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© 2026 · codefunded services sp. z o.o.—Privacy policy—

LEGAL

Privacy policy

Last updated: 2026-04-24 · Version: 1.0


1. General information

This privacy policy describes how Codefunded Services sp. z o.o. processes personal data collected through the website codefunded.com, its subdomains ("Website"), and related communication channels.

Processing is carried out 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 (General Data Protection Regulation - "GDPR") and the Polish Act on Electronic Communication of 12 July 2024.


2. Data controller

The controller of personal data is Codefunded Services spółka z ograniczoną odpowiedzialnością, with its registered office at ul. Mogilska 43, 31-154 Kraków, Poland, entered into the Register of Entrepreneurs of the National Court Register under KRS number 0001023704, NIP PL6751779056, REGON 524688835, share capital 5,000 PLN (hereinafter "Codefunded", "we", "us", "our").

Contact:

  • email: contact@codefunded.com
  • postal: ul. Mogilska 43, 31-154 Kraków, Poland

3. Purposes of processing and legal basis

3.1 Contact form and direct correspondence

When you submit the contact form on our Website ("Start a conversation" - name, email, free-text message) or reach out to us by email, we process your personal data to respond to your inquiry and conduct related business communication. The legal basis is our legitimate interest (Article 6(1)(f) GDPR) in handling inbound correspondence, or - where the inquiry initiates pre-contractual steps - Article 6(1)(b) GDPR.

Providing your name and email is voluntary but necessary for us to reply. Data is retained for 12 months from the last message in the exchange. If the inquiry leads to a contractual relationship, retention is extended for the duration of the contract, the limitation period for related claims, and the tax archival period (typically 5 years from the end of the relevant fiscal year).

3.2 Scheduling meetings

When you book a call through our scheduling tool (Google Calendar / Google Workspace appointment scheduling), we process your name, email address, the chosen time slot, timezone, and any notes you voluntarily provide. The purpose is to arrange and conduct the meeting. The legal basis is our legitimate interest in responding to a business inquiry (Article 6(1)(f) GDPR) or, where the meeting is part of pre-contractual steps, Article 6(1)(b) GDPR. Retention: 12 months from the meeting date, unless the engagement progresses - in which case the contract-performance retention rule applies.

3.3 Website usage analysis and product analytics

When you use the Website, we may process your IP address (truncated where possible), device type, browser type and version, pages visited, referrer, interaction events, and - where you have consented - session recordings. The purpose is to understand aggregate Website usage, improve functionality and content, debug issues, and protect against abuse.

  • For essential / anonymized analytics the legal basis is our legitimate interest (Article 6(1)(f) GDPR).
  • For non-essential analytics, session replay, and any storage/retrieval of information on your device beyond what is strictly necessary, the legal basis is your consent (Article 6(1)(a) GDPR), collected via our cookie consent mechanism.

Data is retained for 12 months. Session recordings are retained for the lifetime set in the analytics tool (typically up to 12 months).

3.4 Marketing and advertising measurement

Where you consent, we may process identifiers set by LinkedIn (LinkedIn Insight Tag) and Google (Google Ads / Google Analytics tags) to measure the performance of our advertising campaigns, attribute conversions, and build audiences for remarketing. The legal basis is your consent (Article 6(1)(a) GDPR). Consent can be withdrawn at any time via the cookie consent mechanism on the Website. Retention follows the default retention of the respective platforms, generally up to 13 months.

3.5 Contract performance and client relationship management

When we engage with you as a client, prospect, partner, or supplier, we process business contact data, identifiers, contract details, correspondence, project deliverables, and billing information. The legal bases are:

  • performance of a contract or steps taken at your request prior to entering into a contract (Article 6(1)(b) GDPR);
  • compliance with legal obligations, in particular accounting and tax obligations (Article 6(1)(c) GDPR read with the Polish Accounting Act of 29 September 1994);
  • our legitimate interest in managing our client and partner relationships (Article 6(1)(f) GDPR).

Retention: duration of the engagement + the limitation period for related claims under Polish civil law + the tax archival period (5 years from the end of the relevant fiscal year).

3.6 Claims, legal obligations, archiving

Your personal data may additionally be processed:

  • to pursue or defend against legal claims - for the relevant limitation period under Polish law;
  • to comply with legal obligations imposed on us (e.g. tax, accounting, responding to authorities) - for the period required by law;
  • to maintain backups and archives - for the period defined by our backup and retention policies.

The legal basis is Article 6(1)(c) GDPR (legal obligation) or Article 6(1)(f) GDPR (legitimate interest in the defense of claims and in operational resilience).


