Privacy Policy

Last updated: 2024

This Privacy Policy explains how Galebe ("we", "us", "our") processes personal data of visitors to our website and participants in our Mentorship Program for Entrepreneurs. We are committed to protecting your personal data in accordance with Regulation (EU) 2016/679 (the "GDPR") and the Polish Act of 10 May 2018 on the Protection of Personal Data (Ustawa o ochronie danych osobowych).

1. Data Controller

The data controller responsible for your personal data is:

2. What Personal Data We Collect and Why

We collect personal data primarily through the contact and application forms available on our website. This may include:

• Name and surname — to identify you and address you correctly in our correspondence.
• Email address — to respond to your inquiry and communicate about our Mentorship Program for Entrepreneurs.
• Phone number (if provided) — to contact you directly regarding your application or inquiry.
• Message content — the information you choose to share about your business or mentorship needs, in order to evaluate and respond to your request.

We do not collect any sensitive categories of personal data (as defined in Article 9 GDPR) through our forms, and we ask that you refrain from submitting such information.

3. Legal Basis for Processing

We process your personal data on the following legal grounds under Article 6(1) GDPR:

• Article 6(1)(b) GDPR — processing necessary to take steps prior to entering into a contract with you, or to perform a contract (e.g., when you apply to our mentorship program).
• Article 6(1)(a) GDPR — your consent, where you have voluntarily submitted a form and, separately, where you have given consent to advertising measurement on the confirmation page.
• Article 6(1)(f) GDPR — our legitimate interest in responding to inquiries and maintaining business correspondence, where applicable.

4. Storage Period and Recipients

We retain personal data collected through our forms only for as long as necessary to handle your inquiry, provide mentorship services, or comply with legal obligations (such as accounting and tax retention periods required under Polish law, typically up to 5 years from the end of the relevant tax year for financial records). Correspondence data is deleted or anonymized once it is no longer needed for the purpose it was collected, unless a longer retention period is required by law.

Personal data may be shared with:

• Service providers who support our IT infrastructure and hosting, acting as data processors under a data processing agreement, bound to process data only on our instructions.
• Advertising measurement partners, but only after you have given explicit consent, and only in connection with the confirmation page of our website.
• Public authorities, where disclosure is required by Polish or EU law.

We do not sell personal data to third parties, and we do not transfer personal data outside the European Economic Area without appropriate safeguards.

5. Cookies

Our website uses a single cookie, named privacy_state, which stores your consent choice regarding data processing preferences for a period of one year. This cookie is strictly necessary to remember your preference and does not track browsing behavior across other sites.

We do not use analytics cookies, advertising tracking cookies, session cookies, or CSRF-protection cookies. No third-party tracking technologies (such as Google Analytics, Yandex Metrica, or social network pixels) are present on this website. Advertising measurement, where applicable, is activated only after you provide consent, and only on the confirmation page following a form submission.

6. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

• Right of access — to obtain confirmation of whether we process your data and to receive a copy of it.
• Right to rectification — to correct inaccurate or incomplete data.
• Right to erasure — to request deletion of your data ("right to be forgotten"), subject to legal exceptions.
• Right to restrict processing — to limit how we use your data in certain circumstances.
• Right to data portability — to receive your data in a structured, commonly used format.
• Right to object — to object to processing based on legitimate interest.
• Right to withdraw consent — at any time, without affecting the lawfulness of processing carried out before withdrawal.
• Right to lodge a complaint — with the Polish supervisory authority, the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO), if you believe your data has been processed unlawfully.

7. How to Exercise Your Rights

To exercise any of the above rights, or if you have questions about this Privacy Policy, please contact us at:

Email: [email protected]
Phone: +48 58 011 44 38
Postal address: Galebe, Ulica Jasienska 42, 84-858 Gdańsk, Poland

We will respond to your request within one month, as required by Article 12(3) GDPR. This period may be extended by two further months where necessary, taking into account the complexity and number of requests.

8. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any changes will be published on this page with an updated revision date.