We are serious about protecting your data.

# 1: Who is the administrator of your personal data?

The administrator of your personal data is Pawel Malenczak, conducting business activity under the company name "PROJECT SCOPE Pawel Malenczak," ul. Bonifraterska 17, 00-203 Warsaw, Poland, NIP/VAT-EU: 7481543521.

# 2: Who can you contact regarding the processing of your personal data?

As part of implementing personal data protection in our company, we have decided not to appoint a Data Protection Officer since it is not mandatory in our case. For matters related to personal data protection and privacy, you can contact us via email at hello@projectscope.eu.

# 3: What information do we have about you?

Depending on the purpose, we may process the following information about you:

• First and last name
• Residential address
• Business address
• Tax identification number/VAT-UE
• Email address
• Phone number
• Data included in email correspondence
• Bank account number
• IP address
• Approximate location

The scope of processed data has been described precisely in relation to each processing purpose. More information on this is provided later in this privacy policy. Furthermore, we use tools that collect various information about you related to your use of our website. This includes:

• Information about the operating system and internet browser
• Visited subpages
• Time spent on the website
• Transitions between individual subpages
• Clicks on specific links
• The source from which you access the website
• Age range
• Gender
• Approximate location limited to the locality
• Your interests determined based on online activity

These pieces of information are referred to as "Anonymous Information" in this privacy policy. Anonymous Information does not, by itself, constitute personal data because it does not allow us to identify you, and we do not link it to typical personal data that we collect about you. Nevertheless, considering the strict case law of the Court of Justice of the European Union, we have included detailed explanations regarding the processing of this information in this privacy policy.

Since Anonymous Information is collected by external tools we use (Google Analytics), it is also processed by the providers of these tools according to their terms and privacy policies.

Anonymous Information is used for analytical and statistical purposes. It is also used by providers of specific tools to provide and improve services, manage them, develop new services, measure the effectiveness of advertisements, protect against fraud and abuse, and personalize content and ads displayed on various services, websites, and applications.

# 4: Where do we get your personal data from?

In most cases, you provide your data to us yourself. This happens when you:

• Browse our website
• Contact us via email
• Follow our social media profiles
• Interact with content we publish on social media

Additionally, some information about you may be automatically collected by the tools we use:

• The website's mechanism collects your IP address
• Google Analytics collects Anonymous Information related to your actions on the website.

# 5: Are your data safe?

We take the security of your personal data seriously. We have analyzed the risks associated with various data processing processes and implemented appropriate security measures and data protection. We continually monitor the state of the technical infrastructure, train the staff, review relevant procedures, and introduce necessary improvements. If you have any questions about your personal data, we am available at hello@projectscope.eu.

# 6: For what purposes do we process your personal data?

There are several purposes for processing your data. Here is a list of them, followed by more detailed explanations. Each processing purpose is associated with specific legal grounds for processing:

• Handling communication (emails, communication tools / apps) – Article 6(1)(f) of the GDPR
• Fulfillment of tax and accounting obligations – Article 6(1)(f) of the GDPR
• Social media management – Article 6(1)(f) of the GDPR
• Analysis and statistics (only Anonymous Information) – Article 6(1)(f) of the GDPR

Handling communication (emails, communication tools / apps) – Details:

When you contact us via email or online communication tools/apps, you naturally provide your personal data included in the content, including but not limited to your email address, handle and/or first and last name. Providing this data is voluntary but necessary to establish contact. Your data in this case is processed for the purpose of communication with you, and the legal basis for processing is Article 6(1)(f) of the GDPR.

The legal basis for processing after the contact has ended is also our legitimate interest in the form of archiving correspondence for the purpose of being able to demonstrate specific facts in the future (Article 6(1)(f) of the GDPR). The content of the correspondence may be subject to archiving, and we cannot definitively specify when it will be deleted.

You have the right to request the history of correspondence with us (if it has been archived), which may contain your personal data. This will also allow you to receive a copy of your data from me.

Fulfillment of tax and accounting obligations – Details:

We process your personal data to the extent and for the purpose necessary to fulfill the tax and accounting obligations imposed on us by law. In this case, the legal basis for processing is Article 6(1)(c) of the GDPR in connection with tax and accounting regulations.

