Privacy policy
This document explains what personal data this website collects, why, on what legal basis and for how long we keep it, along with the rights you have in connection with it.
This is a translation provided for convenience. In case of any discrepancy, the Polish version of this document prevails.
Last updated:
1. General provisions
This privacy policy is informative in nature, which means it is not a source of obligations for the users or clients of the Website. It sets out the rules under which the Controller processes personal data on the Website, including the legal bases, purposes and periods of processing, the rights of data subjects, and information about the cookies and analytics tools used on the Website.
The controller of personal data collected through the Website is Fundacja Rozwoju Przedsiębiorczości „Twój Startup", with its registered office in Warsaw, ul. Żurawia 6/12 apt. 766, 00-503 Warsaw, Poland, entered in the register kept by the National Court Register under number KRS 0000442857, tax identification number NIP 5213641211, statistical number REGON 146433467, acting through the organisationally separated project „Gabinet Psychologiczny Unique", operated at ul. Béli Bartóka 8/76, 02-787 Warsaw, e-mail address: gabinetunique@gmail.com, telephone number: +48 698 186 680 - hereinafter the „Controller".
Personal data on the Website is processed by the Controller in accordance with applicable law, in particular with 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) - hereinafter the „GDPR".
Using the Website is voluntary. Likewise, providing personal data by a user of the Website is voluntary.
The Controller takes particular care to protect the interests of the data subjects and in particular ensures that the data it collects is: (1) processed lawfully; (2) collected for specified, lawful purposes and not further processed in a way incompatible with those purposes; (3) accurate and adequate in relation to the purposes for which it is processed; (4) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes of the processing; and (5) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Taking into account the nature, scope, context and purposes of processing, as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, the Controller implements appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with the GDPR. Those measures are reviewed and updated where necessary. The Controller applies technical measures preventing unauthorised persons from obtaining and modifying personal data sent electronically.
The Website collects no health data and no other special categories of data. Appointments are booked outside this website, and everything said during a consultation is covered by professional secrecy and has nothing to do with this document.
2. Legal bases for processing
The Controller is entitled to process personal data where - and to the extent that - at least one of the following conditions is met: (1) the data subject has given consent to the processing of their personal data for one or more specific purposes; (2) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; (3) processing is necessary for compliance with a legal obligation to which the Controller is subject; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
Each instance of processing by the Controller requires at least one of the bases listed in clause 2.1 to apply. The specific bases for processing users’ personal data are indicated in the next chapter of this policy, in relation to each purpose of processing.
3. Purpose, legal basis and retention period
In each case the purpose, legal basis, retention period and recipients of personal data processed by the Controller follow from the actions taken by the given user or by the Controller.
The Controller processes personal data within the Website for the following purposes, on the following bases and for the following periods:
- Use of the Website and ensuring that it works correctly and safely
- Legal basis: article 6(1)(f) GDPR (the legitimate interest of the Controller in making the website available and protecting it from abuse). Retention: server log data held by the hosting provider is kept for no longer than 30 days.
- Keeping statistics and analysing traffic on the Website
- Legal basis: article 6(1)(a) GDPR (consent given in the cookie consent dialog). Retention: until consent is withdrawn, and no longer than 14 months from the last visit - that is the retention period configured in the analytics tool.
- Contact by telephone or e-mail, including booking an appointment
- Legal basis: article 6(1)(b) GDPR (steps taken at the request of the data subject prior to entering into a contract) and article 6(1)(f) GDPR (the legitimate interest in replying). Retention: for the duration of the correspondence and afterwards for the limitation period for claims.
- Establishing, pursuing or defending claims
- Legal basis: article 6(1)(f) GDPR (the legitimate interest of the Controller). Retention: for the limitation period for claims set out in law, in particular in the Polish Civil Code.
The Website contains no contact form. Contact with the Controller takes place by telephone or e-mail, and appointments are booked through the external service described in clause 4.3.
