This Privacy Policy explains how personal data is processed in connection with the services provided by Sabio Smart Oleksii Yankevych (including individuals representing clients or partners), visits to websites operated by the Controller – in particular within the sabiosmart.com domain – the Controller’s social media profiles, as well as contact with the Controller.
I. Personal Data Controller
The controller of personal data is Sabio Smart Oleksii Yankevych, based in Warsaw (04-502), ul. Korkowa 39B/263, NIP: 1132915381 (hereinafter: the “Controller”).
You may contact the Controller:
- in writing – at the address indicated above,
- by email – info@sabiosmart.com.
II. General Rules for Processing Personal Data
The Controller processes personal data in compliance with applicable laws, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”).
The scope of processed data depends on the purpose (described in detail in Section III). Providing data is generally voluntary; however, failure to provide data may prevent the Controller from achieving a given purpose, for example responding to an inquiry or preparing an offer. If providing data is required by law or necessary to enter into/perform a contract, the Controller will inform you explicitly.
The Controller places great importance on privacy and confidentiality. Appropriate technical and organizational measures are applied to ensure data security, including protection against unauthorized access, disclosure, loss, or destruction. Access to data is granted only to authorized persons and to processors acting on the Controller’s behalf – strictly to the extent necessary to provide services.
III. Purposes, Legal Bases, and Retention Periods
Personal data is processed only for clearly defined purposes and on appropriate legal bases. The Controller does not process data in a manner inconsistent with the purposes listed below.
- Entering into and performing a contract / providing services – Article 6(1)(b) GDPR (performance of a contract) and pre-contractual steps taken at the data subject’s request (e.g., preparing an offer).
Retention: for the duration of the contract, and thereafter – where necessary – for the limitation period for claims or other mandatory retention obligations. - Newsletter and marketing communication (if provided) – Article 6(1)(b) GDPR (service performance) and/or Article 6(1)(a) GDPR (consent – for additional data and/or channels requiring consent).
Retention: until you unsubscribe or withdraw consent (where consent is the legal basis), but no longer than for the period the newsletter service is provided. - Use of the Controller’s websites – Article 6(1)(f) GDPR (legitimate interest: operating and maintaining the website, ensuring security, technical statistics).
Retention: depends on the type of cookies/similar technologies used; details are available in the cookie banner and in Section VII. - Cookies other than strictly necessary – Article 6(1)(a) GDPR (consent).
Retention: until consent is withdrawn or the cookie expires (as described in the cookie banner settings). - Handling inquiries and contact (form, email, phone, social media messages) – Article 6(1)(f) GDPR (legitimate interest: responding to inquiries and maintaining correspondence).
Retention: until an effective objection is raised, but no longer than until the end of the calendar year following 3 years from the last contact regarding the matter. - B2B cooperation – contact with individuals representing a client/contractor – Article 6(1)(f) GDPR (legitimate interest: proper performance of the agreement and business communication).
Data scope: in particular business and contact data provided in the agreement or during cooperation.
Retention: until an effective objection is raised, no longer than until the end of cooperation, and for the time necessary to secure potential claims. - Establishing, pursuing, or defending claims and handling complaints – Article 6(1)(f) GDPR (legitimate interest: protecting the Controller’s rights).
Retention: for the duration of proceedings and until the expiry of the limitation period for claims. - Marketing of the Controller’s services and promotional activities – Article 6(1)(f) GDPR (legitimate interest: promotion and business development) and – where required by law – consent for marketing communication / commercial information.
Retention: until consent is withdrawn (if applicable) or an effective objection is raised; if no objection is raised – no longer than 12 months from the last marketing activity/correspondence. - Tax and accounting obligations – Article 6(1)(c) GDPR (legal obligation).
Retention: for the period required by tax and accounting regulations. - Analytics and statistics – Article 6(1)(f) GDPR (legitimate interest: traffic analysis, service quality improvement, content and functionality optimization).
Retention: until you stop using a given functionality or raise an objection, but no longer than until the end of the calendar year following 3 years from data collection. - Social media profiles – Article 6(1)(f) GDPR (legitimate interest: communication, community building, promotion of services).
Retention: for as long as you follow/engage with the profile or until an objection is raised; additionally, according to the rules of the respective platform. - Contests/promotional campaigns (if organized) – Article 6(1)(f) GDPR (legitimate interest: running the campaign) or Article 6(1)(b) GDPR (performance of campaign rules).
Retention: until the campaign is completed and settled; for winners – for the time necessary to deliver prizes and complete settlements (e.g., tax), and then for the limitation period for claims. - Call/meeting recordings (if used, e.g., to improve service quality) – Article 6(1)(f) GDPR (legitimate interest: quality improvement and evidentiary security).
Retention: until an objection is raised, no longer than necessary to achieve the purpose and secure claims.
