1. Controller and scope of this policy
IRID spółka z ograniczoną odpowiedzialnością (a Polish limited liability company), ul. Heroldów 6, 01-991 Warsaw, Poland; KRS 0000816335, NIP 6372209018, REGON 384964097; share capital PLN 5,000.00.
Company and personal data protection contact: sekretariat@irid.pl.
T-wire system enquiries: kontakt@t-wire.eu.
This policy applies to the T-wire information website and correspondence addressed to IRID in connection with the project. It does not replace the data processing policies of the provider of an account used to access the website or the user's email provider.
2. Data processed and purposes
- Correspondence: email address, name, details of the entity represented and information voluntarily provided in a message. These are used to handle enquiries and business contacts under Article 6(1)(f) GDPR, based on the controller's legitimate interest in conducting correspondence. Where an individual requests steps towards entering into a contract with them, Article 6(1)(b) GDPR applies.
- Technical operation and security: when a connection is made, the infrastructure serving the website may process the IP address, request time, resource address, browser information and error data. For IRID's activities, the purpose is to provide and protect the website under Article 6(1)(f) GDPR.
- Legal claims: necessary correspondence may be retained to establish, exercise or defend legal claims under Article 6(1)(f) GDPR.
The website has no contact form, newsletter or shop. Clicking an email address opens an email application; it does not send a message automatically. Providing data in correspondence is voluntary, but a response may be impossible without contact details. Please provide only information necessary to handle the matter.
3. Recipients and infrastructure
Data may be accessed by authorised persons acting for IRID, email, hosting and IT service providers, and advisers where necessary to handle the matter. Data may be disclosed to authorities entitled to receive it by law.
The current website is hosted on the ChatGPT Sites platform. The platform operator may also process data relating to access, authentication and security under its own policies. The operator's information is available in the OpenAI privacy policy.
Using international providers' infrastructure may involve processing data outside the European Economic Area. The applicable rules depend on the service and the provider's role. Information on recipients and safeguards for data processed by IRID can be obtained at sekretariat@irid.pl. This policy does not determine server locations or a specific transfer mechanism for every service.
4. Retention periods
Correspondence is retained while the matter is being handled, and subsequently only to the extent necessary to maintain a legitimate business relationship or safeguard legal claims, taking applicable limitation periods into account. Documents subject to mandatory retention are kept for the period required by law. Retention periods for logs and account data handled by the platform operator are governed by that service's policies; they are not determined by the T-wire website code.
5. Individual rights
Subject to the conditions set out in the GDPR, individuals have rights of access, rectification, erasure, restriction of processing and data portability. Processing based on legitimate interests may be objected to on grounds relating to the individual's particular situation. Where processing is based on consent, consent may be withdrawn without affecting the lawfulness of earlier processing.
Requests should be sent to sekretariat@irid.pl. A complaint may also be lodged with the President of the Polish Personal Data Protection Office — uodo.gov.pl. The T-wire website code does not carry out profiling or automated decision-making producing legal effects.
6. Legal basis and updates
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), in particular Articles 6, 12–22 and 44–49. Text of the Regulation — EUR-Lex. This policy will be updated if the website's operation or data processing changes.