§01
Who controls your data
The controller of personal data processed in connection with the use of duztr.com and with our design and engineering services is:
/ Administrator danych
Usługi IT Bartosz Nalewajka
al. Solidarności 68 / 121
00-240 Warsaw, Poland
VAT PL9492182387
We have not appointed a Data Protection Officer (DPO) — for any data-protection matter you write directly to the controller at the e-mail above.
§02
What data we collect, and from where
We collect only data strictly necessary to reply, quote and deliver the project. No data hoarding.
- Data from the contact form — name and/or company, e-mail, optional phone, message content, approximate budget, project type.
- E-mail correspondence — message threads, attachments, sender address.
- Contract data — data needed to sign a contract and issue invoices (VAT ID, address, bank account).
- Technical data — anonymised IP, browser type, navigation events — aggregated only, never profiled.
We do not collect special category (sensitive) data within the meaning of Art. 9 GDPR.
§03
Purposes and legal bases
Every processing activity is tied to a specific legal basis. Here are all of them:
Purpose
Legal basis
Retention
Answering inquiries
Art. 6(1)(b) GDPR — pre-contractual steps
up to 12 months from last contact
Entering into and performing a contract
Art. 6(1)(b) GDPR — contract performance
duration of the contract
Invoicing, bookkeeping
Art. 6(1)(c) GDPR — legal obligation
5 years (Polish Tax Code)
Defence against claims
Art. 6(1)(f) GDPR — legitimate interest
until statute of limitations
Traffic statistics (no profiling)
Art. 6(1)(f) GDPR — legitimate interest
26 months
§04
Who we share data with
By default: no one — we operate solo, no middlemen. Data is shared only with trusted processors strictly necessary to deliver the service:
- Hosting and e-mail — server and mailbox provider (EU).
- Accounting office — the minimum needed to book invoices.
- Payment providers / bank — for settlements.
- Work tooling — code repositories (GitHub), communication and design tools, used strictly within the scope of the project.
We sign a Data Processing Agreement (Art. 28 GDPR) with every processor. We do not sell your data and do not share it for marketing.
§05
International transfers
By default, data is processed within the EU. Some providers (e.g. GitHub) may process data outside the EEA — in such cases the transfer is based solely on Standard Contractual Clauses (SCC) approved by the European Commission or on an adequacy decision (Data Privacy Framework).
Exact periods are listed in the table in §03. The general rule:
- Unanswered follow-ups — deleted after 12 months.
- Contract data and project correspondence — for the duration of the project plus the statute of limitations.
- Invoices and accounting documents — 5 years from the end of the tax year (legal requirement).
- Traffic statistics — up to 26 months, aggregated, no identification.
After these periods data is permanently deleted or irreversibly anonymised.
Under GDPR you have full control over your data. To exercise any of these rights, e-mail hey@duztr.com — we respond within 30 days, usually sooner.
/ 01
Access
Request a copy of the data we hold about you.
/ 02
Rectification
Tell us what's outdated — we'll fix it.
/ 03
Erasure
„Right to be forgotten”. We delete what we can (beyond legal retention).
/ 04
Restriction
You may request we pause processing in certain cases.
/ 05
Portability
You get your data in a structured, machine-readable format.
/ 06
Objection
You may object to processing based on our legitimate interest.
/ 07
Withdrawal
Where consent is the basis — you may withdraw it anytime.
/ 08
Complaint (DPA)
You may lodge a complaint with the Polish DPA (uodo.gov.pl).
The duztr.com site is lean — we use the minimum possible cookies:
- Strictly necessary cookies — remember your language (PL/EN) and light/dark mode. No consent required.
- Analytics cookies (optional) — anonymous traffic statistics, no profiling, no cross-source joining. Loaded only after you consent in the cookie banner.
We do not use remarketing, targeted ads, or third-party trackers such as Facebook Pixel. You can change cookie settings at any time — in the on-page banner or in your browser.
We process data in a way proportionate to our scale — no theatre, real safeguards:
- Site connection encrypted end-to-end (TLS/HTTPS).
- Access to work tooling secured with multi-factor authentication.
- Passwords stored in a password manager — never in plain text, never „just in case” in the cloud.
- Working disks encrypted at the OS level (FileVault / LUKS).
- Project backups encrypted and time-limited.
- In case of a data breach — we notify you and the Polish DPA within 72h under Art. 33 GDPR.
§10
Changes to this policy
We update this policy when the scope of services, tools or regulations change. Every version carries a number (v.1.0, v.1.1, …) and an issue date — visible at the top and in the footer.
We notify active clients of material changes by e-mail. Previous versions are archived and available on request.
End of document — thanks for reading.SHA · 4a7e··bd22 / v.1.2