Privacy Policy
Code Publishing sp. z o.o.
Effective date: 1 January 2025
1. DATA CONTROLLER
Code Publishing sp. z o.o.
ul. Fabryczna 6, 54-609 Wrocław, Poland
KRS: 0001046452 | NIP: 8971924946 | REGON: 525831482
Email: contact@codepublishing.eu | Phone: +48 780 540 927
The Controller has not appointed a Data Protection Officer. For all matters concerning personal data, please contact: contact@codepublishing.eu
2. WHOSE DATA WE PROCESS
We process personal data of:
- Business partners and contractors (and their representatives)
- B2B collaborators providing services to Code Publishing
- MedKid application users (governed by separate policy: www.iubenda.com/privacy-policy/55476950)
- Individuals contacting us for business or technical matters
3. PURPOSES AND LEGAL BASIS FOR PROCESSING
| Purpose of Processing | Legal Basis | Retention Period |
|---|---|---|
| Performance of contracts and B2B cooperation | Art. 6(1)(b) GDPR (contract performance) | Duration of contract + limitation period for claims |
| Accounting and tax obligations | Art. 6(1)(c) GDPR (legal obligation) | 5 years from end of tax year |
| Technical communication with users (failures, issues) | Art. 6(1)(f) GDPR (legitimate interest) | Until issue resolved + 1 year |
| Establishing or defending legal claims | Art. 6(1)(f) GDPR (legitimate interest) | Until claims are time-barred |
| Direct marketing (if applicable) | Art. 6(1)(f) GDPR or consent | Until objection or consent withdrawal |
| Document archiving | Art. 6(1)(f) GDPR (legitimate interest) | As required by law |
4. SCOPE OF DATA PROCESSED
Data of contractors/B2B collaborators:
- Name and surname, company name
- Tax ID (NIP), REGON (for sole traders)
- Email address, phone number
- Bank account number (for settlements)
- Data from documents (invoices, contracts)
Data of company representatives:
- Name and surname, position
- Business email and phone
Data of individuals contacting us for technical matters:
- Email address
- Description of issue/request
- Technical data related to the issue
5. DATA SOURCES
We obtain data from:
- Directly from the data subject
- From the employer or company the person represents
- Public sources (CEIDG, KRS business registers)
6. DATA RECIPIENTS
Data may be shared with:
- Data processors: accounting office, law firms, IT providers, hosting services
- State authorities: Tax Office, Social Insurance Institution (based on legal requirements)
- Communication service providers: email, video conferencing, cloud services (including outside EEA - see point 7)
7. DATA TRANSFERS OUTSIDE THE EEA
Data may be transferred to the USA only to entities certified under the Data Privacy Framework (e.g., Google, Microsoft). List of certified entities: www.dataprivacyframework.gov/s/participant-search
We do not transfer data to other third countries.
8. YOUR RIGHTS
You have the following rights:
- Access to your data and obtaining a copy
- Rectification of incorrect or completion of incomplete data
- Erasure of data ("right to be forgotten") - except data required by law
- Restriction of processing in specific cases
- Data portability in electronic format
- Object to processing based on legitimate interest
- Withdraw consent (if processing is based on consent)
- Lodge a complaint with the Polish Data Protection Authority (UODO, ul. Stawki 2, 00-193 Warsaw)
To exercise these rights, please contact: contact@codepublishing.eu
9. DATA SECURITY
We implement appropriate technical and organisational measures:
- Data transmission encryption (SSL/TLS)
- System access control
- Data processing agreements with subcontractors
- Regular backups
10. ADDITIONAL INFORMATION
- We do not use automated decision-making or profiling
- We do not use cookies on company websites
- Providing data is voluntary but necessary for contract/cooperation
- Identity verification may be required when exercising GDPR rights
11. MEDKID APPLICATION
MedKid application users are governed by separate policies:
- Privacy Policy: www.iubenda.com/privacy-policy/55476950
- Terms and Conditions: www.iubenda.com/zasady-i-warunki/55476950
12. POLICY CHANGES
We will notify of significant changes through:
- Updates on www.codepublishing.eu
- Email to active contractors (if applicable)
13. CONTACT
Code Publishing sp. z o.o.
Email: contact@codepublishing.eu
Phone: +48 780 540 927
Address: ul. Fabryczna 6, 54-609 Wrocław, Poland
This document fulfils the information obligation under Articles 13 and 14 of the GDPR