: Cloudflare, Inc.; [Paddle / Lemon Squeezy]; Google Ireland Ltd (analytics, only with consent); [email provider]. Some are located outside the EEA. Transfers rely on the EU-US Data Privacy Framework or Standard Contractual Clauses. [Legal review: confirm the list of providers.]

4. Retention

Order and invoice data: as long as tax law requires ([e.g. 5 years]). Support emails: up to [24 months] after the matter is closed. Analytics: [14 months].

5. Your rights

You have the right of access, rectification, erasure, restriction, data portability and objection, and the right to withdraw consent. You can also complain to a supervisory authority (in Poland: Prezes UODO, uodo.gov.pl) or to the authority where you live. Contact: our contact form.

6. Cookies

This site uses no cookies of its own. Checkout pop-ups from our payment partner may set cookies that are strictly needed for payment. Analytics cookies are set only after you consent.