Privacy Policy

Privacy Policy

DEFINITIONS

Data Controller - Łukasz Brzyski, sole trader operating under the business name “Łukasz Brzyski Trustart”, fixed place of business: 30-383 Kraków, ul. Wandejska 9, Tax ID (NIP) 6782864550, Business Registry No. (REGON) 386775495, e-mail address: contact@brzyski.com, who is at the same time the Administrator of the website “Brzyski & Partners Management Consulting”. GDPR - the Personal Data Protection Act of 30 August 2019 (Journal of Laws 2019, item 1781, as amended) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), Website - the online service available at https://brzyski.com, through which the Administrator offers services to Clients under the name “Brzyski & Partners Management Consulting”. Client - any Client using the Website (natural persons, legal persons and entities without legal personality, regardless of the form of their business activity). Service - a service provided electronically by the Administrator, without the simultaneous presence of the parties (at a distance), through the transmission of data at the individual request of the Client, sent and received by means of equipment for electronic processing, including digital compression, and data storage, which is entirely transmitted, received or sent via a telecommunications network within the meaning of the Act of 16 July 2004 - Telecommunications Law, as well as any other services (not provided remotely) rendered by the Data Controller in the course of its business. Newsletter - a free electronic distribution Service, provided by the Seller by e-mail, enabling all Clients using it to automatically receive from the Administrator recurring content of successive Newsletter issues, containing in particular: information about products, training, news in the marketing industry and in running a business, marketing, sales and business advice, and invitations to events (hereinafter the “Newsletter”), provided on the terms described in the Newsletter Service Terms available at https://brzyski.com/regulamin-newslettera.

I. GENERAL INFORMATION

  1. This privacy policy is informational in nature, which means that it is not a source of obligations for the Clients of the Administrator or of the website “Brzyski & Partners Management Consulting”, hereinafter referred to as the “Website“.
  2. The Administrator of the Website is Łukasz Brzyski, sole trader operating under the business name “Łukasz Brzyski Trustart”, fixed place of business: 30-383 Kraków, ul. Wandejska 9, Tax ID (NIP) 6782864550, Business Registry No. (REGON) 386775495, e-mail address: contact@brzyski.com, who is at the same time the Controller of Clients’ personal data and the provider of the Newsletter service, hereinafter referred to as the “Administrator“.
  3. The Client’s personal data is processed in accordance with the Personal Data Protection Act of 30 August 2019 (Journal of Laws 2019, item 1781, as amended) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), jointly referred to as the “GDPR“, as well as the Act on Providing Services by Electronic Means of 6 February 2020 (Journal of Laws 2020, item 344).
  4. The Administrator pays particular attention to protecting the interests of data subjects and, in particular, ensures that the data it collects is processed lawfully; collected for specified, lawful purposes and not subjected to further processing incompatible with those purposes; substantively correct and adequate in relation to the purposes for which it is processed; and stored in a form that permits identification of the data subjects no longer than is necessary to achieve the purpose of the processing.
  5. Providing personal data by the Client is voluntary, but necessary in order to use the services of the Website. The services of the Website cannot be used anonymously.
  6. The Client may withdraw any consent given to the processing of data for the purpose specified on the Website - to do so, it is sufficient to send a request to cease processing of personal data by the Website to the Administrator’s e-mail address. The Client’s request to cease processing will be confirmed by the Administrator without undue delay by replying to the Client’s e-mail address.
  7. In order to use the Website, the Client should have a computer or device with software enabling web browsing and access to the Internet. The Website may be accessed using the most popular web browsers.
  8. The Administrator declares that the Website is free of content infringing the rights of third parties or applicable law, in particular content containing information that causes or creates a threat to the privacy or security of any person, information promoting illegal activity or conduct that is abusive, threatening, obscene, defamatory or libellous, inciting racism, ethnic, cultural or religious persecution, promoting or facilitating criminal activity, infringing the rights of third parties including intellectual property rights, or constituting any other form of infringement of legally protected interests.

