Privacy Policy

This Privacy Policy sets out the rules for the processing of personal data and the use of cookies in connection with the use of the website available at growtime.eu (hereinafter: the “Website”). This document has been prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the General Data Protection Regulation (EU) 2016/679, hereinafter: the “GDPR”), as well as with the Polish Act on Providing Services by Electronic Means and the Polish Telecommunications Law.

We care about the privacy of those who visit our Website and contact us. Below we explain who the controller of your data is, for what purpose and on what legal basis we process it, to whom we may entrust it, how long we retain it, and what rights you are entitled to.

1. Data controller

The controller of the personal data processed in connection with the use of the Website is:

• GROWTIME Sp. z o.o.
• ul. Waryńskiego 32-36, 86-300 Grudziądz, Poland
• NIP (Tax ID): 8762462542 (EU VAT: PL8762462542)
• KRS: 0000599877 (Register of Entrepreneurs of the National Court Register)
• REGON: 362685569

In all matters relating to the processing of personal data and the exercise of the rights to which you are entitled, you may contact the controller:

• in writing — at the registered office address indicated above,
• by e-mail — at info@growtime.eu,
• by telephone — at +48 56 477 20 80.

The controller has not appointed a Data Protection Officer. Contact in all matters relating to the protection of personal data is available at info@growtime.eu.

2. Scope, purposes and legal bases of data processing

We process personal data solely for specified, explicit and legitimate purposes. Below we present the individual processing purposes together with their corresponding legal bases arising from Article 6(1) of the GDPR.

2.1. Handling enquiries submitted via the contact form and by e-mail

On the Website we provide a contact form (based on the Contact Form 7 plugin). If you use the form or send an enquiry to the indicated e-mail address, we process the data you provide, such as your first name and surname, e-mail address, telephone number (if provided) and the content of the message.

The purposes and legal bases for processing this data:

• responding to the submitted enquiry and conducting correspondence — where the contact aims to conclude or perform a contract, the basis is the necessity of processing to take steps at the request of the data subject prior to entering into a contract or to perform a contract (Article 6(1)(b) of the GDPR);
• responding to enquiries not directly related to the conclusion of a contract and maintaining a business relationship (B2B) — on the basis of the legitimate interest of the controller, namely the handling of submitted enquiries and communication with interested parties (Article 6(1)(f) of the GDPR).

2.2. Securing the contact form (reCAPTCHA mechanism)

The contact form is protected by the Google reCAPTCHA mechanism, which serves to protect the Website against abuse and the automated submission of requests (spam, bots). The basis for processing data in this respect is the legitimate interest of the controller consisting in ensuring the security of the Website and preventing abuse (Article 6(1)(f) of the GDPR).

2.3. Analytical and marketing purposes

On the Website we use analytical and marketing tools (including Google Analytics / GA4 launched via Google Tag Manager and the Hotjar tool), which allow us to examine how the Website is used, create statistics and improve the content presented. In the case of the Hotjar tool, the analysis may include statistics, heatmaps and anonymised session recordings illustrating how users interact with the page (without recording the content entered in form fields). The processing of data for these purposes — to the extent that it takes place using cookies other than necessary ones — is carried out on the basis of freely given consent (Article 6(1)(a) of the GDPR), which you express through the appropriate configuration of cookie settings. You may withdraw your consent at any time, which does not affect the lawfulness of processing carried out before its withdrawal.

2.4. Establishment, assertion and defence of claims

Personal data may be processed for the purpose of establishing, asserting or defending against any claims connected with the conducted activity and contact with the controller. In this case the basis for processing is the legitimate interest of the controller (Article 6(1)(f) of the GDPR).

3. Data recipients and processors

In connection with our activities, we may entrust the processing of personal data or make it available to trusted entities that support us in operating the Website and serving customers. These entities process data solely on the basis of data processing agreements and in accordance with our instructions. The data recipients include in particular:

• cyber_Folks S.A. — provider of hosting services, on whose servers the Website is maintained (infrastructure located in Poland / the European Union);
• Google Ireland Limited / Google LLC — provider of analytical and marketing tools (Google Analytics / GA4 launched via Google Tag Manager) and the form protection mechanism (Google reCAPTCHA);
• Hotjar Ltd — provider of a tool for analysing user behaviour (statistics, heatmaps, anonymised session recordings);
• uvdesk — provider of the ticketing and technical support system (growtime.uvdesk.com), used to handle enquiries and service requests.

Personal data may also be made available to entities authorised to obtain it under applicable laws (e.g. state authorities) where they submit a request based on an appropriate legal basis.

