Privacy policy
This policy explains how personal data is handled on beatlearn.com and in the BeatLearn launch emails.
1. Who is responsible
The data controller is destruggle P.S.A., Aleje Jerozolimskie 109/70, 02-011 Warsaw, Poland, KRS 0001273798. Full details are on the company details page.
For any privacy question, email [email protected].
2. What data is collected
- Launch emails: your email address, the date and time of signup and confirmation, the signup form used (which shows the chosen language), your marketing consent, and technical signup data such as IP address.
- Email activity: whether emails are opened and links are clicked, to see what is useful and keep the list healthy.
- Website visits: when the site loads, Cloudflare processes technical data such as IP address, browser type and the pages requested.
The site uses no analytics or advertising cookies. The Kit signup form may store a small technical identifier in the browser so that the form works correctly.
3. Why, and on what legal basis
- Sending launch emails: your consent (Art. 6(1)(a) GDPR).
- Keeping a record of consent and handling requests: legitimate interest in being able to demonstrate compliance (Art. 6(1)(f) GDPR).
- Delivering and protecting the website: legitimate interest in running a secure website (Art. 6(1)(f) GDPR).
Providing an email address is voluntary, but without it launch emails cannot be sent.
4. Who processes the data
Two service providers process data on the company's behalf, under data processing agreements:
- Kit (Kit.com, United States): stores the email list and sends the emails.
- Cloudflare, Inc. (United States): hosts the website and protects it from attacks.
Data is not sold or shared with anyone else.
5. Transfers outside the EEA
Kit and Cloudflare may process data in the United States. These transfers rely on the EU-US Data Privacy Framework or on the European Commission's standard contractual clauses, as set out in each provider's data processing terms.
6. How long data is kept
- Email address, consent record and email activity: until you unsubscribe, then deleted within 30 days.
- Technical website data: according to Cloudflare's standard retention, only as long as needed to deliver and protect the site.
7. Your rights
You have the right to:
- access your data and receive a copy,
- have it corrected,
- have it deleted,
- restrict its processing,
- receive it in a portable format,
- object to processing based on legitimate interest,
- withdraw consent at any time, using the unsubscribe link in every email or by emailing [email protected]. Withdrawing consent does not affect processing carried out before the withdrawal.
To use any of these rights, email [email protected].
You can also complain to the Polish data protection authority: President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl, or to the supervisory authority in your country of residence.
8. Automated decisions
No decisions with legal or similarly significant effects are made about you automatically.
9. Changes
This policy may be updated, for example when the BeatLearn app launches. The date at the top shows the latest version.