The Controller may use IP addresses solely for technical purposes related to server administration and security, as well as to prepare aggregated statistics (e.g., connection region).
IV. Rights of Data Subjects
Where the legal conditions are met, data subjects have the following rights:
- the right to access their data and obtain a copy,
- the right to rectify (correct) data,
- the right to erasure (“right to be forgotten”),
- the right to restrict processing,
- the right to data portability,
- the right to object – for reasons related to a particular situation – to processing based on Article 6(1)(f) GDPR,
- the right to object to processing for direct marketing purposes,
- the right to withdraw consent – where processing is based on consent (without affecting the lawfulness of processing before withdrawal),
- the right to lodge a complaint with the supervisory authority: President of the Personal Data Protection Office (PUODO), ul. Stawki 2, 00-193 Warsaw, Poland.
You can exercise your rights in any way, in particular by sending a request to: info@sabiosmart.com. If the Controller cannot reliably identify the requester, additional information may be requested for verification.
V. Recipients of Personal Data
Data may be disclosed to entities authorized under applicable law (e.g., public authorities). In addition, data may be shared with trusted partners cooperating with the Controller, in particular:
- postal and courier service providers,
- accounting and settlement service providers,
- law firms and advisors,
- IT service providers (hosting, maintenance and development of the website, analytics/marketing tools),
- software and IT system providers,
- debt collection agencies (where justified).
As a rule, the Controller processes data within the European Economic Area (EEA). If, in connection with the use of certain service providers’ tools (e.g., analytics or advertising), data is transferred outside the EEA, this occurs only where necessary and with an adequate level of protection ensured – in particular based on: an EU Commission adequacy decision, Standard Contractual Clauses, or another legal basis provided by law (e.g., explicit consent). Detailed information about transfer mechanisms for specific providers can be obtained by contacting the Controller at: info@sabiosmart.com.
VI. Automated Processing and Profiling
The Controller may process data in an automated manner, including profiling (e.g., within marketing or analytics tools). However, automated processing will not result in decisions producing legal effects concerning the data subject or similarly significantly affecting them. Profiling may influence, for example, the selection of displayed content or advertisements.
VII. Cookies
VII.I General Information
The Controller uses cookies and similar technologies (collectively: “cookies”), i.e., small text files stored on the user’s device. Cookies help the website function properly, enhance security, allow content to be tailored to user preferences, and generate statistics about how the website is used.
Data collected via cookies is used to provide specific website functions. Cookies are generally not personal data; however, when combined with other information, they may in some cases constitute personal data.
VII.II Types of Cookies Used on sabiosmart.com
Due to storage duration, the Controller uses:
- session cookies – stored until the browser is closed or you log out,
- persistent cookies – stored for the period defined in the cookie parameters or until deleted by the user.
Due to purpose, cookies can be classified as:
- Necessary – essential for the website to operate and for basic functions; they cannot be disabled in consent management systems.
- Analytics – help understand how users interact with the website (e.g., visits), enabling improvements.
- Marketing – enable displaying ads tailored to user preferences and measuring campaign effectiveness.
The Controller uses both first-party cookies (set by sabiosmart.com) and third-party cookies (set by external providers). Third parties include in particular:
- Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA – Google Analytics (analytics), Google Ads (advertising), Google Tag Manager (tag management), reCAPTCHA (security), YouTube (embedded video content).
More: https://policies.google.com/privacy, https://www.youtube.com/t/terms. - Meta Platforms, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA – Meta advertising tools (campaign measurement and optimization, including the pixel).
More: https://www.facebook.com/policies/cookies/. - Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA – Bing Ads (advertising and conversion measurement).
More: https://privacy.microsoft.com/privacystatement. - LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland – LinkedIn analytics and marketing tools.
More: https://www.linkedin.com/legal/privacy-policy. - Social plugins and integrations – Instagram, TikTok, LinkedIn, YouTube, Facebook. Providers of these plugins may receive information about visits to the website, user identifiers, and browser parameters. If you are logged in to a given service, information may be linked to your profile according to that platform’s rules.
Providers’ policies: Instagram, TikTok, Facebook, LinkedIn, YouTube.
VII.III Managing Cookies
Except for strictly necessary cookies, the use of cookies requires your consent. Consent is provided in the cookie banner before cookies are stored on your device. You can change your preferences at any time (withdraw consent or object) – via the cookie banner settings and your browser settings.
Managing cookies in browsers (example instructions):
- Microsoft Edge: https://privacy.microsoft.com/en-us/privacystatement
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Opera: https://www.opera.com/help/tutorials/security/cookie/
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Safari: https://support.apple.com/en-us/HT201265
Restricting cookies may cause some website functionalities to stop working properly.
VIII. Changes to This Privacy Policy
The Controller may update this Privacy Policy, in particular due to changes in laws, technology, or data processing practices. The current version is published on sabiosmart.com.