Privacy Policy

§1. Data Controller

The controller of personal data collected through the website blackless.pl (hereinafter: the "Website") is:

(hereinafter: the "Controller").

§2. Scope and Purpose of Data Processing

The Controller processes personal data of Website Users for the following purposes:

• Waitlist management — e-mail address, first name (optional). Legal basis: Art. 6(1)(a) GDPR (consent) and Art. 6(1)(b) GDPR (steps taken at the request of the data subject prior to entering into a contract).
• Contact form / e-mail correspondence — e-mail address, first name, message content. Legal basis: Art. 6(1)(f) GDPR (legitimate interest of the Controller — responding to inquiries).
• Analytics and Website improvement — data collected automatically: IP address, browser type, screen resolution, operating system, visit duration, pages visited. Legal basis: Art. 6(1)(a) GDPR (consent for analytical cookies) and Art. 6(1)(f) GDPR (legitimate interest — traffic analysis).
• Personalization and A/B testing — a random identifier assigned to the User's browser (UUID) that does not allow personal identification. It is used to ensure consistent display of page variants during A/B tests. Legal basis: Art. 6(1)(f) GDPR (legitimate interest of the Controller — optimizing Website performance).

§3. Data Recipients

Users' personal data may be shared with the following categories of recipients:

• Vercel Inc. (San Francisco, USA) — Website hosting and Vercel Analytics service. Data may be transferred to the USA based on Standard Contractual Clauses (SCCs).
• Google LLC (Mountain View, USA) — Google Analytics service for Website traffic analysis. Data may be transferred to the USA based on Standard Contractual Clauses (SCCs).

The Controller does not sell or share personal data with third parties for marketing purposes.

§4. Data Retention Period

• Waitlist data — until consent is withdrawn or until the launch of sales and any subsequent order placement.
• Contact form data — for the period necessary to handle the inquiry, no longer than 12 months from the last contact.
• Analytical data (cookies) — in accordance with the validity period of respective cookies (details in §7).

§5. User Rights

Every User has the following rights under the GDPR:

• right of access to personal data (Art. 15 GDPR),
• right to rectification of data (Art. 16 GDPR),
• right to erasure — "right to be forgotten" (Art. 17 GDPR),
• right to restriction of processing (Art. 18 GDPR),
• right to data portability (Art. 20 GDPR),
• right to object to processing (Art. 21 GDPR),
• right to withdraw consent at any time (without affecting the lawfulness of processing carried out prior to withdrawal),
• right to lodge a complaint with the supervisory authority — the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw, Poland).

To exercise the above rights, please contact us at: kontakt@blackless.pl.

§6. Voluntary Provision of Data

Providing personal data is voluntary but necessary to sign up for the waitlist or use the contact form. Failure to provide the required data will prevent the fulfillment of the above purposes.

§7. Cookie Policy

7.1. What are cookies?

Cookies are small text files stored on the User's device (computer, phone, tablet) while using the Website. They are used to ensure the proper functioning of the Website and to analyze how Users interact with it.

7.2. Types of cookies used on the Website

7.3. Legal basis for cookies

Essential cookies are used on the basis of Art. 173(3) of the Polish Telecommunications Law (they are necessary to provide the service electronically). Analytical cookies (Google Analytics, Vercel Analytics) are used on the basis of User consent (Art. 173(2) of the Telecommunications Law in conjunction with Art. 6(1)(a) GDPR).

7.4. Managing cookies

Upon the first visit to the Website, a cookie banner is displayed allowing the User to grant or refuse consent to specific categories of cookies. The User may change cookie preferences at any time through their browser settings. Detailed information on managing cookies is available in the browser documentation.

Refusing consent to analytical cookies does not affect the ability to use the Website.

§8. Data Security

The Controller applies appropriate technical and organizational measures to protect processed personal data, in particular safeguarding data against unauthorized access, loss, or destruction. The Website uses SSL/TLS encryption.

§9. Changes to the Privacy Policy

The Controller reserves the right to amend this Privacy Policy. Users will be informed of any changes through the publication of an updated version on the Website. The date of the last update is shown at the top of this document.

§10. Contact

For matters related to the protection of personal data, please contact us at: kontakt@blackless.pl.