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PRIVACY POLICY

GENERAL INFORMATION

This Privacy Policy (hereinafter referred to as the "Policy") outlines the rules for processing personal data and the use of cookies on the website of Oligamy Software Sp. z o.o., with its registered office at 38 Nowiec Street, 80-293 Gdańsk, Poland, registered in the Central Register and Information on Economic Activity (CEIDG) under the tax identification number (NIP) 5833433323 and the statistical number REGON 389455609. The National Court Register (KRS) number is 0000911398.

This Policy is designed to comply with applicable data protection regulations, including the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the ePrivacy Directive 2002/58/EC, the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), the UK General Data Protection Regulation ("UK GDPR"),Brazil's Lei Geral de Proteção de Dados ("LGPD"), and other applicable privacy laws in jurisdictions where our services are offered.

DEFINITIONS

For the sake of clarity, we apply the following definitions:

  • "Service" or "Website" means the internet website available at www.oligamy.com.
  • "Administrator" or "Data Controller" refers to Oligamy Software Sp. z o.o., responsible for determining the purposes and means of processing personal data.
  • "User" or "Data Subject" refers to an individual or legal entity using the Service whose personal data is processed by the Administrator.
  • "Personal Data" means any information relating to an identified or identifiable natural person.
  • "Processing" means any operation performed on personal data, such as collection, recording, storage, alteration, retrieval, use, disclosure, or erasure.
  • "Consent" means any freely given, specific, informed, and unambiguous indication of the Data Subject's wishes by which they agree to the processing of their personal data.

DATA CONTROLLER

The Data Controller responsible for your personal data is:

Oligamy Software Sp. z o.o.
38 Nowiec Street, 80-293 Gdańsk, Poland
NIP: 5833433323 | REGON: 389455609 | KRS: 0000911398
Email: hello@oligamy.com

TYPES OF PERSONAL DATA COLLECTED

The Administrator collects and processes the following categories of personal data of Users:

  • Email address
  • First and last name
  • Company name and job title (if provided)
  • Phone number (if provided)
  • IP address of the device
  • Browser type, version, and language preferences
  • Operating system and device information
  • Referring website URL
  • Pages visited, time spent on pages, and clickstream data
  • Geographic location (city/region level, derived from IP)
  • Cookie identifiers and online identifiers (e.g., Google Analytics Client ID, Google Ads identifiers)
  • Information submitted through contact forms, inquiry forms, or newsletter sign-up forms on the Website
  • Any other information voluntarily provided by the User through the Service

METHODS OF DATA COLLECTION

Personal data is collected through the following methods:

  • Contact and inquiry forms — when a User submits a form on the Website (e.g., contact form, free validation sprint request, newsletter sign-up), the data entered by the User is collected and processed.
  • Cookies and tracking technologies — the Website uses cookies (first-party and third-party) and similar tracking technologies to collect data about User behavior, preferences, and interactions with the Website. See the "Cookies and Tracking Technologies" section below for details.
  • Google Analytics 4 — the Website uses Google Analytics 4, a web analytics service provided by Google LLC ("Google"), which collects data about website traffic, user behavior, and engagement through cookies and JavaScript code.
  • Google Ads — the Website uses Google Ads conversion tracking and remarketing features, which may collect data about User interactions with advertisements and the Website.
  • Server logs — the Website's hosting provider automatically collects technical data such as IP addresses, browser type, and access timestamps.

PURPOSE OF DATA PROCESSING

The personal data of Users is processed for the following purposes:

  • Performance of a contract or pre-contractual measures — to respond to inquiries submitted through contact forms, to provide requested services, and to fulfill agreements with Users.
  • Consent-based processing — to send marketing communications and newsletters, to use non-essential cookies and tracking technologies (including Google Analytics and Google Ads), and for any other purpose for which the User has given explicit consent.
  • Legitimate interests of the Administrator — to analyze website traffic and user behavior for the purpose of improving the Website and services, to ensure the security and proper functioning of the Website, and to establish, exercise, or defend legal claims.
  • Compliance with legal obligations — to fulfill tax, accounting, and other legal requirements under applicable law.

