Privacy policy
What data we collect on whiteanchor.pl, why, who we share it with and what rights you have.
Contents
Data controller
The controller of your personal data is Sylwester Budzelewski, running a business under the name White Anchor Sylwester Budzelewski, ul. Jana Heweliusza 11, 80-890 Gdańsk, Poland, NIP (Polish tax identification number) 578-289-61-01.
For matters relating to personal data, write to ahoj@whiteanchor.pl or call 792 793 088. We have not appointed a data protection officer, because the law does not require one for our activities.
What data we collect
From the enquiry form: your full name and email address and, if you provide them: your company, phone number, budget range, what you need, the content of your message and your answers in the details section.
From the contact form: your full name, email address, phone number if you provide it, and the content of your message.
We count downloads anonymously: we record how many times a file has been downloaded, without any data that could identify you. If you consent to analytics cookies, the download is also sent to Google Analytics together with the rest of your visit.
With every form we record the page from which the form was sent and the source of the visit (for example UTM parameters). This tells us which channels bring in enquiries.
Technical data: IP address, browser and device type, time of visit. This data is processed by the website server and Cloudflare so that the site works and is protected.
Data from cookies and similar technologies: only to the extent you consent to in the banner (details in the cookies section).
Providing data is voluntary. Without the fields marked as required in the form, we cannot reply to your enquiry.
Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Replying to an enquiry or message and discussing working together | Article 6(1)(f) GDPR, our legitimate interest, namely replying to your message. When you ask about working together on your own behalf, also Article 6(1)(b) GDPR, namely steps taken prior to entering into a contract |
| Entering into and performing a contract | Article 6(1)(b) GDPR |
| Accounting and taxes | Article 6(1)(c) GDPR, legal obligation |
| Assessing the effectiveness of our channels (source of the enquiry) | Article 6(1)(f) GDPR |
| Visit statistics and analysis of how the site is used (Google Analytics 4, Microsoft Clarity) | Article 6(1)(a) GDPR, consent given in the banner |
| Conversion tracking and remarketing (Google Ads, Meta, LinkedIn, Microsoft Advertising) | Article 6(1)(a) GDPR, consent given in the banner |
| Website security and protecting forms against spam | Article 6(1)(f) GDPR |
| Establishing, pursuing or defending legal claims | Article 6(1)(f) GDPR |
Remarketing means that advertising platforms may show you our ads after you have visited the website. We do not make decisions based solely on automated processing that would produce legal effects concerning you or similarly significantly affect you.
Forms and HubSpot
Data from the forms goes to the ahoj@whiteanchor.pl mailbox and to HubSpot CRM, where we keep the conversation and the history of our contact. HubSpot processes the data on our behalf under a data processing agreement and stores it in a data centre in the European Union. The service provider is HubSpot Ireland Limited.
Cookies, Google Tag Manager and Consent Mode
Cookies are small files stored in your browser. On your first visit, the banner asks for your consent separately for each category. Without consent, only essential cookies are used.
| Category | Tools | Purpose |
|---|---|---|
| Essential | consent banner, Cloudflare (including Turnstile) | remembering your choice, protecting the site and forms |
| Analytics | Google Analytics 4, Microsoft Clarity | visit statistics: which pages you read, where you come from, how you scroll and click |
| Marketing | Google Ads, Meta Pixel and Conversions API, LinkedIn Insight Tag, Microsoft Advertising UET tag | measuring ad performance and remarketing |
We run these tools through Google Tag Manager, which does not set cookies itself. Tag Manager loads only after you consent to analytics or marketing cookies, and each tag runs only in the category you have ticked. Google tags work in the basic mode of Consent Mode v2 and receive information about which categories you have consented to.
Microsoft Clarity shows us how visitors use the website: it records cursor movement, clicks and scrolling, and uses this data to create recordings of visits and click maps. Text typed into forms does not appear in the recordings, because Clarity masks it. We run this tool only after you consent to analytics cookies.
If you consent to marketing cookies, we also send information about a submitted form to Meta from our server (Conversions API). In that case, your email address and phone number are sent as SHA-256 hashes: one-way strings that Meta uses to match the event to a user account. In this form the data is still personal data. For data collected by the Meta Pixel and the Conversions API, Meta Platforms Ireland Limited is a joint controller with us with respect to the collection and transmission of the data. The essence of the arrangement: Meta Controller Addendum.
We remember your choice for 12 months. You can change your decision at any time using the button below or in your browser settings. Withdrawing consent does not affect the lawfulness of processing carried out before it was withdrawn.
Cloudflare and Turnstile
Traffic to the website passes through the Cloudflare network, which speeds up page loading and protects the site against attacks. The forms are protected by Cloudflare Turnstile, which checks whether a form is being sent by a human without asking you to retype characters from an image. In doing so, Cloudflare processes technical data: IP address and information about your browser and device. The provider is Cloudflare, Inc., based in the USA, which participates in the EU-U.S. Data Privacy Framework.
How long we keep data
| Data | Period |
|---|---|
| Enquiries and messages that do not lead to working together | 180 days from the last contact |
| Contract-related data | for the term of the contract, and then until the limitation periods for claims expire |
| Accounting documents | 5 years from the end of the calendar year in which the tax payment deadline passed |
| Data in Google Analytics 4 | 14 months |
| Visit recordings in Microsoft Clarity | 30 days (click maps and aggregated data: 9 months) |
| Record of your choice in the cookie banner | 12 months |
| Analytics cookies | until you withdraw consent; the Google Analytics identifier expires after 24 months |
| Marketing cookies | until you withdraw consent; the cookies expire after 13 months at the latest |
| Server logs (IP address, browser, time of visit) | 30 days |
Who we share data with
We share data with the providers of the tools we use to run the website and the business:
- Zenbox sp. z o.o.: website hosting and email,
- HubSpot Ireland Limited: CRM system,
- Cloudflare, Inc.: content delivery network and form protection,
- Google Ireland Limited: Google Tag Manager, Google Analytics 4, Google Ads and Google Drive, where we store documents relating to enquiries and our work together,
- Meta Platforms Ireland Limited: Meta Pixel and Conversions API,
- LinkedIn Ireland Unlimited Company: LinkedIn Insight Tag,
- Microsoft Ireland Operations Limited: Microsoft Advertising UET tag and Microsoft Clarity,
- iFirma S.A.: accounting system, only for data of clients with whom we have signed a contract.
Google, Meta, Microsoft, LinkedIn, Cloudflare and HubSpot belong to groups based in the USA, so data may be transferred outside the European Economic Area. Such transfers are based on the European Commission's decision on the EU-U.S. Data Privacy Framework or on standard contractual clauses approved by the Commission. We will provide a copy of the safeguards on request sent to ahoj@whiteanchor.pl.
We may also disclose data to public authorities where the law requires it.
Your rights
You have the right to:
- access your data and receive a copy of it,
- rectification of your data,
- erasure of your data,
- restriction of processing,
- portability of data that we process on the basis of consent or a contract,
- object to processing based on legitimate interest,
- withdraw your consent at any time, without affecting the lawfulness of processing before its withdrawal,
- lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, Poland).
To exercise your rights, write to ahoj@whiteanchor.pl. We reply within one month. In a complex case we may extend this by a further two months, and we will let you know if so.
Changes to this policy
When we change our tools or the way we process data, we update this policy and the date at the top of the page. If the change requires new consent, the banner will ask for it again.