Privacy Policy

Last updated: 29 April 2026

This Privacy Policy sets out the rules for the processing of personal data of Users of the website seminars.alex666cold.com (the "Service") in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR") and the Polish Act of 10 May 2018 on the Protection of Personal Data (Dz.U. 2018 poz. 1000).

§ 1. Controller

The Controller of personal data within the meaning of Article 4(7) GDPR is:

Alex Vasilevko, conducting sole-proprietorship business activity registered in the Polish Central Register and Information on Economic Activity (CEIDG), with the following identifiers:

• NIP (Tax Identification Number): 7972058054
• REGON (National Business Registry Number): 365012977
• Principal PKD activity code: 96.99.Z
• Place of business: Wrocław, Republic of Poland

Contact with the Controller in matters relating to the processing of personal data is possible via:

• WhatsApp: +48 531 609 827
• Telegram: @alex666cold

§ 2. Categories of personal data processed

In connection with the User's use of the Service and the lead-magnet form located thereon, the Controller processes the following categories of personal data:

• e-mail address provided by the User in the form;
• declaration (or absence thereof) of consent to receive marketing communication;
• technical data: IP address, user-agent string of the browser, locale (en/ru);
• marketing identifiers: UTM parameters of the source link, identifiers of analytical and advertising cookies (_ga, _fbp, _fbc) — only after the User's consent;
• aggregated behavioural data collected via Google Analytics 4 (measurement identifier G-267DEDP3FZ) — only after the User's consent.

§ 3. Purposes and legal bases of processing

The Controller processes personal data for the following purposes and on the following legal bases:

1. Delivery of the lead-magnet PDF and entry of the User onto the early-access list for upcoming online seminars — pursuant to Article 6(1)(b) GDPR (steps taken at the request of the data subject prior to entering into a contract).
2. Sending marketing communication about the launch of the seminars and related materials — pursuant to Article 6(1)(a) GDPR (consent expressed by ticking the appropriate checkbox in the form). Consent may be withdrawn at any time, without affecting the lawfulness of processing carried out before its withdrawal.
3. Use of analytical and marketing cookies — pursuant to Article 6(1)(a) GDPR (consent expressed via the cookie banner) and the Polish Act of 16 July 2004 — Telecommunications Law (Article 173).
4. Maintaining the security of the Service, prevention of abuse, rate-limiting and recording of operational logs — pursuant to Article 6(1)(f) GDPR (legitimate interests of the Controller consisting in ensuring the operational security of the Service).

§ 4. Recipients of personal data

The Controller entrusts the processing of personal data to the following entities (data processors within the meaning of Article 28 GDPR):

• Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA — hosting infrastructure (Cloudflare Pages, Workers, D1, R2), bot-protection (Turnstile). Data may be transferred outside the European Economic Area on the basis of Standard Contractual Clauses adopted by the European Commission.
• Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland — analytical service Google Analytics 4 with IP-truncation enabled.
• Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland — Meta Pixel for measurement of advertising effectiveness.

§ 5. Retention period

• E-mail address and the marketing-consent declaration — until the consent is withdrawn or until a request for erasure is made;
• IP address and user-agent — 90 days from the date of collection, after which the data is automatically irreversibly anonymised;
• Aggregated analytical data in Google Analytics 4 — 14 months (system default);
• Encrypted backup copies of the database — 30 days, stored locally with end-to-end age encryption, not transferred to third parties.

§ 6. Rights of the data subject

In connection with the processing of personal data, the User shall have the following rights:

• right of access to data — Article 15 GDPR;
• right to rectification — Article 16 GDPR;
• right to erasure ("right to be forgotten") — Article 17 GDPR;
• right to restriction of processing — Article 18 GDPR;
• right to data portability — Article 20 GDPR;
• right to object — Article 21 GDPR;
• right to withdraw consent at any time — Article 7(3) GDPR.

Each marketing message sent by the Controller contains an individual unsubscribe link with an HMAC token, the activation of which results in the immediate erasure of the User's data from the marketing database.

Requests for the exercise of any of the above rights should be addressed to the Controller via the channels indicated in § 1. The Controller shall respond within 30 days from the date of receipt of the request.

§ 7. Right to lodge a complaint with a supervisory authority

The User has the right to lodge a complaint with the supervisory authority for personal data protection in the Republic of Poland:

Prezes Urzędu Ochrony Danych Osobowych
ul. Stawki 2, 00-193 Warszawa
uodo.gov.pl

§ 8. Voluntary nature of providing data

Provision of personal data is voluntary, however non-provision of an e-mail address makes it impossible to deliver the requested lead-magnet PDF and to receive notification of the launch of the seminars.

§ 9. Cookies and Google Consent Mode v2

The Service uses three categories of cookies: necessary (the operation of the form), analytical (Google Analytics 4) and marketing (Meta Pixel). Pursuant to Article 173 of the Polish Telecommunications Law, analytical and marketing cookies are activated only after the User's consent expressed via the cookie banner.

The Service implements the Google Consent Mode v2 mechanism with default consent state denied for Users from the European Economic Area and the United Kingdom.

§ 10. Automated decision-making

Personal data is not subject to automated decision-making, including profiling within the meaning of Article 22 GDPR.

§ 11. Amendments to the Privacy Policy

The Controller reserves the right to amend this Privacy Policy. The current version is always available at the URL seminars.alex666cold.com/legal/privacy. The date of the last amendment is indicated at the top of the document.

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