II. PURPOSE AND SCOPE OF DATA COLLECTION AND DATA RECIPIENTS

  1. The collection and processing of personal data may take place in connection with and for the purpose of presenting an offer of Services, establishing cooperation, providing Services, as well as financial settlements and network security. Providing personal data is also necessary in order to use the contact form.
  2. The Administrator may process the following personal data of Clients using the Website: first name and surname; e-mail address; contact telephone number; postal address for correspondence. In the case of Clients who are not consumers, the Administrator may additionally process the Client’s company name and tax identification number (NIP).
  3. Where a Client uses electronic payments or a payment card, the Administrator shares the Client’s collected personal data with the selected entity handling those payments.
  4. Personal data will be processed for the purposes of:
    • submitting, accepting and fulfilling an enquiry or Service,
    • statistics, on the basis of Article 6(1)(f) GDPR, i.e. the legitimate interests pursued by the Administrator,
    • marketing consisting in sending commercial information by e-mail, on the basis of Article 6(1)(a) GDPR, where consent to the processing of data has been given,
    • conducting direct marketing activities on the basis of Article 6(1)(f) GDPR, i.e. the legitimate interests pursued by the Administrator,
    • the Client expressing an opinion on the way the Services are provided, on the basis of Article 6(1)(a) GDPR,
    • handling any complaints, as well as establishing, pursuing and defending against claims, on the basis of Article 6(1)(f) GDPR, i.e. the legitimate interests pursued by the Administrator,
    • fulfilling legal obligations imposed on the Administrator relating, among other things, to accounting and bookkeeping and to giving effect to the rights of data subjects, on the basis of Article 6(1)(c) GDPR, i.e. compliance with a legal obligation to which the Administrator is subject,
    • administering the website,
    • personalising the website for the Client,
    • dispatching goods purchased through the website,
    • providing services purchased through the website,
    • sending the Client statements, invoices and payment reminders, and receiving payments from the Client,
    • sending non-marketing commercial communications,
    • sending notifications to the e-mail address requested by the Client,
    • sending the newsletter to the e-mail address, after obtaining the Client’s consent (the Client has the right to inform the Administrator at any time that they no longer wish to receive the Newsletter),
    • sending marketing information concerning the activities of carefully selected third parties which, in the Administrator’s view, may be of interest to the Client, having first obtained the Client’s consent, by post (letter), electronically (e-mail) or using similar technology (the Client has the right to inform the Administrator at any time that they no longer wish to receive marketing communications),
    • sharing statistical information about Website users with third parties (without, however, the possibility of identifying a user on the basis of that information),
    • ensuring the security of the website and the Website and preventing fraud,
    • verifying compliance with the terms of use of the Website,
    • other purposes, after obtaining the Client’s consent.
  5. Where the Client provides the Administrator with personal data for publication on the Website, the Administrator may publish it and otherwise use it in accordance with the consent (licence) granted. The Client’s privacy settings may be used to limit the publication of information provided by the Client on the Website and may be adjusted using the privacy controls on the website. The Administrator will not, without the Client’s express consent, transfer personal data to third parties or to any other related third parties for direct marketing purposes.
  6. The Website performs the function of obtaining information about Clients and their behaviour in the following ways:
    • through the voluntary provision of personal data in forms - where failure to provide the personal data indicated on the Website as necessary for contacting the Client or providing the Service will make it impossible to reply or to provide the Service,
    • by storing cookie files on end devices,
    • by recording technical logs at the level of the web server, operated by the hosting provider cyber_Folks (https://cyberfolks.pl/).

III. INFORMATION PROVIDED IN THE CONTACT FORM

  1. The Website collects information provided voluntarily by the Client.
  2. The Website may also record information about connection parameters (time stamp, IP address).
  3. Data contained in the form is shared with third parties with the Client’s consent, unless disclosure of data to authorised state bodies, without prior consent, follows from generally applicable law.
  4. Data provided in the contact form is processed in particular for the purpose of: answering the question asked, sending an offer of cooperation, providing marketing and sales advice, and sending invitations to events and training offers in the following sectors: marketing, sales and business.
  5. Data provided in the contact form may be transferred to entities that technically deliver particular services - this concerns in particular the transfer of information about the holder of a registered domain to entities that are internet operators (primarily the Research and Academic Computer Network - NASK), payment operators or other entities with which the Website cooperates in this respect.

