Privacy Policy

1. Information We Collect

1.1 Information you provide directly

When you contact us through our website contact form, we collect the following information:

• First name and last name - to address you properly in correspondence
• Email address - to respond to your inquiry
• Message content - to understand and address your request

This information is provided voluntarily. You are not obligated to provide it, but without it we may not be able to respond to your inquiry.

1.2 Information collected automatically

When you visit our website, our hosting provider may automatically collect certain technical information:

• IP address
• Browser type and version
• Device type and operating system
• Referring website
• Date and time of visit
• Pages visited

This information is used solely for technical operation of the website, security, and aggregate traffic analysis. We do not link this data to your identity.

1.3 Information from our applications

Our mobile applications store all user data locally on the user's device. We do not collect, transmit, or process any data from our applications on any server. All data entered by users remains on their device under their full control.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Responding to inquiries - to reply to messages sent via our contact form
• Business communication - to discuss projects, partnerships, or support requests
• Website operation - to maintain and operate our website securely
• Legal compliance - to fulfill legal obligations where applicable
• Security - to protect against fraud, abuse, and unauthorized access

We do not use your information for marketing, advertising, profiling, or selling to third parties.

3. Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

• Consent (Article 6(1)(a)) - you voluntarily provide your information through our contact form
• Legitimate interests (Article 6(1)(f)) - processing is necessary for responding to your inquiry and operating our website securely
• Legal obligation (Article 6(1)(c)) - where we are required to retain data for tax or legal purposes

You may withdraw your consent at any time by contacting us at contact@ethirion.net. Withdrawal does not affect the lawfulness of processing before withdrawal.

4. Cookies and Tracking Technologies

Our website does not use cookies, web beacons, tracking pixels, or similar tracking technologies. We do not use analytics tools (such as Google Analytics), advertising trackers, or social media pixels.

Our hosting provider (Cloudflare) may use essential technical cookies necessary for the operation and security of the website. These are strictly necessary and cannot be disabled. They do not track you for advertising or profiling purposes.

5. Data Sharing and Third Parties

We do not sell, rent, or trade your personal data with any third party. We share data only in the following limited circumstances:

• Hosting provider - our website is hosted by Cloudflare, which may process technical data (IP address) for website operation and security
• Email provider - if you contact us via email, your message is processed by our email service provider to deliver and store correspondence
• Legal requirements - we may disclose data if required by law, court order, or competent authority

We do not use any third-party analytics, advertising SDKs, or tracking services. We do not share data with social networks, advertising networks, or data brokers.

6. Data Retention

We retain your personal data only as long as necessary for the purposes described in this policy:

• Contact form submissions - retained for the duration of the business correspondence and up to 12 months thereafter, unless you request earlier deletion
• Email correspondence - retained for up to 24 months for business and legal purposes
• Technical server logs - retained for up to 30 days by our hosting provider for security purposes

After the retention period, data is permanently deleted or anonymized. Data from our mobile applications is never retained on any server because it is stored only on the user's device.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

• SSL/TLS encryption for all website traffic (HTTPS)
• Access restricted to authorized personnel only
• Regular security reviews of our infrastructure
• Secure email providers with end-to-end encryption where available
• No storage of payment data - all transactions are processed by Apple or our payment provider

Despite these measures, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security but we strive to use commercially acceptable means to protect your data.

8. Your Rights (GDPR)

Under the GDPR, you have the following rights regarding your personal data:

• Right of access - you can request a copy of the personal data we hold about you
• Right to rectification - you can request correction of inaccurate or incomplete data
• Right to erasure - you can request deletion of your personal data ("right to be forgotten")
• Right to restrict processing - you can request that we limit the processing of your data
• Right to data portability - you can request your data in a structured, machine-readable format
• Right to object - you can object to processing based on legitimate interests
• Right to withdraw consent - you can withdraw consent at any time
• Right to lodge a complaint - you can file a complaint with your local data protection authority

To exercise any of these rights, contact us at contact@ethirion.net. We will respond within 30 days of receiving your request.

If you believe we have not handled your data appropriately, you have the right to lodge a complaint with the Polish data protection authority (UODO):

Urząd Ochrony Danych Osobowych
ul. Stawki 2, 00-193 Warszawa, Poland
Website: uodo.gov.pl

9. Children's Privacy

Our website and applications are not directed to children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will promptly delete it.

10. International Data Transfers

Our company is based in Poland (European Union). Your data is processed within the EU/EEA. Where our hosting or email provider processes data outside the EU, appropriate safeguards such as Standard Contractual Clauses are in place to ensure a level of data protection equivalent to the GDPR.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated policy on this page with a revised "Last updated" date. We encourage you to review this page periodically.

If we make material changes that significantly affect your rights, we will provide a prominent notice on our website or contact you directly if we have your email address.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

Ethirion Sp. z o.o.
ul. 3 Maja 23
42-400 Zawiercie, Poland
Email: contact@ethirion.net
NIP: 6492319502
REGON: 386642446