1. Data controller
The controller of your personal data is NEW PROJECT Andrzej Brzeziński, ul. Adama Mickiewicza 4/8, 19-300 Ełk, Poland, VAT ID PL8481164296. For matters concerning personal data write to office@newproject360.pl.
2. What data and for what purpose
In connection with the newsletter we process:
- the e-mail address - to send you the newsletter,
- the chosen language (Polish or English) - to send the issue in the right version,
- the subscription and confirmation dates and a confirmation flag - to demonstrate that the subscription was consented to and confirmed,
- the IP address and the time of subscription - to a minimal extent, for two purposes: form security (limiting abuse and automated submissions) and as part of the evidence of consent.
We do not collect your name, company or job title. We do not profile recipients and we do not make automated decisions about them producing legal effects.
3. Legal basis
The legal basis depends on the purpose of the processing.
- Sending the newsletter - your consent, Article 6(1)(a) of the GDPR (Regulation (EU) 2016/679 of the European Parliament and of the Council). You give consent by ticking the consent box on subscription and confirming with a link. The newsletter is commercial information within the meaning of the Polish Act on the provision of electronic services (consolidated text, Journal of Laws 2024 item 1513), and sending it to the given e-mail address requires the consent referred to in Article 398(1) of the Act of 12 July 2024 - Electronic Communications Law (Journal of Laws item 1221).
- Form security and evidence of consent (the IP address and time of subscription) - our legitimate interest, Article 6(1)(f) of the GDPR, in protecting the service against abuse and being able to demonstrate that consent was given. You may object to this processing at any time.
4. Retention period
Subscription data (the e-mail address and chosen language) is kept until consent is withdrawn, that is until you unsubscribe. After unsubscribing we delete the entire record: the address, the language, the dates and the evidence of consent together with the IP address. Nothing is left, including anything that would let us recognise you if you subscribe again. We chose this over keeping the evidence of consent for the limitation period, which the law would allow, because withdrawing consent removes the basis for processing, and less data means less risk for you. The consequence falls on us: once you unsubscribe, we no longer hold anything to show that the subscription was made with your consent. A subscription not confirmed within seven days is deleted automatically.
5. Recipients of the data
We do not sell the data and do not share it for marketing purposes. We entrust it to a single entity: the provider of hosting and mail for this service (Hostinger), which maintains the server, the recipient database and the sending mailbox office@newproject360.pl, under a data processing agreement and to the extent necessary for the service to work. The server holding the subscriber list is located within the European Economic Area. We do not use external analytics tools or a separate bulk-sending system.
Two things, however, happen outside that server, and they have to be named plainly, because otherwise this description would be untrue.
- Pages are served by Hostinger's content delivery network (CDN). The node serving this site is in Frankfurt, that is, within the European Economic Area. The CDN sees the visitor's IP address and standard request data, because it could not deliver the page without them. We collect no statistics through it and do not link that data to the subscriber list.
- Mail leaves through the provider's relay server (MailChannels). Its infrastructure sits outside the EEA, including in the United States. Your e-mail address and the content of the message therefore pass through that server on the way to you. The provider supplies the legal basis for this transfer under its data processing agreement; for details write to office@newproject360.pl.
Both are part of the hosting infrastructure rather than separate marketing tools: they exist so that the page opens and the message arrives.
6. Your rights
You have the right to: access your data, rectify it, erase it, restrict processing, data portability and to object. You also have the right to withdraw consent at any time, which does not affect the lawfulness of processing before withdrawal. The simplest way to withdraw consent is the unsubscribe link in the message. You also have the right to lodge a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw, Poland).
7. Cookies and logs
The site is static and uses no cookies for tracking or analytics. Remembering the chosen light or dark theme happens in the browser's memory (localStorage) and is not sent to the server. The server, like any web server, may keep standard access logs (IP address, request time) for security and diagnostics; these logs are not combined with the subscriber list for marketing purposes.