Privacy Policy

1. General provisions

1.1. This Privacy Policy (the "Policy") sets out how the personal data of visitors to the website hoverly-soft.com (the "Website") is processed and protected, and how cookies are used.

1.2. The controller of your personal data is Julia Pimonowa, operating as an unregistered sole trader (działalność nierejestrowana) under the Hoverly brand (the "Controller", "we"). Contact for data protection matters: info@hoverly-soft.com.

1.3. We process data in accordance with Regulation (EU) 2016/679 of 27 April 2016 (GDPR), the Polish Personal Data Protection Act of 10 May 2018 and the Polish Electronic Communications Law of 12 July 2024 (as regards cookies).

1.4. Using the Website does not require an account or providing any data. You provide data only when you send us an enquiry through the contact form or contact us in another way.

2. Definitions

• Personal data — information about an identified or identifiable natural person.
• User / you — any person using the Website.
• Cookies — small text files stored on your device while you use the Website.
• GDPR — the regulation referred to in section 1.3.

3. What data we collect

3.1. Data you provide yourself — through the contact form on the Website or by writing to us directly:

• first name,
• contact details: phone number, messenger username or e-mail address,
• preferred language of communication,
• the content of your message and any information about your project you choose to share.

Providing this data is voluntary, but without contact details we will not be able to reply to your enquiry.

3.2. Data collected automatically while you use the Website:

• technical information recorded in server logs (IP address, date and time of the request, address of the page visited, browser and operating system type),
• with your consent — information about how you use the Website and about the effectiveness of our ads, collected by analytics and marketing tools (see section 8).

3.3. We do not collect special categories of data (e.g. health or beliefs) and ask you not to include them in the form.

4. Purposes and legal bases of processing

We process your data in order to:

• a) reply to your enquiry, present an offer and agree the terms of cooperation — under Article 6(1)(b) GDPR (steps prior to entering into a contract, taken at your request) and Article 6(1)(f) GDPR (our legitimate interest in handling correspondence and running our business);
• b) conclude and perform a contract, if you decide to work with us — Article 6(1)(b) GDPR;
• c) comply with legal obligations, in particular tax and accounting obligations related to the contract — Article 6(1)(c) GDPR;
• d) establish, pursue or defend against claims — Article 6(1)(f) GDPR;
• e) ensure the security and proper functioning of the Website (server logs) — Article 6(1)(f) GDPR;
• f) compile statistics and improve the Website using analytics tools, and measure the effectiveness of our ads and show them to people who have visited the Website (marketing tools) — on the basis of your consent given in the cookie banner, Article 6(1)(a) GDPR.

You may withdraw your consent at any time (section 8); this does not affect the lawfulness of processing carried out before withdrawal.

5. Data retention

• Data from enquiries that did not lead to cooperation — for 12 months from the last contact, after which we delete it.
• Data related to a concluded contract — for the duration of the contract and then for the limitation period of any claims and for the period required by tax and accounting law (as a rule, 5 years from the end of the year in which the obligation arose).
• Server logs — no longer than 90 days.
• Analytics and marketing data — for the lifetime of the relevant cookies (section 8) or until consent is withdrawn.

6. Recipients of data

6.1. Data may be shared with providers that support the operation of the Website and our business and process data on our instructions:

• DigitalOcean, LLC — hosting of the Website and the server that sends contact-form messages;
• Namecheap, Inc. — domain management and e-mail forwarding;
• Google (Google Ireland Limited / Google LLC) — the mailbox that receives contact-form messages (Gmail), analytics tools (Google Analytics, Google Tag Manager) and Google Ads advertising tools — analytics and advertising only with your consent;
• Meta Platforms Ireland Limited — Meta Pixel, a tool for measuring the effectiveness of ads on Facebook and Instagram; it runs only with your consent. Meta also processes this data under its own terms described in its privacy policy (facebook.com/privacy/policy);
• Useme sp. z o.o. (Wrocław, Poland) — the platform through which we conclude contracts and settle payments with clients; your data will be shared with it if you decide to work with us;
• where necessary — providers of accounting, legal or IT services.

6.2. Data may be disclosed to public authorities where required by law.

6.3. If you contact us via a messenger (e.g. WhatsApp, Telegram), the provider of that messenger processes your data under its own privacy policy.

7. Transfers outside the European Economic Area

Some of the providers listed above (DigitalOcean, Namecheap, Google, Meta) are based in the United States or may process data on servers outside the EEA. In such cases, the transfer takes place on the basis of a European Commission adequacy decision (EU-U.S. Data Privacy Framework, for certified providers) or standard contractual clauses approved by the European Commission. You can request a copy of the safeguards applied by writing to info@hoverly-soft.com.

8. Cookies, analytics and marketing tools

8.1. The Website uses three types of cookies:

• necessary — required for the Website to work properly and to remember your cookie choice; they do not require consent;
• analytics — help us understand how visitors use the Website (number of visits, traffic sources, pages viewed, devices). We use Google Analytics 4, implemented via Google Tag Manager. The data is collected as aggregated statistics; Google Analytics 4 does not store full IP addresses.
• marketing — let us measure whether our ads on Google, Facebook and Instagram are working, and show them to people who have already visited the Website (remarketing). We use Google Ads and Meta Pixel.

8.2. Analytics and marketing cookies are activated only after you give consent in the banner — separately for each category. Until you consent, these tools remain switched off (Consent Mode). You can change or withdraw your consent at any time by clicking "Cookie settings" in the Website footer.

8.3. Google Analytics cookies are stored for a maximum of 2 years; Google Ads and Meta marketing cookies for up to 90 days (or until they are deleted or consent is withdrawn). More on how Google and Meta process data: policies.google.com/privacy and facebook.com/privacy/policy.

8.4. You can also manage cookies in your browser settings, including deleting and blocking them. Blocking necessary cookies may make the Website harder to use.

8.5. Declining analytics or marketing cookies does not limit your use of the Website in any way. If we add new tools, we will update this Policy and ask for your consent again.

9. Server logs

The server hosting the Website automatically records technical information about each request in its logs: IP address, date and time, page address, browser and system type. We use this data solely to administer the Website, detect errors and ensure security; we do not combine it with data from the contact form.

10. Your rights

You have the right to:

• access your data and obtain a copy of it,
• rectify your data,
• erase your data (the "right to be forgotten"),
• restrict processing,
• data portability (for data processed on the basis of a contract or consent),
• object to processing based on legitimate interest,
• withdraw consent at any time,
• lodge a complaint with the President of the Polish Personal Data Protection Office (Prezes UODO, ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl).

To exercise your rights, write to info@hoverly-soft.com. We will reply within one month at the latest.

11. Data security

We apply measures appropriate to the risk: the connection to the Website is encrypted (HTTPS), access to the mailbox and server is protected by passwords and, where possible, two-step verification, and enquiry data is stored only in the systems listed above and is not disclosed to unauthorised persons.

12. Automated decision-making and profiling

We do not make decisions about you based solely on automated processing and do not profile you within the meaning of the GDPR.

13. Children's data

The Website and our services are intended for adults and businesses. We do not knowingly collect data from persons under 16; if we become aware of such a case, we will delete the data.

14. Changes to this Policy

We may update this Policy when the law, our tools or the scope of our services change. The current version is always available on the Website, with the date of the last update shown at the top.

15. Contact

For all matters relating to personal data: info@hoverly-soft.com.