In addition, the data is also processed for our legitimate interest in the form of archiving documents for the purpose of being able to demonstrate specific facts in the future (Article 6(1)(f) of the GDPR). The content of the documents may be subject to archiving, and we cannot definitively specify when it will be deleted.

Social media management – Details:

We process your personal data to the extent and for the purpose necessary to manage our social media profiles. This includes data provided voluntarily, e.g., in comments and in your profile. Providing this data is voluntary but necessary to participate in social media activities, e.g., commenting on entries or sending messages. The legal basis for processing is Article 6(1)(f) of the GDPR.

Analysis and statistics (only Anonymous Information) – Details:

We process Anonymous Information for analytical and statistical purposes. Anonymous Information is not personal data. The legal basis for processing is Article 6(1)(f) of the GDPR.

# 7: Who can we pass your data to?

In certain situations, we may transfer your data to third parties, but only to the extent and for the purpose necessary for the proper execution of the service. we may share your personal data with the following categories of recipients:

• Entities providing IT and hosting services
• Entities providing online communication services
• Entities providing accounting and legal services
• Entities providing analytical and statistical services
• Entities providing payment services
• Entities providing debt collection services

If we are legally obliged to do so, we may also disclose your data to authorized state authorities. we will also disclose your data to authorized state authorities if this is necessary for the establishment, exercise, or defense of legal claims.

Furthermore, when it comes to Anonymous Information, access to them is available to providers of tools that collect Anonymous Information. These tool providers are independent data controllers for the information they gather and may share this data according to their own terms and privacy policies, over which we have no control.

# 8: How long will we process your data?

Your personal data will be processed for the period necessary to achieve the purposes for which they were collected. After this period, your data will be deleted. The exact retention period may vary depending on the purpose of processing and the nature of the data.

Handling communication:

We will process your data until the end of communication with you, and in the case of correspondence archiving for the purposes of potential defense, establishment, or pursuit of claims, the data will be processed indefinitely for our legitimate interest.

Fulfillment of tax and accounting obligations:

We will process your data for the period necessary to fulfill the tax and accounting obligations imposed on us by law, and in the case of archiving documents for the purposes of potential defense, establishment, or pursuit of claims, the data will be processed for the time necessary to fulfill the obligation imposed on us by law.

Social media management:

We will process your data for the duration of our activity on social media. If your data is processed by the administrators of social media websites, the retention period may vary and depend on their rules.

Analysis and statistics (only Anonymous Information):

Anonymous Information will be processed for analytical and statistical purposes for the time necessary to achieve these purposes.

# 9: What are your rights?

You have several rights related to the processing of your personal data. These rights include:

• The right to access your personal data
• The right to rectify your personal data
• The right to erase your personal data
• The right to restrict the processing of your personal data
• The right to data portability
• The right to object to the processing of your personal data
• The right to withdraw your consent to the processing of personal data, if applicable

You can exercise your rights by sending a relevant request to hello@projectscope.eu. We will respond to your request as soon as possible, but no later than within one month of receiving it. If necessary, due to the complexity of the request or the number of requests, we may extend this period by two months, about which we will inform you.

If you believe that your personal data is being processed unlawfully, you have the right to lodge a complaint with the President of the Personal Data Protection Office in Poland https://uodo.gov.pl/en.

# 10: Do we process your data automatically for purposes of profiling?

No.

# 11: Do we transfer your data to third countries or international organizations?

We do not transfer your personal data to countries outside the European Union (so-called third countries) or international organizations.

# 12: Do we use cookies, and what are they exactly?

Cookies are small text information stored on your end device (e.g., computer, tablet, smartphone) that can be read by our teleinformatics system (first-party cookies) or third-party teleinformatics systems (third-party cookies). Specific information may be saved and stored in cookies, which teleinformatics systems can later access for specific purposes. Some of the cookies we use are deleted after you close your web browser session (session cookies). Others are stored on your end device and allow your browser to be recognized when you revisit the site (persistent cookies).

