Privacy Policy
1. Introduction
This Privacy Policy explains how Aleksandra Kubicka, conducting business under the trade name Clean Culture Aleksandra Kubicka, operating as Taanto, a sole proprietorship registered in Poland ("Controller", "we", "our", "us"), processes personal data in connection with:
- our website located at taanto.ai
- consulting and advisory services provided by the Controller
- communication with users, customers, and prospective customers
- free materials and marketing communication
- bookings and consultation requests
We process personal data in accordance with Regulation (EU) 2016/679 (GDPR) and the Polish Personal Data Protection Act of 10 May 2018.
2. Data Controller
The controller of personal data described in this Privacy Policy is:
Aleksandra Kubicka, conducting business under the trade name Clean Culture Aleksandra Kubicka, operating as Taanto
NIP: 5842677326
ul. Góralska 67/2
80-292 Gdańsk, Poland
Contact email: [email protected]
3. Roles in Data Processing
When individuals interact with our website, download free materials, contact us, submit inquiries, or book consultations, the Controller acts as the data controller.
In the course of providing consulting and advisory services, the Controller may gain access to personal data held by the client organization. In such cases, the Controller acts as a data processor on behalf of the client. The scope and terms of such processing are governed by a separate data processing agreement.
4. Categories of Personal Data
Depending on how you interact with us, we may process the following categories of personal data:
- name, email address, phone number, company name, job title, message content
- booking details and service-related communication
- social media username, publicly available profile information, messages and interactions
- technical data: IP address, browser type, device information, operating system, language settings, approximate location, pages viewed, clicks, session data, cookie identifiers, timestamps
5. Purposes of Data Processing
We may process personal data for the following purposes:
- providing and operating our website
- responding to inquiries and maintaining correspondence
- providing consulting and advisory services
- providing free materials and downloadable resources
- sending marketing communication
- managing bookings, meetings, and consultations
- providing customer support
- sending service-related communication to users
- maintaining and operating our social media presence
- analyzing website traffic and user behavior
- improving our website, services, and communication
- ensuring security, reliability, and integrity of the website and related services
- complying with legal obligations
6. Legal Basis for Processing
We process personal data based on the following legal grounds under Article 6 GDPR.
6.1 Performance of a Contract - Art. 6(1)(b) GDPR
We process personal data where necessary to:
- provide our consulting and advisory services
- manage bookings and consultations
- fulfill service agreements
6.2 Legitimate Interests - Art. 6(1)(f) GDPR
We may process personal data based on our legitimate interests, including:
- responding to inquiries and maintaining communication
- operating and improving our website and services
- providing customer support
- maintaining our social media presence
- ensuring service security
- preventing abuse, misuse, or unauthorized access
- maintaining technical logs necessary for reliability and security
6.3 Legal Obligations - Art. 6(1)(c) GDPR
We process personal data where necessary to comply with legal obligations, including accounting, tax, and regulatory requirements.
6.4 Consent - Art. 6(1)(a) GDPR
Where required, we rely on consent, including for:
- certain cookies and marketing technologies
- specific forms of marketing communication
Consent may be withdrawn at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
7. Whether Providing Data Is Mandatory
Providing personal data is generally voluntary. However, it may be necessary in order to receive a response to an inquiry, obtain free materials, book a consultation, or receive our services. If required data is not provided, we may be unable to complete the requested action.
8. Data Retention
We retain personal data only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required by law. In particular:
- inquiry and contact form data: up to 2 years from last contact
- cookie data: in accordance with consent preferences and browser settings
- statistical and analytical data: up to 2 years
- booking and consultation data: for the duration of the relationship and any follow-up period
- accounting and tax-related data: up to 6 years, or longer if required by law
9. Data Recipients
Personal data may be shared with the following categories of recipients:
- public authorities and institutions, to the extent required by applicable law in connection with the Controller's legal obligations, such as pursuing legal claims, fulfilling tax obligations, and other proceedings regulated by law
- website infrastructure provider (hosting, server, domain)
- website development and technical support provider
- cloud storage provider for data and documents
- cookie consent management provider
- accounting and bookkeeping service provider
- invoicing software provider
- where you have consented to marketing cookies, your data stored in cookies may be shared with our advertising partners (e.g. Meta, Google)
- where you have consented to analytics cookies, your data stored in cookies may be processed by the provider of our website analytics software (e.g. Google Analytics)
- other subcontractors who may gain access to personal data where the scope of their services requires such access
These providers process personal data only to the extent necessary to provide their services to the Controller.
10. International Data Transfers
Some service providers may process personal data outside the European Economic Area (EEA), including in the United States. The following providers are involved in such transfers:
- Google LLC (USA) - website analytics (Google Analytics), cloud tools (Google Workspace). Transfer safeguard: EU-US Data Privacy Framework (DPF) certification.
- Meta Platforms, Inc. (USA) - marketing and advertising tools (Meta Pixel). Transfer safeguard: EU-US Data Privacy Framework (DPF) certification.
Where the EU-US Data Privacy Framework does not apply, transfers are carried out on the basis of Standard Contractual Clauses (SCCs) approved by the European Commission, or other appropriate safeguards under Chapter V of GDPR.
11. Cookies
Our website uses cookies and similar technologies. We may use strictly necessary cookies (required for the website to function), analytics cookies, marketing cookies, and functional cookies. Third-party cookies may be provided by Google, Meta, and Cookiebot.
You can manage your cookie preferences through our cookie banner or browser settings. Analytics and marketing cookies are used only where consent has been obtained.
12. Data Subject Rights
Under GDPR, you have the right to: access your personal data, rectification, erasure, restriction of processing, data portability, withdrawal of consent at any time, and lodging a complaint with a supervisory authority.
Right to object (Art. 21 GDPR)
You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data based on our legitimate interests (Art. 6(1)(f) GDPR). If you object, we will no longer process your data for the relevant purpose unless we demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
Where personal data is processed for direct marketing purposes, you have the right to object at any time. If you object, your data will no longer be processed for such purposes.
Requests regarding personal data may be sent to: [email protected]
In Poland, the competent supervisory authority is the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, Poland (www.uodo.gov.pl).
13. Automated Decision-Making
We do not perform automated decision-making or profiling that produces legal or similarly significant effects.
14. Contact
If you have any questions regarding this Privacy Policy or the processing of personal data, please contact:
Aleksandra Kubicka, Clean Culture Aleksandra Kubicka (operating as Taanto)
Email: [email protected]