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. On the basis of the same consent we also use Microsoft Clarity (see section 4).

Inquiry form. If you fill in the form on this website, we store the information you provide: what the inquiry is about, dates, number of people, place, needs, description, full name, e-mail or phone, country, preferred language of contact and - if you provide it - how you heard about us, as well as the page from which you came to the form. The data is stored in our database on a server in Poland and sent as a notification to the info@sebir.pl mailbox. We use it only to answer your inquiry and prepare an offer - not for marketing.

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 browser storage. The site stores in your browser (localStorage) only your cookie choice with its date (key sebir_consent) and your light or dark theme (key sebir_theme). This does not require consent, because it only serves the choice you made. It is not used for tracking and is never sent anywhere.

Statistics (Google Analytics 4). These load only after you consent: the “Accept” button in the banner or the “Statistics” category switched on in the “Settings” window. They are off by default. The _ga and _ga_* cookies (Google Ireland Ltd.) are kept for up to 12 months.

Site usage analysis (Microsoft Clarity). In the same “Statistics” category, and only after you consent, we use Microsoft Clarity (Microsoft Ireland Operations Ltd.). Clarity creates aggregated click and scroll maps and recordings of how visits unfold, which show us what is unclear on the site. The content of form fields is masked and is not sent to Clarity. Cookies: _clck (up to 12 months) and _clsk (1 day); Microsoft may also use cookies from its own domains (clarity.ms, bing.com), such as CLID and MUID, for up to 12 months. Data may be transferred outside the EEA (to the USA) under standard contractual clauses and the EU-U.S. Data Privacy Framework.

Changing or withdrawing consent. At any time - the “Cookie settings” button in the footer of every page. Withdrawing consent deletes the Google Analytics and Microsoft Clarity cookies and stops measurement; it does not affect the lawfulness of measurement before withdrawal. Your choice is valid for 12 months - after that we ask again.

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 (WhatsApp) - when you contact us via WhatsApp, your phone number and messages are also processed by WhatsApp under its own privacy policy. If you prefer, write to us by e-mail. We do not use Meta advertising tools (e.g. the Facebook Pixel);
• SEOHOST.pl - the Polish hosting provider whose servers run this website and the info@sebir.pl mailbox;
• GitHub (GitHub Inc., Microsoft) - a private, non-public repository with a copy of the website and internal company documentation, which may contain information about cooperation with business clients (e.g. names of organizations and contact persons). Data from the inquiry form is not stored there.

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 (a setting of our Google Analytics 4 account).

Inquiries that did not lead to a contract (including inquiries from the form) are deleted no later than 24 months after the last contact.

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.

Only the SEBIR team has access to form inquiries, through a password-protected panel. We do not store IP addresses - for spam protection we use a one-time encrypted identifier that is deleted after 24 hours.

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.