4. Transfer of data to third countries

Some of the tools we use (in particular the services provided by Google and uvdesk) may involve the transfer of personal data outside the European Economic Area, including to the United States of America.

The transfer of data to third countries takes place with the appropriate safeguards provided for in the GDPR, in particular on the basis of:

• standard contractual clauses approved by the European Commission (Standard Contractual Clauses — SCC), and
• a European Commission decision confirming an adequate level of protection with respect to entities certified under the Data Privacy Framework (EU–U.S. Data Privacy Framework).

You have the right to obtain a copy of the safeguards applied by contacting the controller at info@growtime.eu.

5. Data retention period

We retain personal data only for the period necessary to achieve the purposes for which it was collected, and subsequently for the period required by law or justified by the protection of our interests. In particular:

• data processed in connection with handling enquiries submitted via the contact form or by e-mail is retained until the completion of the matter to which the correspondence relates, and subsequently for the limitation period of any claims arising from the law;
• data processed on the basis of consent (including for analytical and marketing purposes) is retained until consent is withdrawn or until the expiry of the individual cookies in accordance with the settings of the given tool;
• data processed for the purpose of establishing, asserting or defending against claims is retained for the limitation period of those claims.

6. Rights of data subjects

In connection with the processing of personal data, you are entitled to the following rights:

• the right of access to data and to obtain a copy of it (Article 15 of the GDPR);
• the right to rectification (correction) of data (Article 16 of the GDPR);
• the right to erasure of data — the “right to be forgotten” (Article 17 of the GDPR);
• the right to restriction of processing (Article 18 of the GDPR);
• the right to obtain information about the recipients to whom your data has been disclosed, in connection with its rectification, erasure or restriction of processing (Article 19 of the GDPR);
• the right to data portability (Article 20 of the GDPR);
• the right to object to processing based on the legitimate interest of the controller (Article 21 of the GDPR);
• the right to withdraw consent at any time — to the extent that processing is carried out on the basis of consent — whereby the withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

In order to exercise the above rights, please contact us at info@growtime.eu or in writing at the controller’s registered office address.

If you consider that the processing of your personal data infringes the provisions of the GDPR, you have the right to lodge a complaint with the supervisory authority, which in Poland is the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, Poland.

7. Cookies and similar technologies

The Website uses cookies (so-called “cookies”) and similar technologies (e.g. the browser cache mechanism). Cookies are small text files saved on the user’s end device that enable the correct operation of the Website and — with your consent — the analysis of traffic and marketing activities.

We divide cookies into the following categories:

• necessary — required for the proper functioning of the Website; their use does not require consent, since without them the Website could not operate correctly;
• analytical — allowing us to examine how the Website is used and to create statistics; used only with your consent;
• marketing — used to carry out marketing activities and measure their effectiveness; used only with your consent.

The table below presents the most important tools and technologies used on the Website:

7.1. Managing cookies

You can manage cookies other than necessary ones, including give or withdraw consent to their use and change your preferences at any time. The primary tool for managing cookies is the settings of your web browser — at any time you can use them to independently review, block and delete cookies. Detailed information on how to manage cookies can be found in the settings and help files of the most popular browsers:

• Google Chrome,
• Mozilla Firefox,
• Microsoft Edge,
• Safari,
• Opera.

Please note that limiting or disabling the use of cookies may affect certain functionalities of the Website and make it more difficult to use.

8. Automated decision-making and profiling

Your personal data is not subject to automated decision-making, including profiling, that would produce legal effects concerning you or similarly significantly affect you. Profiling may take place only to a limited extent related to analytics and marketing activities (e.g. statistical analysis of traffic on the Website) and is carried out on the basis of your consent, without producing legal effects concerning you.

9. Voluntary nature of providing data

Providing personal data is voluntary; however, in some cases it may be necessary to use certain functions of the Website. Providing data in the contact form or in an e-mail message is a condition for responding to the submitted enquiry — failure to provide it will prevent us from contacting you back and handling the matter.

10. Final provisions

In connection with the development of the Website, changes in the tools used or changes in the law, this Privacy Policy may be updated periodically. The current version of the document is always available on the Website. We encourage you to review the content of the Privacy Policy on an ongoing basis.

In matters not regulated by this Privacy Policy, the relevant provisions of law shall apply, in particular the GDPR and the Polish Act on Providing Services by Electronic Means.

Date of last update: 10 July 2026.

The Polish version of this document is binding; in case of any discrepancy, the Polish version prevails.