PRIVACY POLICY

This Privacy Policy sets out the principles governing the collection, processing, storage and protection of personal data by Lead Creators LTD, a company established and operating under the laws of the Republic of Poland, in connection with the operation of its website and the provision of digital marketing services. The processing of personal data is carried out in accordance with applicable legal provisions, including 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 (General Data Protection Regulation – GDPR) as well as the Polish Personal Data Protection Act of 10 May 2018.

This Privacy Policy applies to all personal data processed in connection with the use of the website, communication initiated through the website, requests for marketing services, and other interactions between users and the Company. By accessing the website or submitting personal information through any communication channel available on the website, users acknowledge that their personal data may be processed in accordance with the terms described in this Privacy Policy.

1. Data Controller
The controller of personal data within the meaning of Article 4(7) of the GDPR is Lead Creators LTD, with its registered business address at ul. SZLAK 77, lok. 222, 31-153 Kraków, Poland, registered under company number 6772464686.
The Company determines the purposes and means of processing personal data obtained through the website and related communication channels. In matters concerning the processing of personal data, users may contact the Company via email at lead.creators.spzoo@gmail.com or by using the contact details published on the website.

2. Scope of Application
This Privacy Policy applies to the processing of personal data obtained through the Company’s website, including data provided by users when submitting inquiries through contact forms, requesting consultations or marketing services, communicating with the Company via email or other electronic means, or otherwise interacting with the website.
The website is intended primarily for entrepreneurs, business entities and individuals interested in digital marketing services provided by the Company. The Company does not intentionally collect personal data from persons under the age of eighteen and requests that such persons refrain from providing personal data through the website.

3. Categories of Personal Data Processed
In connection with the operation of the website and the provision of digital marketing services, the Company may process personal data voluntarily provided by users. Such data may include identification data such as the user’s name, surname, professional role or business affiliation, as well as contact information including email address, telephone number and the content of messages submitted through contact forms or electronic correspondence.
Where users submit inquiries regarding digital marketing services, the Company may also process information related to the user’s business activity, marketing objectives, requested services, project details or other information provided for the purpose of evaluating potential cooperation.
In addition, certain technical and usage data may be collected automatically when users access the website. Such data may include the user’s IP address, browser type and version, operating system, device type, referral URLs, session identifiers and information relating to the user’s interaction with the website. These data are used solely for technical administration, security monitoring and analytical purposes.

4. Purposes of Data Processing
Personal data are processed for purposes related to the operation of the website and the provision of services offered by the Company. In particular, personal data may be processed in order to respond to inquiries submitted through the website, establish and maintain communication with potential clients, prepare marketing proposals, provide digital marketing services including online advertising management, social media marketing, search engine optimization, strategic marketing consulting and analytics services, as well as to ensure the proper functioning, maintenance and security of the website.
Personal data may also be processed for analytical purposes in order to monitor website performance, analyze user behavior and improve the quality and effectiveness of the services offered by the Company.
Furthermore, personal data may be processed where necessary to comply with legal obligations imposed on the Company under applicable law or to protect the legitimate interests of the Company, including the prevention of fraud, protection of IT infrastructure, safeguarding of legal claims and ensuring the security of the website.

5. Legal Basis for Processing
Personal data are processed in accordance with Article 6 of the GDPR. Processing may be based on the necessity to take steps at the request of the data subject prior to entering into a contract or for the performance of a contract to which the data subject is a party. Processing may also be based on the legitimate interests pursued by the Company, in particular in relation to maintaining business communication, ensuring the security and functionality of the website, improving the quality of services and protecting the Company’s legal interests.
Where required by applicable law, personal data may be processed on the basis of the user’s consent. In such cases the user has the right to withdraw consent at any time without affecting the lawfulness of processing carried out prior to the withdrawal of consent.
Processing may also be carried out where it is necessary for compliance with legal obligations applicable to the Company under European Union or Polish law.

6. Recipients of Personal Data
Personal data may be disclosed to entities cooperating with the Company where such disclosure is necessary for the operation of the website or the provision of services. These entities may include providers of hosting services, IT infrastructure providers, website maintenance providers, analytics service providers, marketing technology platforms, as well as professional advisers such as legal or accounting consultants.
Where third parties process personal data on behalf of the Company, such processing is carried out on the basis of appropriate data processing agreements concluded in accordance with Article 28 of the GDPR and ensuring adequate safeguards for the protection of personal data.
The Company does not sell, rent or otherwise commercially exploit personal data provided by users.

7. International Transfers of Personal Data
In certain circumstances personal data may be transferred to entities located outside the European Economic Area. Where such transfers occur, the Company ensures that appropriate safeguards are implemented in accordance with the GDPR. Such safeguards may include the use of standard contractual clauses adopted by the European Commission or reliance on adequacy decisions issued by the European Commission where applicable.

8. Data Retention
Personal data are retained only for the period necessary to fulfill the purposes for which they were collected. Data related to business inquiries may be retained for the period necessary to respond to the inquiry and maintain business communication. Data related to contractual relationships may be retained for the duration of the contract and for the period required by applicable accounting, tax or civil law regulations.
Where necessary, personal data may be retained for longer periods in order to establish, exercise or defend legal claims or to comply with legal obligations imposed on the Company.

9. Data Security
The Company implements appropriate technical and organizational measures designed to ensure a level of security appropriate to the risks associated with the processing of personal data. These measures are intended to protect personal data against unauthorized access, accidental loss, destruction, alteration or disclosure.
Such measures may include secure server infrastructure, controlled access to data within the organization, internal procedures governing the processing of personal data and the use of secure communication protocols where applicable.
Despite the implementation of appropriate safeguards, the transmission of data over the internet may not be completely secure and the Company cannot guarantee absolute security of data transmitted through the website.

10. Cookies and Similar Technologies
The website may use cookies and similar technologies to ensure the proper functioning of the website, analyze website traffic and improve user experience. Cookies may collect certain information relating to user interaction with the website and may be used for analytical or technical purposes.
Detailed information regarding the use of cookies is provided in the separate Cookie Policy available on the website.

11. Rights of Data Subjects
Persons whose personal data are processed by the Company have the rights provided under the GDPR, including the right to obtain confirmation as to whether their personal data are being processed, the right to access personal data, the right to request rectification or erasure of personal data, the right to restrict processing, the right to object to processing and the right to data portability where applicable.
Where processing is based on consent, the data subject has the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.
Data subjects also have the right to lodge a complaint with the competent supervisory authority responsible for data protection.

12. Supervisory Authority
In Poland the supervisory authority responsible for personal data protection is the President of the Personal Data Protection Office.
Urząd Ochrony Danych Osobowych
ul. Stawki 2
00-193 Warszawa
Poland
https://uodo.gov.pl

13. Third-Party Websites
The website may contain links to websites operated by third parties. The Company does not control such websites and is not responsible for their privacy practices. Users are encouraged to review the privacy policies of external websites before providing personal data.

14. Amendments to the Privacy Policy
The Company reserves the right to amend this Privacy Policy where necessary in order to reflect changes in applicable legal provisions, technological developments or modifications in the Company’s business activities. The most current version of the Privacy Policy will always be available on the website.

15. Contact Information
Any questions regarding this Privacy Policy or the processing of personal data may be directed to the Company at:
Lead Creators LTD
ul. SZLAK 77, lok. 222
31-153 Kraków
Poland
Email: lead.creators.spzoo@gmail.com
Phone: +48 579 610 845