privacy policy

PRIVACY AND COOKIE POLICY (GDPR)

We respect and protect the privacy of all visitors to our website: mindspark.com.pl (including the subpage https://mindspark.com.pl/travel/). In this document, we explain how MindSpark Sp. z o.o. and MindSpark Travel Sp. z o.o. collect, use, and protect your personal data, as well as how they manage cookies. We will process your data at all times in accordance with applicable data protection laws, including the GDPR.

1. Joint Controllers of Personal Data
The joint controllers of your personal data are:

MindSpark Sp. z o.o.

MindSpark Travel Sp. z o.o.

Contact e-mail address for all matters related to privacy and personal data protection: hello@mindspark.com.pl

  1. What data do we collect, for what purposes, and on what legal basis?

We collect both data provided directly by you and data collected automatically during your visit to the Website. We process them for the following purposes:

  • Handling inquiries and establishing contact (Forms / E-mail):
  • Data scope: name, surname, e-mail address, phone number, company name, position, and other information provided voluntarily in the message content.
  • Purpose and legal basis: providing an answer to your inquiry, presenting an offer, or taking steps at your request prior to entering into a contract (Art. 6(1)(a) and (b) GDPR). We do not collect sensitive data.
  • Analytics, research, and website development (Google Analytics, Microsoft Clarity):
  • Data scope: IP address (anonymized), cookie identifiers, browser type, operating system, geographical location, time spent on the site, navigation paths, and ways of interacting with the website (e.g., clicks, scrolling).
  • Purpose and legal basis: traffic analysis, studying user behavior, optimizing website performance, and adapting its structure to the needs of the audience – exclusively on the basis of your voluntary consent (Art. 6(1)(a) GDPR).
  • Marketing, advertising, and remarketing (Meta Pixel / Facebook):
  • Data scope: online identifiers, website activity data, viewed subpages, device information.
  • Purpose and legal basis: targeting customized advertising content in social media and advertising networks, measuring the effectiveness of marketing campaigns, and conducting remarketing activities – exclusively on the basis of your voluntary consent (Art. 6(1)(a) GDPR).
  • Ensuring proper operation and security of the website (Server logs):
  • Data scope: IP address, server date and time, browser and operating system information.
  • Purpose and legal basis: ensuring stability, security, and proper technical support of the website based on our legitimate interest (Art. 6(1)(f) GDPR).

Data retention period:
 Contact data is stored for the time necessary to handle the inquiry or until consent is withdrawn. Analytical and marketing data are stored for the validity period of individual cookies or until preferences are changed in the consent banner.

  1. Who processes your data? (Data Recipients / Processors)

We entrust your personal data and information collected by cookies for processing to external entities (processors) with whom we cooperate. These are exclusively verified companies providing us with technological, analytical, and organizational services:

  • Server / hosting provider: A company providing hosting and e-mail maintenance services for the mindspark.com.pl domain (processes data in server logs and forms).
  • Google Ireland Limited / Google LLC: Provider of the Google Analytics tool (website traffic analysis) and cloud/tool infrastructure.
  • Microsoft Ireland Operations Ltd. / Microsoft Corporation: Provider of the Microsoft Clarity tool (analysis of behavior and website performance).
  • Meta Platforms Ireland Ltd. / Meta Platforms Inc.: Provider of the Meta Pixel / Facebook tool (marketing campaign effectiveness measurement and analytics).
  • Accounting / bookkeeping office: An external entity handling the accounting of MindSpark Sp. z o.o. and MindSpark Travel Sp. z o.o. (in case an inquiry leads to the issuance of financial documents/invoices).
  1. Automatic data collection and cookies

While using the Website, we automatically collect certain technical information using cookies (small text files saved on your device) and server logs.

Cookies help us ensure the proper operation of the website, create anonymous statistics, and personalize content and advertisements. We do not use this data to directly identify you (e.g., link your browsing profile with your name and surname without separate consent).

  1. Categories of cookies

We have divided cookies into four categories. The legal basis for using necessary cookies is our legitimate interest (Art. 6(1)(f) GDPR). For the remaining categories, you decide which ones you consent to (Art. 6(1)(a) GDPR):

  • Necessary (technical) – they are required for the proper functioning of the website (e.g., navigation, security). You cannot disable them because the Website will not function properly without them.
  • Functional – they allow remembering your preferences and choices (e.g., selected website language or privacy settings).
  • Analytical – we use them (with the help of Google Analytics and Microsoft Clarity tools) to study how users interact with the website, which allows us to improve its performance and structure.
  • Marketing – they help us measure the effectiveness of advertising campaigns, conduct remarketing, and tailor ads to your interests. We cooperate here, among others, with the Meta Pixel system (Facebook).
  1. Data transfer outside the European Economic Area (EEA)

Because we use tools provided by global companies (Google LLC, Microsoft Corporation, Meta Platforms Inc.), the collected technical information may be transferred to servers located in the United States.

We ensure that this transfer is fully legal and secure. We rely on the European Commission’s implementing decision stating an adequate level of personal data protection in the USA (the so-called EU-US Data Privacy Framework – our providers are certified entities in this program) or on approved Standard Contractual Clauses (SCCs).

  1. Your Rights and consent management

You have the right to:

  • Access your data, rectify it, delete it (“right to be forgotten”), or restrict its processing.
  • Object to the processing of your data.
  • Expire or withdraw your consent at any time.
  • Lodge a complaint with a supervisory authority (President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw).

Cookie management:

  • You have full control over cookies (except for necessary ones). You can freely set your preferences in our cookie banner during your first visit.
  • You can withdraw or change your consent at any time – just click change privacy settings or contact us directly at: hello@mindspark.com.pl. Remember that withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.