4. Scope of personal data being processed

We process the following categories of personal data:

  • Contact form - name, email address, message content, date and time of submission, any additional information you voluntarily include.
  • Email correspondence - sender email address, name, message content, attachments, metadata.
  • Scheduling - name, email, selected time slot, timezone, meeting notes.
  • Website analytics and product analytics - IP address (truncated where possible), device and browser metadata, pages visited, referrer, interaction events, consent choices, and - subject to consent - session recordings.
  • Advertising measurement - advertising identifiers and conversion signals set by LinkedIn and Google, subject to consent.
  • Client, prospect, and partner data - business contact details, company name, role, identifiers (NIP/VAT, KRS, address), contract and project details, correspondence, billing and payment data.

We do not knowingly process special categories of personal data (Article 9 GDPR) or data of children under 16. Please do not submit such data via the Website.


5. Retention periods

Purpose
Contact-form correspondence
Data scope
name, email, message
Legal basis
Art. 6(1)(f) GDPR (Art. 6(1)(b) if pre-contractual)
Retention
12 months from last contact; extended if a contract is signed
Purpose
Scheduling
Data scope
name, email, meeting details
Legal basis
Art. 6(1)(f) / (b) GDPR
Retention
12 months from the meeting date
Purpose
Website and product analytics
Data scope
IP, device, behavior, events
Legal basis
Art. 6(1)(f) or (a) GDPR
Retention
12 months
Purpose
Session recordings
Data scope
session replay data
Legal basis
Art. 6(1)(a) GDPR
Retention
Up to 12 months (tool default)
Purpose
Marketing / advertising measurement
Data scope
platform identifiers, conversions
Legal basis
Art. 6(1)(a) GDPR
Retention
Up to 13 months (platform default)
Purpose
Contract performance
Data scope
client and billing data
Legal basis
Art. 6(1)(b) GDPR
Retention
Duration of contract + limitation period + 5 years tax archival
Purpose
Accounting / invoicing
Data scope
invoice and transaction data
Legal basis
Art. 6(1)(c) GDPR + PL Accounting Act
Retention
5 years from end of fiscal year
Purpose
Claim defense
Data scope
relevant identifiers
Legal basis
Art. 6(1)(f) GDPR
Retention
Applicable limitation period under Polish law
PurposeData scopeLegal basisRetention
Contact-form correspondencename, email, messageArt. 6(1)(f) GDPR (Art. 6(1)(b) if pre-contractual)12 months from last contact; extended if a contract is signed
Schedulingname, email, meeting detailsArt. 6(1)(f) / (b) GDPR12 months from the meeting date
Website and product analyticsIP, device, behavior, eventsArt. 6(1)(f) or (a) GDPR12 months
Session recordingssession replay dataArt. 6(1)(a) GDPRUp to 12 months (tool default)
Marketing / advertising measurementplatform identifiers, conversionsArt. 6(1)(a) GDPRUp to 13 months (platform default)
Contract performanceclient and billing dataArt. 6(1)(b) GDPRDuration of contract + limitation period + 5 years tax archival
Accounting / invoicinginvoice and transaction dataArt. 6(1)(c) GDPR + PL Accounting Act5 years from end of fiscal year
Claim defenserelevant identifiersArt. 6(1)(f) GDPRApplicable limitation period under Polish law

6. Recipients of personal data

We may share your personal data with:

  • Public authorities - when required by law (courts, tax authorities, the President of the Personal Data Protection Office, law-enforcement agencies).
  • Processors acting on our behalf under data processing agreements (DPAs):
    • Vercel Inc. (USA) - Website hosting and delivery.
    • Microsoft Ireland Operations Ltd. / Microsoft Corporation (Azure) (Ireland / USA) - cloud infrastructure hosting.
    • Hetzner Online GmbH (Germany) - server infrastructure hosting.
    • Twilio Inc. (SendGrid) (USA) - transactional and operational email delivery.
    • Google Ireland Ltd. / Google LLC (Google Workspace, Google Calendar, Google Ads) (Ireland / USA) - business email, document storage, scheduling, advertising measurement.
    • Notion Labs, Inc. (USA) - internal document and CRM workspace.
    • PostHog, Inc. (USA) - product and website analytics, session recording, feature flags.
    • LinkedIn Ireland Unlimited Company / LinkedIn Corporation (Ireland / USA) - advertising measurement (LinkedIn Insight Tag), professional page.
  • Professional service providers - legal, accounting, audit, and consulting firms acting under confidentiality obligations.

A current master list of processors is maintained internally and can be provided on request by writing to contact@codefunded.com.