# 13: On what basis do we use cookies?

We use cookies based on your consent, except in cases where cookies are necessary for the proper provision of an electronic service to you. Cookies that are not essential for providing an electronic service remain blocked until you give your consent to use them. During your first visit to our website, we display a message asking for your consent and providing you with options to manage cookies, i.e., decide which cookies you accept and which you want to block. Please note that disabling or limiting cookie support may prevent you from using some of the features available on our website, as well as other websites that use cookies.

# 14: Can you disable cookies?

Yes, you can manage cookie settings within your web browser. You can block all or select cookies, as well as block cookies from specific websites. You can also delete previously stored cookies and other website data at any time. Web browsers also offer incognito mode, which you can use if you do not want information about visited websites and downloaded files to be saved in your browsing and download history. Cookies created in incognito mode are deleted when you close all windows of that mode.

Browser extensions are also available that allow you to control cookies, such as Ghostery, and additional software, especially antivirus packages, may offer cookie control options. Additionally, there are online tools available that enable you to control certain types of cookies, particularly for managing behavioral advertising settings.

We also provide you with the ability to control cookies directly from our website. We have implemented a special cookie management mechanism that allows you to block cookies.

# 15: What are the purposes of our own cookies?

Our own cookies are used to ensure the proper functioning of various website mechanisms, such as ensuring the proper transmission of forms visible on the website. Our own cookies also store information about the cookie settings you have defined from the cookie management mechanism.

# 16: What third-party cookies are used?

The following third-party cookies are used on our website:

• Google Analytics

Details about individual third-party cookies are described below.

Google Analytics – Details

We use the Google Analytics tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. We implement these actions based on our legitimate interest, which involves creating statistics and analyzing them to optimize the website. To use Google Analytics, we have implemented special tracking code in the website's code.

The tracking code uses cookies from Google LLC related to the Google Analytics service. You can block Google Analytics tracking code at any time by installing a browser add-on provided by Google. Google Analytics automatically collects information about your use of the website. The information collected is often sent to Google servers, which may be located worldwide, and stored there.

Due to the anonymization of the IP address activated by me, your IP address is shortened before further transmission. In exceptional cases, the full IP address is sent to Google servers and then shortened. The anonymized IP address transmitted by your browser as part of Google Analytics is generally not linked to other Google data. I want to emphasize that We do not collect any data through Google Analytics that would allow for your identification. Therefore, the data collected through Google Analytics is not considered personal data.

The information we have access to through Google Analytics includes, in particular: information about the operating system and web browser, the pages you visit, time spent on the website and its individual pages, transitions between individual pages, the source from which you came to our website, and your approximate location limited to the city.

Google Analytics and Google Analytics 360 services have obtained the ISO 27001 independent security standard certificate. ISO 27001 is one of the most widely recognized standards in the world and certifies compliance with the relevant requirements for systems that support Google Analytics and Google Analytics 360. If you are interested in details related to Google's use of data from websites and applications using Google services, we encourage you to review that information.

# 17: Do we track your behavior on our website?

Yes, we use Google Analytics tools, which involve collecting information about your activity on our website. These tools have been described in detail in the question about third-party cookies, so we will not repeat that information here.

# 18: How can you manage your privacy?

The answer to this question is found in various places in this privacy policy, especially when describing specific tools, cookie consent, etc. Nevertheless, for your convenience, We have summarized this information in one place below. Here is a list of options for managing your privacy:

• Cookie settings in your web browser
• Browser plugins that support cookie management, e.g., Ghostery
• Additional software for managing cookies
• Incognito mode in your web browser
• Cookie settings directly from our website

# 19: What are server logs?

Using the website involves sending queries to the server on which the website is stored. Each query directed to the server is recorded in server logs. The logs include, among other things, your IP address, server date and time, information about the web browser, and operating system you are using. The logs are saved and stored on the server.

Data stored in server logs is not associated with specific individuals using the website, and We do not use it to identify you. Server logs serve as auxiliary material for administering the website, and their contents are not disclosed to anyone other than authorized individuals responsible for server administration.

# 20: Do we update this Privacy Policy?

We are constantly working on improving and expanding our services, which is why we may introduce new or change existing functionalities or update this Privacy Policy. Updated Privacy Policy will always be available on the website.

# 21: How can you contact us?

You can contact us at hello@projectscope.eu regarding any issues related to your personal data or this Privacy Policy.