LEGAL BASIS FOR PROCESSING

Processing of personal data is carried out based on the following legal provisions under the GDPR:

  • Article 6(1)(a) GDPR — Consent: the User has given consent to the processing of their personal data for one or more specific purposes (e.g., marketing communications, non-essential cookies).
  • Article 6(1)(b) GDPR — Contract: processing is necessary for the performance of a contract to which the User is party, or in order to take steps at the request of the User prior to entering into a contract.
  • Article 6(1)(c) GDPR — Legal obligation: processing is necessary for compliance with a legal obligation to which the Administrator is subject.
  • Article 6(1)(f) GDPR — Legitimate interests: processing is necessary for the purposes of the legitimate interests pursued by the Administrator, such as website analytics, security, and fraud prevention, except where such interests are overridden by the interests or fundamental rights of the User.

COOKIES AND TRACKING TECHNOLOGIES

The Service uses cookies and similar tracking technologies for statistical purposes, to improve the quality of User experience, and to serve relevant advertisements. Cookies are small text files stored on Users' devices to recognize them and adapt the Service to their individual preferences.

Types of Cookies Used

  • Strictly necessary cookies — essential for the operation of the Website. These cookies do not require consent and cannot be disabled.
  • Analytics cookies (Google Analytics 4) — used to collect information about how Users interact with the Website, including pages visited, time spent, and navigation paths. Google Analytics uses the following first-party cookies: _ga (used to distinguish users, expires after 2 years) and _ga_<container-id> (used to persist session state, expires after 2 years).
  • Advertising cookies (Google Ads) — used to track conversions, serve relevant advertisements, and measure the effectiveness of advertising campaigns. These may include third-party cookies placed by Google.
  • Functional cookies — used to remember User preferences and settings to enhance the browsing experience.

Consent for Cookies

Before any non-essential cookies are placed on your device, we will request your explicit, informed consent through a cookie consent banner. You may grant or deny consent for each category of cookies separately. You have the right to withdraw your consent at any time by adjusting your cookie preferences through the cookie settings link available on the Website. The option to reject cookies is presented with equal prominence as the option to accept them, in compliance with GDPR and ePrivacy Directive requirements.

Google Consent Mode v2

The Website implements Google Consent Mode v2, which adjusts how Google tags (including Google Analytics and Google Ads) behave based on the User's consent choices. When consent is not granted, Google tags will operate in a limited mode, sending cookieless pings for basic measurement without storing cookies or collecting personal identifiers.

Managing Cookies via Browser

In addition to our cookie consent mechanism, Users can manage cookies through their browser settings. Most browsers allow you to view, delete, and block cookies from websites. Please note that disabling cookies may affect the functionality of the Website. For more information, consult your browser's help documentation.

INTERNATIONAL DATA TRANSFERS

As the Website uses services provided by Google LLC (a US-based company), personal data collected through Google Analytics and Google Ads may be transferred to and processed in the United States.

Such transfers are conducted in compliance with GDPR Chapter V on the basis of the EU-U.S. Data Privacy Framework, under which Google LLC has certified its compliance. In the event that the adequacy framework is invalidated, we will ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, to protect your personal data.

Data processing agreements are in place with all third-party service providers that process personal data on behalf of the Administrator.

DATA RETENTION PERIOD

Personal data is retained for the following periods:

  • Contact form submissions and inquiries: for the duration necessary to respond to and resolve the inquiry, and thereafter for a maximum of 5 years for the purpose of establishing, exercising, or defending legal claims.
  • Marketing communications (newsletter): until consent is withdrawn by the User.
  • Contractual data: for the duration of the contract and for a maximum of 5 years thereafter, or longer if required by applicable tax or accounting regulations.
  • Google Analytics data: in accordance with the data retention settings configured by the Administrator in Google Analytics 4 (default: 14 months). Users may request deletion of their data at any time.
  • Cookie data: as specified in the cookie descriptions above. Consent records are retained for the duration required to demonstrate compliance.

After the applicable retention period, the data will be permanently deleted unless processing is required for other reasons arising from legal provisions.

DATA PROCESSING ENTITIES

Personal data of Users may be transferred to entities cooperating with the Administrator, including but not limited to:

  • Google LLC — for the purpose of web analytics (Google Analytics 4) and advertising (Google Ads). Google acts as a data processor under a data processing agreement.
  • Hosting and cloud service providers
  • Email service providers (for sending newsletters and transactional emails)
  • Accounting and bookkeeping service providers
  • IT support and maintenance providers
  • Legal and professional advisors (when necessary)

All entities processing personal data of Users operate under an agreement with the Administrator (data processing agreement) and only on the Administrator's documented instructions. The Administrator ensures that all processors provide sufficient guarantees to implement appropriate technical and organizational measures to meet the requirements of the GDPR.

