Privacy Policy
How PolandEduStart collects, protects, uses, and respects your personal data across the European Union, United States, and worldwide.
1. Identity of the Data Controller
The controller of your personal data processed through the website PolandEduStart (polandedustart.com) and in connection with our educational admission and relocation consulting services is:
PRIMO-DOTACJE Sp. z o.o.
ul. Półwiejska 17/26, 61-885 Poznań, Poland
Tax Identification Number (NIP): 7831934246
Data Protection Contact Email: info@primodotacje.pl
In this Privacy Policy, references to "Administrator", "we", "us", or "our" refer to PRIMO-DOTACJE Sp. z o.o. operating the PolandEduStart brand.
2. Personal Data We Collect
Depending on your interaction with PolandEduStart, we collect and process several categories of personal data:
- Identification & Contact Data: Full name, email address, phone number (including WhatsApp numbers), nationality, current country of residence, and spoken languages.
- Academic & Relocation Documents: Educational background, high school or university transcripts, graduation certificates, proof of language proficiency, passport details, and background notes submitted during admission assistance.
- Technical & Navigation Data: IP address, device type, browser information, operating system, geographical region based on IP, referring URLs, page views, time spent on pages, and standard server log records.
- Transaction & Invoicing Data: Billing name, company details, address, transaction reference, and invoice details. Note that payment card numbers are processed directly and securely by PCI-DSS compliant third-party payment gateways (such as Stripe or PayPal); we do not store full credit card numbers on our servers.
3. Purposes of Processing & Legal Bases (GDPR Art. 6)
We process your personal data in full compliance with Regulation (EU) 2016/679 (General Data Protection Regulation - GDPR / RODO) based on the following legal grounds:
A. Execution of Services & Pre-Contractual Steps (Art. 6(1)(b) GDPR)
Processing inquiry forms, scheduling paid consultations, managing university admission procedures, processing student documentation, and coordinating relocation support services.
B. Compliance with Legal Obligations (Art. 6(1)(c) GDPR)
Fulfilling accounting, tax reporting, and statutory bookkeeping duties mandated by Polish tax law (*Ustawa o rachunkowości*) and European financial legislation.
C. Legitimate Business Interests (Art. 6(1)(f) GDPR)
Responding to student inquiries, maintaining website security, preventing fraudulent activity, improving website performance, and handling potential legal claims.
D. Voluntary Consent (Art. 6(1)(a) GDPR)
Sending educational newsletters, promotional communications, or activating non-essential analytical cookies. You may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.
4. Recipients of Personal Data
To deliver our services effectively, your personal data may be shared with trusted third parties under strict confidentiality and security standards:
- Higher Education Institutions: Public and private universities, academies, and institutes in Poland or the EU where you apply for admission.
- Service Infrastructure Providers: Web hosting companies, cloud storage vendors, content delivery networks (CDNs), and database security partners.
- Communication & CRM Systems: Secure email providers, customer relationship platforms, online meeting tools, and messaging channels (e.g. WhatsApp for client updates).
- Payment Processors & Accountants: Licensed Polish accounting offices, tax advisors, and certified payment processors.
- Public & Diplomatic Bodies: Polish consulates, embassies, or border guard authorities strictly when required for official visa processing or legally binding administrative requests.
5. International Data Transfers (Non-EEA Transfers)
Because we serve international students worldwide, your personal data may be transferred to or accessed from countries outside the European Economic Area (EEA).
Whenever data is transferred outside the EEA, we implement appropriate safeguards in accordance with Chapter V of the GDPR:
- Transfers to service providers in the United States rely on the EU-U.S. Data Privacy Framework (DPF) adequacy decision or Standard Contractual Clauses (SCCs) approved by the European Commission.
- Transfers necessary for the performance of an admission contract between you and a university outside the EEA are conducted pursuant to Article 49(1)(b) of the GDPR.
- You can request a copy of the applied safeguards by contacting us at info@primodotacje.pl.
6. Data Retention Periods
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or to comply with statutory legal requirements:
General Inquiries
Stored for up to 3 years from last contact or until resolution of the inquiry.
Client Contracts & Admissions
Stored for the duration of service delivery plus up to 6 years following contract completion (Polish Civil Code statute of limitations).
Financial & Invoicing Records
Stored for 5 years following the end of the fiscal year in accordance with Polish accounting law.
Marketing Data
Retained until you unsubscribe or withdraw your explicit consent.
7. Your Rights Under GDPR / RODO
Under European Union data protection regulations, you possess the following individual rights:
Right to Lodge a Complaint with a Supervisory Authority
If you believe your data protection rights have been infringed, you have the legal right to submit a complaint to the Polish Data Protection Supervisory Authority:
President of the Personal Data Protection Office (Urząd Ochrony Danych Osobowych - UODO)
Address: ul. Stawki 2, 00-193 Warszawa, Poland
Website: https://uodo.gov.pl
8. Specific Disclosures for United States & United Kingdom Residents
US Residents (CCPA / CPRA & State Privacy Laws)
If you reside in California or another US state with comprehensive privacy legislation:
- We do NOT sell your personal information to third parties.
- We do NOT share your personal information for cross-context behavioral advertising without your explicit consent.
- You have the right to request access to, correction of, or deletion of your personal data without receiving discriminatory treatment.
UK Residents (UK GDPR)
For individuals located in the United Kingdom, processing of your personal data complies with the UK GDPR and the Data Protection Act 2018. UK residents hold equivalent data protection rights to those listed in Section 7 above.
9. Automated Decision Making & Profiling
PolandEduStart does not engage in automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you as described under Article 22 of the GDPR.
11. Changes to This Policy & Contact Information
We reserve the right to update this Privacy Policy to reflect modifications in our services, statutory requirements, or legal interpretations. Any updates will be posted on this page with a revised effective date.
For any privacy questions, rights requests, or feedback regarding your personal data, please contact our data protection team:
PRIMO-DOTACJE Sp. z o.o. (PolandEduStart)
ul. Półwiejska 17/26, 61-885 Poznań, Poland
NIP: 7831934246
Email: info@primodotacje.pl