4. Recipients of data on the Website
For the Website to function properly, the Controller must use the services of external entities. The Controller uses only those processors that provide sufficient guarantees to implement appropriate technical and organisational measures so that the processing meets the requirements of the GDPR and protects the rights of data subjects.
The Controller does not transfer data in every case and not to all of the recipients or categories of recipients indicated in this policy. Data is transferred only where it is necessary to achieve a given purpose of processing and only to the extent necessary to achieve it.
Personal data of Website users may be transferred to the following recipients or categories of recipients:
- Hosting provider: Cloudflare, Inc.
- The Website is served from the edge network of Cloudflare, Inc. (101 Townsend St., San Francisco, California, United States). The provider processes the IP address and technical request data, which is necessary to display the page and to protect it. Transfers outside the European Economic Area are based on the standard contractual clauses approved by the European Commission and on the adequacy decision under the EU-US Data Privacy Framework.
- Analytics provider: Google Ireland Limited
- The Controller uses Google Analytics 4, provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). The service starts ONLY after consent has been given in the cookie consent dialog. Details in chapter 7.
- Appointment booking widget provider: DocPlanner
- The Website embeds the booking widget of the ZnanyLekarz service, operated by DocPlanner S.A., ul. Kolejowa 5/7, 01-217 Warsaw, Poland. Loading the widget transfers to that provider your IP address, device information and the address of the page the widget sits on, and stores that provider’s cookies. Booking an appointment in that widget is governed by the privacy policy of the ZnanyLekarz service, which is then a separate controller of your data.
- Providers of accounting, legal and advisory services
- In particular an accounting office or a law firm - the Controller discloses collected personal data to a selected provider acting on its behalf only where and to the extent necessary to achieve a given purpose of processing consistent with this privacy policy.
Google privacy policyZnanyLekarz privacy policyCloudflare privacy policy
The Website contains NO social media plugins. Links to the practice’s social profiles are ordinary links: until you click one, they transfer no data.
5. Profiling on the Website
The GDPR obliges the Controller to provide information about automated decision-making, including profiling, referred to in article 22(1) and (4) GDPR and - at least in those cases - meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
The Controller does NOT use profiling or automated decision-making producing legal effects on the Website. The statistics described in chapter 7 are aggregate and are not used to assess an individual person.
The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
6. Rights of the data subject
Right of access, rectification, restriction, erasure and portability - the data subject has the right to request from the Controller access to their personal data, its rectification, erasure (the „right to be forgotten") or restriction of processing, and the right to data portability. Detailed conditions for exercising these rights are set out in articles 15-21 GDPR.
Right to withdraw consent at any time - a person whose data is processed by the Controller on the basis of consent has the right to withdraw that consent at any time, without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal. You can withdraw consent to statistical cookies using the „Cookie settings" link in the footer of every page.
Right to lodge a complaint with a supervisory authority - a person whose data is processed by the Controller has the right to lodge a complaint with a supervisory authority in the manner and procedure set out in the GDPR and in Polish law. The supervisory authority in Poland is the President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw.
Right to object - the data subject has the right to object at any time, on grounds relating to their particular situation, to processing of personal data concerning them which is based on article 6(1)(e) or (f) GDPR, including profiling based on those provisions. The Controller shall then no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or grounds for the establishment, exercise or defence of legal claims.
Right to object to direct marketing - where personal data is processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning them for such marketing, including profiling, to the extent that it is related to such direct marketing.
To exercise the rights described in this chapter, you may contact the Controller by sending a message in writing or by e-mail to the address of the Controller indicated in clause 1.2.
8. Final provisions
The Website may contain links to other websites. The Controller encourages you to read the privacy policy established there after moving to another site. This privacy policy applies only to the Controller’s Website.
The Controller may amend this privacy policy, in particular where the set of tools used on the Website changes or where the applicable law changes. The date of the last change is given at the top of this document.

