Privacy Policy

The controller of your personal data is PROGRESS-CONSULTING EESTI OÜ, registered at Astangu 60-32, 13519 Tallinn, Estonia, VAT: EE 100923281, registry number: 11057026 - the entity providing services under the SEBIR brand and concluding contracts with SEBIR clients.

For all matters relating to personal data protection, you can contact us at info@sebir.pl.

Data provided voluntarily. When you contact us via WhatsApp, email, or otherwise, we process the data you provide - e.g. your name, contact details, the content of your inquiry, and information about your planned stay or group. We use this only to respond to your inquiry and prepare an offer or deliver a service.

Data collected automatically. After you consent to analytics cookies, we use Google Analytics (GA4), which collects anonymized visit statistics (e.g. number of page views, traffic source, device) - this is not used to directly identify you.

We process your data on the basis of:

• Article 6(1)(b) GDPR - where processing is necessary to take steps before entering into a contract or to perform one (e.g. preparing an offer, delivering a service);
• Article 6(1)(a) GDPR - your voluntary consent (e.g. to analytics cookies);
• Article 6(1)(f) GDPR - our legitimate interest (e.g. responding to an inquiry, pursuing claims).

Essential cookies. These remember your choice of site language and your cookie consent decision. They are always active and don't require consent, since the site wouldn't work properly without them.

Analytics cookies (Google Analytics). These load only after you click "Accept" in the cookie banner. You can withdraw your consent at any time by clearing your browser data for this site.

We do not sell or share your personal data with third parties for marketing purposes. Data may only be shared with trusted service providers who help us run the site and communicate with you:

• Google Ireland Limited / Google LLC - as part of the Google Analytics (GA4) service, with appropriate legal safeguards for transferring data outside the European Economic Area (European Commission standard contractual clauses);
• Meta Platforms Ireland Limited - if in the future we launch tools such as the Facebook Pixel for advertising purposes (currently inactive).

We keep data from inquiries for as long as necessary to respond and deliver the service, and afterwards for the statute-of-limitations period for potential claims (standardly up to 6 years, under Polish Civil Code).

Data collected by Google Analytics is retained for 14 months from the last activity by default, in line with Google Analytics 4's default settings.

Under the GDPR, you have the right to:

• access your data and obtain a copy of it;
• rectify (correct) your data;
• erasure ("the right to be forgotten");
• restrict processing;
• data portability;
• object to processing;
• withdraw consent at any time (without affecting the lawfulness of processing carried out before withdrawal);
• lodge a complaint with a supervisory authority - in Poland this is the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, Poland.

To exercise any of the above rights, write to us at info@sebir.pl.

We apply appropriate technical and organizational measures to protect your data from unauthorized access, loss, or destruction - including an encrypted connection (HTTPS) and limited access to data, restricted to those who need it to deliver the service.

We may periodically update this policy, for example as our services evolve (including new marketing tools) or as regulations change. The date of the last update appears at the top of this document. We encourage you to check it from time to time.

For matters relating to personal data protection and this privacy policy, contact us at info@sebir.pl.