IV. RIGHT OF CONTROL, ACCESS TO AND CORRECTION OF DATA, SECURITY, RETENTION PERIOD

  1. The Client has the right to access and correct their personal data.
  2. Every person has the right to control the processing of data relating to them contained in the Administrator’s data set, and in particular the right to: request the completion, updating or rectification of personal data, the temporary or permanent suspension of its processing, or its erasure, if it is incomplete, out of date, untrue or was collected in breach of the act, or is no longer needed for the purpose for which it was collected.
  3. Where voluntary consent has been given, the Administrator may provide Clients with direct marketing services within the meaning of Article 172(1) of the Act of 16 July 2004 (consolidated text: Journal of Laws 2021, item 576) Telecommunications Law, using for that purpose the Client’s e-mail address and/or contact telephone number. Where the Client has given consent to the processing of data for marketing purposes, that consent may be withdrawn at any time.
  4. In order to exercise the rights referred to in points 2 and 3 above, you may contact the Administrator by sending an appropriate message in writing or electronically to the Administrator’s address: contact@brzyski.com.
  5. The Administrator applies technical and organisational measures ensuring protection of the personal data processed that is appropriate to the risks and to the categories of data protected, and in particular protects data against disclosure to unauthorised persons, removal by an unauthorised person, processing in breach of applicable law, and alteration, loss, damage or destruction.
  6. The Administrator observes the following principles of security in processing Clients’ personal data:
    • it records collected personal data only on such media and devices as are secured against access by third parties,
    • it maintains a register of data sets in accordance with legal requirements,
    • it supervises the security of the data throughout the period it holds it, in a manner ensuring in particular protection against unauthorised access, damage, destruction or loss,
    • it transfers data to authorised entities solely on the basis of applicable law, written authorisation or a personal data processing agreement,
    • it maintains the confidentiality of the personal data received.
  7. The period for which the Client’s personal data is processed (the data retention period) depends on the purpose and the legal basis constituting the legal ground for processing such data, i.e.:
    • until consent is withdrawn, where the processing is based on consent,
    • for 3 years after the end of cooperation, where the personal data was provided in order to obtain an answer to a question asked by e-mail, by telephone or through the contact form,
    • for the duration of negotiations, correspondence, orders or Services, until the order or Services are completed, and for the period required by law, in view of securing possible claims or defending against claims,
    • where no order is placed or where a Service is withdrawn from, or after it has been performed, for the period necessary for the purposes of pursuing claims or defending against claims,
    • until a legal obligation has been fulfilled (for example in respect of retaining documentation and the limitation of claims),
    • until the Administrator’s legitimate interest ceases to apply (for example the limitation period for civil law claims) or until the data subject objects to further processing, where the data is processed on the basis of the Data Controller’s legitimate interest.

V. INFORMATION ABOUT COOKIES

  1. The Website uses cookies.
  2. Consenting to the use of cookies in accordance with the terms of this Policy on the first visit to the Website permits the use of cookies on every subsequent visit to the Website.
  3. The Website does not automatically collect any information except for the information contained in cookies.
  4. Cookies are IT data, in particular text files, which are stored on the Client’s end device and intended for use of the Website. Files of this kind usually contain the name of the website they come from, the length of time they are stored on the end device and a unique number.
  5. The entity placing cookies on the Client’s end device and obtaining access to them is the Administrator or entities cooperating with it.
  6. Cookies are used for the following purposes:
    • creating statistics that help to understand how Clients use websites, which makes it possible to improve their structure and content,
    • maintaining the Client’s session (after logging in), so that the Client does not have to re-enter their login and password on every subpage of the Website,
    • remembering the password and login details in the web browser, if the Client consents to this,
    • determining the Client’s profile in order to display tailored material in advertising networks, in particular the Google network.
  7. Two basic types of cookies are used within the Website: “session cookies” and “persistent cookies”. Session cookies are temporary files stored on the Client’s end device until the Client logs out, leaves the website or switches off the software (web browser). “Persistent” cookies are stored on the Client’s end device for the time specified in the cookie parameters or until they are deleted by the Client.
  8. Web browsing software (the web browser) usually permits the storage of cookies on the end device by default. The Client may change these settings. The web browser makes it possible to delete cookies. It is also possible to block cookies automatically. Detailed information on this is available in the help section or documentation of the web browser.
  9. Restrictions on the use of cookies may affect some functionality of the Website.
  10. Cookies placed on the Client’s end device may also be used by advertisers and partners cooperating with the operator of the Website, as well as by payment operators.
  11. On the Website we use Google Analytics and Adwords in order to recognise a computer when a user visits the website, registers or makes a purchase. These tools also serve to improve usability, analyse use of the Website and administer it. Thanks to these tools the Administrator can prevent fraud and improve the security of the website, as well as personalise the site for each user and target advertising that may be of particular interest to specific users.
  12. We recommend reading the privacy policies of these companies in order to learn the rules on the use of cookies applied in statistics: Google Analytics privacy policy.
  13. Cookies may be used by advertising networks, in particular the Google network, to display advertising tailored to the way the Client uses the Website. For this purpose they may store information about the Client’s navigation path or the time spent on a given page.
  14. As regards information about the Client’s preferences collected by the Google advertising network, the Client may view and edit information resulting from cookies using the tool: https://www.google.com/ads/preferences/
  15. The Website uses measurement tools that are activated only after consent has been given: Google Analytics 4 (measurement ID G-R4LHDRMZ72), deployed through Google Tag Manager. Both tools are provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
  16. These tools set cookies named _ga and _ga_R4LHDRMZ72, valid for up to 2 years, used to distinguish users and sessions. Until consent is given, these cookies are not set.
  17. The Website uses Google Consent Mode v2. Before consent is given, Google tools store no identifiers on the end device and the signals sent do not allow the Client to be identified.
  18. Consent to statistics and marketing cookies is voluntary, and withholding it does not restrict access to the content of the Website.

