Privacy Policy
This Privacy Policy sets out the rules for processing personal data in connection with the use of the toruai.com website.
1. Data Controller
The data controller is Tomasz Pijanowski TORU, ul. Na Ostatnim Groszu 52 lok. 4, 54-207 Wrocław, Poland, NIP (Tax ID): 8943247066, REGON: 540011340. Contact: toru@toruai.com.
The controller has not appointed a Data Protection Officer.
2. Scope of Data Collected
We process data you provide voluntarily, as well as data collected automatically:
- Contact form and demo request — name, email address, company name, message content.
- Newsletter (if you subscribe) — email address.
- Technical data — IP address, browser and device information, data from cookies and similar technologies.
3. Purposes and Legal Bases for Processing
- Handling contact-form enquiries and providing the demo — Article 6(1)(b) and (f) GDPR (handling correspondence as a legitimate interest).
- Newsletter and our own email marketing — Article 6(1)(a) GDPR (consent) and Article 10 of the Polish Act on Providing Services by Electronic Means.
- Statistics and analytics (Google Analytics, PostHog) — Article 6(1)(a) GDPR (consent to cookies).
- Ensuring the security and stability of the website — Article 6(1)(f) GDPR (legitimate interest).
4. Data Retention
- Contact-form correspondence — up to 24 months after the correspondence ends.
- Newsletter — until consent is withdrawn (unsubscription).
- Analytics data and technical logs — up to 24 months.
5. Data Recipients and Processors
Data may be entrusted to entities that process it on our behalf, under data processing agreements:
- dhosting.pl — hosting and email (Poland / EU),
- PostHog — analytics (European Union),
- Google (Google Analytics 4) — analytics (Google Ireland Ltd. / Google LLC),
- Calendly — call scheduling (Calendly LLC),
- Cloudflare — website security and delivery (Cloudflare, Inc.).
6. Transfers Outside the EEA
Some services (Google, Calendly, Cloudflare) may involve transferring data to the USA. This takes place under appropriate safeguards: Standard Contractual Clauses (SCC) or the Data Privacy Framework. PostHog analytics and hosting/email (dhosting.pl) remain within the European Union.
7. Cookies
The website uses cookies and similar technologies in three categories:
- necessary — required for the website to function (no consent needed),
- analytics — statistics and traffic measurement (Google Analytics, PostHog),
- marketing — including remembering marketing preferences.
Analytics and marketing cookies are activated only after you give consent (Google Consent Mode v2). You can change or withdraw consent at any time via the cookie settings in the website footer or in your browser settings.
8. Your Rights
You have the right to: access your data, rectify it, erase it, restrict processing, data portability, object to processing, and withdraw consent at any time (without affecting the lawfulness of processing carried out before withdrawal). You also have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes UODO, ul. Stawki 2, 00-193 Warszawa, Poland).
9. Voluntary Provision of Data
Providing data is voluntary but necessary to use certain features — without your email address we cannot respond to an enquiry or send the newsletter.
10. Security
We process data using appropriate technical and organizational measures, including SSL/TLS encryption and access control.
11. Changes to the Policy
We reserve the right to amend this Privacy Policy. The current version is always available at toruai.com/privacy-policy.