USER RIGHTS UNDER THE GDPR

Users who are located in the European Economic Area (EEA), the United Kingdom, or any jurisdiction that affords similar rights, have the following rights related to the processing of their personal data:

  • Right of access (Art. 15 GDPR) — the right to obtain confirmation as to whether personal data is being processed and, if so, to access the data and related information.
  • Right to rectification (Art. 16 GDPR) — the right to request correction of inaccurate personal data without undue delay.
  • Right to erasure / right to be forgotten (Art. 17 GDPR) — the right to request deletion of personal data when it is no longer necessary for the purposes for which it was collected, or when consent is withdrawn.
  • Right to restrict processing (Art. 18 GDPR) — the right to request that processing of personal data be restricted under certain circumstances.
  • Right to data portability (Art. 20 GDPR) — the right to receive personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
  • Right to object (Art. 21 GDPR) — the right to object to processing based on legitimate interests or direct marketing at any time.
  • Right to withdraw consent (Art. 7(3) GDPR) — the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  • Right to lodge a complaint — the right to lodge a complaint with the supervisory authority. For Users in Poland, the competent authority is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, Poland, uodo.gov.pl).
  • Right not to be subject to automated decision-making (Art. 22 GDPR) — the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects the User.

To exercise any of these rights, please contact us at hello@oligamy.com. We will respond to your request without undue delay and in any event within one month of receipt. This period may be extended by two further months where necessary, taking into account the complexity and number of requests.

ADDITIONAL RIGHTS FOR CALIFORNIA RESIDENTS (CCPA/CPRA)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA). These include:

  • Right to know — the right to request disclosure of the categories and specific pieces of personal information collected, the sources, the business purposes, and the categories of third parties with whom data is shared.
  • Right to delete — the right to request deletion of personal information collected.
  • Right to correct — the right to request correction of inaccurate personal information.
  • Right to opt-out of sale/sharing — the right to opt out of the sale or sharing of personal information. The Administrator does not sell personal data. However, the use of certain third-party cookies (e.g., Google Ads) may constitute "sharing" under the CCPA. You can opt out through our cookie consent preferences or by using a Global Privacy Control (GPC) signal in your browser.
  • Right to limit use of sensitive personal information — the right to limit the use and disclosure of sensitive personal information.
  • Right to non-discrimination — the right not to receive discriminatory treatment for exercising your privacy rights.

The Administrator honors Global Privacy Control (GPC) signals as a valid opt-out request in accordance with applicable law. To exercise your CCPA rights, contact us at hello@oligamy.com.

DO NOT TRACK / GLOBAL PRIVACY CONTROL

The Website recognizes and responds to Global Privacy Control (GPC) signals transmitted by your browser. When a GPC signal is detected, we treat it as a valid opt-out of the sale or sharing of personal information and disable non-essential tracking technologies for that session. Some browsers also offer a "Do Not Track" (DNT) feature; however, there is no universally accepted standard for DNT signals, and the Website may not respond to DNT signals separately from GPC.

DATA SECURITY

The Administrator implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including but not limited to:

  • Encryption of data in transit using TLS/SSL protocols
  • Access control mechanisms limiting data access to authorized personnel only
  • Regular security assessments and updates
  • Secure hosting infrastructure with appropriate certifications
  • Employee training on data protection and information security

Despite these measures, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security.

THIRD-PARTY LINKS

The Website may contain links to third-party websites, services, or applications that are not operated by the Administrator. We are not responsible for the privacy practices or content of such third-party services. We encourage Users to review the privacy policies of any third-party website they visit.

CHANGES TO THE PRIVACY POLICY

The Administrator reserves the right to modify this Privacy Policy at any time. The current version of the Policy will always be available on the Website. In the event of significant changes, we will make reasonable efforts to notify Users (e.g., through a notice on the Website or via email). Continued use of the Service after any changes to the Policy constitutes acceptance of the updated Policy. We encourage Users to review this Policy periodically.

CONTACT

For matters related to personal data processing, to exercise your data protection rights, or for any questions regarding this Privacy Policy, Users can contact the Administrator via email at hello@oligamy.com or by mail at:

Oligamy Software Sp. z o.o.
Attn: Data Protection
38 Nowiec Street
80-293 Gdańsk, Poland

We aim to respond to all legitimate requests within one month. If your request is particularly complex, we will notify you and may take up to three months to respond.

Last updated: 19.02.2026