Privacy and Cookies Policy

§ 1. General provisions

This Privacy Policy sets out the rules for processing and protecting personal data provided by Users in connection with their use of the website https://beagleberry.com (the "Website").

The controller of the personal data processed on the Website is BEAGLEBERRY PROSTA SPÓŁKA AKCYJNA (a Polish simple joint-stock company) with its registered office in Wołomin, ul. Przejazd 3/U4, 05-200 Wołomin, Poland, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw, 14th Commercial Division of the National Court Register, under KRS number 0001186076, NIP (tax ID): 1251791755, REGON: 542403445, with share capital of PLN 4,050 (the "Controller").

To protect the data entrusted to us, we have developed internal procedures and recommendations designed to prevent the disclosure of data to unauthorised persons. We monitor their implementation and continuously verify their compliance with the applicable legislation – the Polish Personal Data Protection Act, the Polish Act on Providing Services by Electronic Means, and all related implementing acts and European Union law (GDPR).

§ 2. Purposes and legal bases of processing

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

§ 3. Recipients of data

Users' personal data may be disclosed to entities processing it on behalf of the Controller, including:

• Hosting and server service providers (to maintain the Website).
• IT and technical support service providers.
• Entities providing legal or accounting services (to the extent necessary to manage the Company's affairs).
• Providers of communication solutions and chatbot/artificial intelligence tools (for the technical handling of conversations).

Analytics data is processed by Google Analytics, provided by Google Ireland Limited. This data may be transferred outside the European Economic Area (EEA) on the basis of standard contractual clauses ensuring an adequate level of protection.

Data on how the Website is used is processed by Microsoft Clarity, provided by Microsoft Corporation. This data may be transferred to the United States on the basis of the European Commission's adequacy decision on the EU-U.S. Data Privacy Framework, in which Microsoft participates, and standard contractual clauses.

§ 4. User rights

Every User whose data is processed has the following rights under the GDPR:

• The right of access to their data.
• The right to rectification (correction) of their data.
• The right to erasure ("right to be forgotten") – in the cases provided for by law.
• The right to restriction of processing.
• The right to data portability.
• The right to object to processing.
• The right to withdraw consent at any time (where processing is based on consent), without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal.
• The right to lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, Poland – if the User considers that the processing of their data infringes the GDPR.

To exercise these rights, the User may contact the Controller at: rodo@beagleberry.com.

§ 5. Cookies and Google Analytics

The Website uses cookies. Cookies are small text files sent by the web server and stored by the browser software on the User's device.

The Website uses Google Analytics, a web analytics service provided by Google.

Google Analytics uses cookies to help the website analyse how users use it.

The Controller has enabled IP anonymisation in Google Analytics, which means that the User's IP address is truncated before it is stored.

The Website also uses Microsoft Clarity, a tool for analysing how the website is used. Microsoft Clarity uses cookies (including _clck – stored for up to 1 year, and _clsk – stored for up to 1 day) to recognise subsequent page views during a visit and combine them into sessions.

Google Analytics and Microsoft Clarity are started only after the User consents to analytics cookies in the cookie banner. Consent can be changed or withdrawn at any time using the "Cookie settings" link in the website footer.

The User may disable cookies in their web browser at any time. However, restricting cookies may affect some features of the website (e.g. it may make logging in to the Shareholders/Partner Zone more difficult).

Detailed information on how cookies can be managed is available in the settings of the software (web browser).

§ 6. Data retention

• Shareholders' data is stored for as long as they hold shareholder status and, after that, for the period required by law (including the Polish Commercial Companies Code and tax regulations).
• Partners' data is stored for the duration of the cooperation and for the limitation period of any claims arising from it.
• Analytics data (Google Analytics) is stored for 14 months and then deleted automatically.
• Session recordings in Microsoft Clarity are stored for 30 days; aggregated statistical data is stored in accordance with Microsoft Clarity's rules.

§ 7. Final provisions

The Controller applies technical and organisational measures ensuring protection of the personal data processed that is appropriate to the risks and to the categories of data protected, and in particular protects data against disclosure to unauthorised persons, removal by an unauthorised person, processing in breach of applicable law, and alteration, loss, damage or destruction (including through the use of SSL encryption).

The Controller reserves the right to amend this privacy policy as a result of developments in internet technology, changes in personal data protection law or the development of the Website itself. We will announce any changes in a visible and understandable way.