EloByku Studios Privacy Policy

Effective from: 29 July 2026

§1. Data controller

The controller of your personal data is QVVER TECHNOLOGY SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, with its registered office at Bielska 7, 43-520 Chybie, Poland, entered in the register of entrepreneurs of the National Court Register under KRS number 0000220705, VAT ID (NIP) 9372437672, REGON 072928654.

For matters concerning the protection of personal data you can contact us at: [email protected].

§2. Purposes and legal bases of processing

We process your personal data for the following purposes:

Performance of the agreement (Article 6(1)(b) GDPR) - providing the Service, account management, settlements.

Legal obligation (Article 6(1)(c) GDPR) - bookkeeping and fulfilment of tax obligations.

Legitimate interest (Article 6(1)(f) GDPR) - direct marketing of our own services, analysis of Service usage, pursuit of claims.

Consent (Article 6(1)(a) GDPR) - newsletter, analytical and marketing cookies.

§3. Data recipients

Your personal data may be transferred to the following categories of recipients:

Hosting and IT infrastructure providers.

Payment service providers (for the purpose of processing transactions).

Stripe Payments Europe, Ltd. - payment operator and provider for the Polish National e-Invoicing System (KSeF).

Entities providing accounting and legal services.

Public authorities in cases provided for by law.

Each recipient processes the data only to the extent necessary to perform the tasks entrusted to them and on the basis of appropriate data processing agreements.

§4. Transfers to third countries

In connection with the use of analytical tools and IT infrastructure, your data may be transferred to third countries (including the USA). In such cases the transfer takes place on the basis of:

An adequacy decision of the European Commission.

Standard contractual clauses approved by the European Commission.

Other appropriate safeguards provided for in Article 46 GDPR.

§5. Retention period

We retain your personal data for the following periods:

Account data - for the term of the agreement and up to 3 years after it ends (the limitation period for claims).

Billing data - for 5 years from the end of the tax year in which the transaction took place.

Marketing data - until consent is withdrawn or an objection is raised.

System logs - for a period not exceeding 12 months.

§6. Rights of the data subject

You have the following rights in connection with the processing of personal data:

Right of access - you can obtain information about the data being processed.

Right to rectification - you can request correction of inaccurate data.

Right to erasure - you can request deletion of data (the "right to be forgotten").

Right to restriction of processing - you can request that processing be restricted.

Right to data portability - you can receive your data in a machine-readable format.

Right to object - you can object to processing based on legitimate interest.

Right to withdraw consent - at any time, without affecting the lawfulness of processing carried out before withdrawal.

To exercise the above rights, contact us at [email protected]. You also have the right to lodge a complaint with the President of the Personal Data Protection Office (PUODO) in Poland.

§7. Cookies

The Service uses cookies for the following purposes:

Essential cookies - ensuring the correct operation of the Service, authentication, session security.

Analytical cookies - analysis of site traffic, optimisation of the user experience (with your consent).

Marketing cookies - personalisation of advertising, measurement of campaign effectiveness (with your consent).

You can manage cookie settings at any time using the cookie settings panel available in the page footer. You can also disable cookies in your browser settings, which may however limit the functionality of the Service.

§8. Changes to the policy

We reserve the right to update this Privacy Policy. We will inform you of material changes through:

A notification in the Service panel.

An e-mail message to the address linked to the account.

Changes take effect 14 days after notification. Continued use of the Service after that date constitutes acceptance of the updated Policy.

§9. Contact

For matters relating to the protection of personal data, please contact us:

E-mail: [email protected]

Postal address: QVVER TECHNOLOGY SP. Z O.O., Bielska 7, 43-520 Chybie, Poland

§10. Information clause (Article 13 GDPR)

The controller of your personal data is QVVER TECHNOLOGY SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, with its registered office at Bielska 7, 43-520 Chybie, entered in the register of entrepreneurs of the National Court Register under KRS number 0000220705.

Contact details of the controller:

E-mail: [email protected]

Address: Bielska 7, 43-520 Chybie, Poland

Personal data is processed on the following legal bases:

Article 6(1)(a) GDPR - consent of the data subject (e.g. for the newsletter, marketing cookies).

Article 6(1)(b) GDPR - necessity for the performance of a contract or to take steps prior to entering into a contract.

Article 6(1)(c) GDPR - necessity for compliance with a legal obligation to which the controller is subject.

Article 6(1)(f) GDPR - necessity for the purposes of the legitimate interests pursued by the controller (direct marketing, analytics, security).

This Policy is published in Polish, English and Ukrainian. In the event of any discrepancy between the language versions, the Polish version prevails.