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Privacy policy

This policy explains what personal data we process when you visit vistulacode.com, contact us or discuss a project with us, why we do it, and what rights you have.

  1. Who is responsible for your data

    The controller of your personal data is Michał Araszkiewicz, running a business under the name VistulaCode Michał Araszkiewicz, al. Jana Pawła II 43a lok. 37b, 01-001 Warszawa, Poland, NIP 5311590360, REGON 141677609 ("VistulaCode", "we", "us").

    For anything related to your personal data, write to hello@vistulacode.com or to the postal address above. We have not appointed a data protection officer, as the law does not require us to.

  2. What this policy covers

    This policy covers the website vistulacode.com, its contact form, and email correspondence with us about potential or ongoing work.

    When we build AI systems for clients, we may process personal data contained in client data on the client's behalf. That processing is governed by our contract and data processing agreement with the client, not by this policy.

  3. Who receives your data

    We use the following service providers. Where they act as our processors, they process data only on our instructions under data processing terms:

    • Cloudflare, Inc. (USA) — website hosting, content delivery, network security, and delivery of contact form messages to our mailbox (Cloudflare Email Service).
    • Microsoft Ireland Operations Limited (Ireland) — Microsoft 365 email hosting for our mailbox, where inquiries and correspondence are stored.
    • Google Ireland Limited (Ireland) and Google LLC (USA) — Google Analytics, only if you consent, and Google reCAPTCHA on the contact page. For reCAPTCHA, Google processes data under its own Privacy Policy and Terms of Service.
    • OpenAI Ireland Limited (Ireland) and its affiliates, including in the USA — the ChatGPT ads measurement pixel, only if you consent. We and OpenAI may be joint controllers for collecting this data on our site and sending it to OpenAI. OpenAI's own use of it, for example to measure and improve ads, is governed by OpenAI's privacy policy.
    • Accounting, legal and IT service providers we work with, where needed for the purposes above.

    We may also disclose data to public authorities when the law requires it. We do not sell personal data. With your consent, OpenAI receives the ads measurement data described above; we do not share the contents of your inquiry with any advertising service.

  4. Transfers outside the European Economic Area

    Cloudflare, Google and OpenAI may process data in the United States. Cloudflare and Google are certified under the EU–U.S. Data Privacy Framework, which the European Commission found to provide an adequate level of protection (decision of 10 July 2023). Where a transfer is not covered by that framework, our providers rely on the European Commission's standard contractual clauses. OpenAI relies on adequacy decisions and standard contractual clauses, as described in its privacy policy.

    Microsoft stores our Microsoft 365 data in the EU, but some processing, such as support or security operations, may involve transfers protected by the same mechanisms.

  5. Cookies, analytics and ads measurement

    Analytics and ads measurement each run only if you allow them in the cookie banner. You can change your choice at any time through "Cookie settings" in the site footer. Details of every cookie and storage item we use are in the cookie policy.

  6. Your rights

    Under the GDPR you have the right to:

    • access your data and receive a copy of it (Art. 15);
    • have inaccurate data corrected (Art. 16);
    • have your data erased (Art. 17);
    • restrict processing (Art. 18);
    • receive your data in a portable format, where processing is based on consent or a contract and carried out by automated means (Art. 20);
    • object at any time to processing based on our legitimate interests, on grounds relating to your particular situation (Art. 21);
    • withdraw consent at any time, without affecting the lawfulness of processing before the withdrawal.

    To exercise your rights, write to hello@vistulacode.com. We will respond within one month; in complex cases this can be extended by up to two further months, and we will tell you if it is. We may ask you to confirm your identity.

    You also have the right to lodge a complaint with a supervisory authority. In Poland this is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl. You can also contact the authority in the EU country where you live or work.

  7. Automated decisions

    We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects. Google reCAPTCHA automatically assesses whether a form submission looks automated, and a submission with a very low score is not delivered. If your message is blocked, email us directly at hello@vistulacode.com.

  8. How we protect your data

    The site is served only over encrypted connections (HTTPS). Access to inquiries and correspondence is limited to the people who handle them. Form submissions are sent to our mailbox and are not stored in a separate database on the website.

  9. Children

    This website is intended for businesses. It is not directed at children, and we do not knowingly collect data from anyone under 16.

  10. Changes to this policy

    We will update this policy when our processing changes. The date at the top shows when the current version took effect. If a change significantly affects how we use data you have already given us, we will tell you directly where we can.