7. Transfer of personal data to third countries

Some of our processors are located outside the European Economic Area (EEA), primarily in the United States. Where such transfers occur, they are made on the basis of:

  • Adequacy decisions issued by the European Commission, where applicable.
  • The EU-US Data Privacy Framework (DPF) - for processors certified under DPF, including (subject to their current certification status) Vercel, Microsoft, Google, SendGrid/Twilio, Notion, PostHog, and LinkedIn.
  • Standard Contractual Clauses (SCCs) issued by the European Commission - where a processor is not DPF-certified or where additional transfer mechanisms are required.
  • Binding Corporate Rules (BCRs) - where approved by a competent supervisory authority.

We only transfer data when necessary for the purposes described in this policy and when appropriate safeguards are in place. You may request a copy of the relevant safeguards by contacting contact@codefunded.com.


8. Cookies

The Website uses cookies and similar technologies (local storage, pixels) to operate the site, remember your preferences, measure usage, and - subject to your consent - measure advertising performance.

Categories used on the Website:

  • Essential - required for the Website to function (security, load balancing, consent state). Processed on the basis of our legitimate interest (Article 6(1)(f) GDPR). No consent required, but disclosed here.
  • Analytics and product analytics (PostHog) - traffic patterns, feature usage, session replay. Processed on the basis of consent (Article 6(1)(a) GDPR).
  • Marketing / advertising measurement (LinkedIn Insight Tag, Google Ads / Google Analytics tags) - conversion measurement and remarketing. Processed on the basis of consent (Article 6(1)(a) GDPR).

Non-essential cookies are loaded only after you provide consent through the consent mechanism on the Website. You can change or withdraw your consent at any time via , or by adjusting your browser settings to block or delete cookies. Information on managing cookies is available at allaboutcookies.org.

For details on how individual vendors process cookie data, consult their privacy notices:

  • PostHog - https://posthog.com/privacy
  • Google - https://policies.google.com/privacy
  • LinkedIn - https://www.linkedin.com/legal/privacy-policy

Cookies we use

ToolCookie / storagePurposeLifetime
PostHogph_* cookies and localStorageProduct and website analytics, session recordingUp to 12 months
Google Tag Manager / GA4_ga, _ga_*, _gid, _gatMarketing measurement and advertisingUp to 13 months (platform default)
Cloudflare TurnstileCloudflare challenge cookiesBot protection (essential, no consent required)Session
Consent decisioncdfd-consent-v1 (localStorage, not a cookie)Remember your cookie choice12 months

9. Your rights

Under the GDPR you have the right to:

  • access your personal data and receive a copy (Article 15 GDPR);
  • rectify inaccurate or incomplete data (Article 16 GDPR);
  • request erasure of your data ("right to be forgotten" - Article 17 GDPR);
  • restrict processing (Article 18 GDPR);
  • data portability (Article 20 GDPR);
  • object to processing based on legitimate interest, including profiling (Article 21 GDPR);
  • withdraw consent at any time, without affecting the lawfulness of prior processing (Article 7 GDPR);
  • lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, Poland) or another competent supervisory authority (Article 77 GDPR).

To exercise any of these rights, contact us at contact@codefunded.com. We will respond within the statutory period (typically 30 days, extendable by up to two further months for complex requests, with prior notice).

We do not make decisions that produce legal effects concerning you, or similarly significantly affect you, based solely on automated processing, including profiling (Article 22 GDPR).


10. Social media - LinkedIn company page (joint controller)

We operate a company profile on LinkedIn. When you interact with our LinkedIn page or content, LinkedIn processes your data according to its own privacy policy.

For statistical insights about our page (LinkedIn Page Insights), we act as a joint controller with LinkedIn Ireland Unlimited Company within the meaning of Article 26 GDPR. The essence of the joint-controller arrangement is available at:

  • https://legal.linkedin.com/pages-joint-controller-addendum

For all other processing carried out by LinkedIn - including profile, feed, and advertising operations - LinkedIn acts as an independent controller. Please refer to LinkedIn's privacy policy at https://www.linkedin.com/legal/privacy-policy for details.

We do not operate Facebook or Instagram company profiles.


11. Links to third-party websites

The Website may contain links to third-party websites, services, or resources. We are not responsible for the privacy practices of those third parties. We recommend reading the privacy policy of any external site you visit.


12. Security

We apply appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, and disclosure, including access controls, encryption in transit, logging, backups, and vendor due diligence for processors.


13. Changes to this policy

We may update this privacy policy to reflect changes in our processing activities, legal requirements, or business operations. Updates will be published on this page with an updated "Last updated" date and version number. For material changes, we will display a prominent notice on the Website and, where appropriate, notify affected individuals directly.


Changelog

  • 2026-04-24 - v1.0 - Initial publication.