1. Data Controller

The Data Controller is MINKBY PROSTA SPÓŁKA AKCYJNA with its registered office in Krakow (ul. Dworna 46A, 30-244 Krakow), KRS 0001141752, NIP 6772518906, REGON 540324121.

Contact: privacy@minkby.com (operational),jansteczko@minkby.com (formal). The company has not appointed a DPO – if needed, contact as above.

2. Scope and Purposes of Processing

a) B2B Contact and Sales – identification and contact data, correspondence content (Art. 6(1)(b)/(f) GDPR – contract/legitimate interest).

b) IT/Graphic Services Implementation – data of persons indicated by the Client, project data (Art. 6(1)(b)/(c)/(f) GDPR).

c) B2B Marketing – business email, phone, preferences (Art. 6(1)(f) GDPR; electronic communication in accordance with applicable law).

d) Recruitment – CV/portfolio, employment history (Art. 6(1)(a)/(c)/(b) GDPR; Labor Code – when applicable).

e) Analytics/UX – device data, server logs, online identifiers (Art. 6(1)(a) – consent for cookies/identifiers; necessary – Art. 6(1)(f)).

f) Waitlist Management – email addresses for ModuleStack early access notification (Art. 6(1)(a) GDPR – consent).

3. Categories of Recipients

Hosting/cloud providers, email and collaborative work providers, analytical/marketing automation tools, accounting, law firms, project subcontractors – based on data processing agreements (Art. 28 GDPR). Transfer outside the EEA – only with appropriate safeguards (SCC, Art. 46 GDPR).

4. Data Retention Period

Correspondence and inquiries: up to 12 months from case closure
Contract/settlement documentation: for the duration of the contract and for the time required by tax/accounting regulations and until the statute of limitations for claims
Recruitment: current – until completion; consent for future recruitment – max. 24 months
Marketing: until withdrawal of objection/consent
Waitlist data: until product launch and user notification, or withdrawal of consent

5. Rights of Data Subjects

Access, rectification, erasure, restriction, portability, objection, withdrawal of consent without affecting the lawfulness of processing based on consent before its withdrawal. Complaint to the President of UODO (uodo.gov.pl).

6. Obligation/Voluntary Nature of Data

Providing data required by contract/settlements is necessary for cooperation; other data – voluntary.

7. Automated Decisions/Profiling

We do not make fully automated decisions with legal effects; marketing profiling may occur based on consent (cookies/analytics).

8. Security

We apply technical and organizational measures appropriate to the risk (transmission encryption, access control, activity logging, password policies, backups, minimization).

9. Cookies and Similar Technologies

Detailed description in the Cookie Policy. Consents and obligations regarding cookies are regulated by applicable electronic communication laws.

10. Changes

The Policy may be updated – we will inform about changes on the website and via email (when appropriate).

Contact Information

For privacy inquiries, contact us at privacy@minkby.com orjansteczko@minkby.com

Privacy Policy