VI. SERVER LOGS

  1. Information about certain Client behaviour is logged at the server layer. This data is used solely for the purpose of administering the Website and ensuring the most efficient possible operation of the hosting services provided.
  2. The resources viewed are identified by URL addresses. In addition, the following may be recorded:
    • the time the request was received,
    • the time the response was sent,
    • the name of the Client’s station - identification carried out by the HTTP protocol,
    • information about errors that occurred during the execution of the HTTP transaction,
    • the URL address of the page previously visited by the Client (referer link) - where the Website was reached via a link,
    • information about the Client’s browser,
    • information about the IP address.
  3. The above data is not associated with specific individuals browsing the pages.
  4. The above data is used solely for the purpose of administering the server.

VII. SHARING AND ENTRUSTING DATA PROCESSING

  1. Data is shared with external entities only within the limits permitted by law, on the basis of written authorisations or personal data processing agreements based on the provisions of the GDPR.
  2. Data enabling the identification of a natural person is shared only with that person’s consent.
  3. The operator may be obliged to provide information collected by the Website to authorised bodies, on the basis of lawful requests and only to the extent resulting from the request.
  4. Clients’ personal data may be transferred to the following recipients or categories of recipients:
    • providers of a review system - in the case of a Client who has consented to giving an opinion about the services of the Website, the Administrator shares the Client’s collected personal data with the selected entity providing the review system at the Administrator’s request, to the extent necessary for the Client to express an opinion through the review system,
    • couriers / postal service providers - in the case of a Client who uses a method of delivery of ordered goods or Services to their home/business or by post, the Administrator shares the Client’s collected personal data with the selected courier, freight forwarder or intermediary carrying out the delivery at the Administrator’s request - to the extent necessary to carry it out,
    • entities handling electronic or payment card payments - in the case of a Client who uses the Website with an electronic or payment card payment method, the Administrator shares the Client’s collected personal data with the selected entity handling those payments on the Website at the Administrator’s request - to the extent necessary to handle payments made by the Client,
    • providers of services supplying the Administrator with technical, IT and organisational solutions enabling the Administrator to run its business, including the Website and the Electronic Services provided through it (in particular providers of computer software for operating the Website, providers of e-mail and hosting services and providers of business management software and technical support to the Administrator) - the Administrator shares the Client’s collected personal data with a selected provider acting on its behalf only in the case of, and to the extent necessary for, achieving the given purpose of data processing in accordance with this Privacy Policy,
    • providers of accounting, legal and advisory services supplying the Administrator with accounting, legal or advisory support (in particular an accounting office, a law firm or a debt collection company) - the Administrator shares the Client’s collected personal data with a selected provider acting on its behalf only in the case of, and to the extent necessary for, achieving the given purpose of data processing in accordance with this privacy policy.
  5. As a rule, the Administrator does not transfer personal data outside the European Economic Area. However, the Administrator may commission particular IT services or tasks to service providers established outside the European Economic Area, for example data processed through the website or sent by e-mail may be processed outside the EEA where the servers of the operators managing those services are located outside the EEA. In such a case the data is transferred to a third country in respect of which an adequate level of data protection has been established on the basis of a decision of the European Commission, or using standard contractual clauses approved by the European Commission. Further information about the safeguards applied and a copy of the data may be obtained on request.

VIII. MANAGING COOKIES - HOW TO GIVE AND WITHDRAW CONSENT IN PRACTICE

  1. On a first visit to the Website a banner is displayed in which the Client decides which categories of cookies they consent to. Until a choice is made, only cookies essential to the operation of the Website are activated.
  2. Three categories are available: Essential (always on, required for the Website to work), Statistics (measurement of traffic and how the Website is used) and Marketing (measurement of advertising performance).
  3. The choice is stored in a cookie named bp_consent, valid for 12 months. This cookie contains no data that would allow the Client to be identified.
  4. Consent may be changed or withdrawn at any time by opening the settings panel with the link below. Withdrawal of consent does not affect the lawfulness of processing carried out before it was withdrawn. Change cookie settings
  5. Independently of the above, the Client may manage cookies in their browser settings: block automatic handling of cookies or request notification each time a cookie is stored on the device. Detailed information is available in the browser documentation.
  6. Please note that disabling cookies required for authentication, security and preference-keeping processes may make using the Website difficult and, in extreme cases, impossible.

IX. FINAL PROVISIONS

  1. The Administrator reserves the right to amend the Privacy Policy at any time.
  2. The Administrator will inform the Client of the content of any amendments by posting a notice on the Website. The Client may also be additionally informed of an amendment by e-mail to the address indicated by them.
  3. The privacy policy applies from 1 May 2026.
This version of the Privacy Policy was published on 1 May 2026. This is a translation of the Polish-language Privacy Policy. In the event of any discrepancy, the Polish version available at https://brzyski.com/polityka-prywatnosci/ shall prevail.