Request a ConsultationLast updated: 10 September 2026
This Privacy Policy explains how PT78 collects, uses, shares and protects personal data when you visit pt78.space, contact us, book a consultation, receive our business communications, or engage us as a service provider.
1. Who We Are
The controller responsible for your personal data is:
- PT78 — Ivan Hrebinchenko, individual entrepreneur registered in Ukraine
- Correspondence address: Poznańska 37, 00-689 Warsaw, Poland
- Email: info@pt78.space
- Telephone: +48 575 416 626
For all privacy matters, including requests to exercise your rights, contact us at info@pt78.space with the subject line “Privacy Request”.
2. Scope
This Policy applies to personal data we process as a controller — that is, where we decide why and how the data is used. Where we process personal data on behalf of a client as part of delivering our services (for example, data inside a client’s advertising account or CRM), we act as a processor, and that processing is governed by our Data Processing Agreement with that client.
Our services are directed at businesses. This Website is not intended for consumers or for anyone under the age of 18.
3. Personal Data We Collect
3.1 Data you give us
- Enquiry and audit request forms: name, business email address, telephone number, company name, website address, and any information you include in a message field.
- Consultation bookings: when you schedule a call through our booking tool, your name, email address, chosen time slot, time zone and any answers to booking questions.
- Correspondence: the content of emails, WhatsApp messages, calls and meetings between you and us, including notes we take.
- Client onboarding: billing details, contract signatory details, and access credentials or delegated access to your marketing platforms.
3.2 Data we collect automatically
- Technical data: IP address, browser type and version, operating system, device type, screen resolution, referring URL, language settings, approximate location derived from IP address at city or region level.
- Usage data: pages viewed, time on page, scroll depth, links and buttons clicked, forms started and submitted, entry and exit pages, and the campaign, search term or referring site that brought you here.
- Session recordings and heatmaps: where you consent to analytics cookies, we use Microsoft Clarity to record mouse movement, scrolling and clicks and to reconstruct them as a session replay and aggregated heatmaps. The tool is configured to mask text content, so what you type into form fields is not captured. We do not use recordings to identify individual visitors.
- Advertising interaction data: where you consent to marketing cookies, identifiers that allow our advertising on Google and Meta platforms to be measured and addressed.
- Server logs: requests made to our web server, including date, time and the resource requested, kept for security and troubleshooting.
- Cookies and similar technologies: see our Cookie Policy for the full list and retention periods.
3.3 Data we obtain from other sources
For business development purposes, we may collect professional contact details from publicly available and commercially available sources, including company websites, professional networks such as LinkedIn, business directories, public registers, trade publications, event attendee lists, and reputable B2B data providers.
The categories of data involved are limited to business contact information: full name, job title, employer, business email address, business telephone number, professional profile URL and publicly stated company information. We do not collect special categories of personal data and we do not seek private or personal contact details.
4. Why We Use Your Data and Our Legal Basis
| Purpose | Legal basis (UK/EU GDPR) |
|---|---|
| Responding to your enquiry, preparing a proposal or free audit | Steps taken at your request prior to entering a contract (Art. 6(1)(b)); legitimate interests (Art. 6(1)(f)) |
| Delivering our services and managing the client relationship | Performance of a contract (Art. 6(1)(b)) |
| Invoicing, accounting and tax record keeping | Legal obligation (Art. 6(1)(c)) |
| Business-to-business outreach about services relevant to the recipient’s professional role | Legitimate interests in promoting our services (Art. 6(1)(f)), subject to the safeguards in section 5; consent where required by local law |
| Sending our newsletter and marketing emails to subscribers | Consent (Art. 6(1)(a)) or soft opt-in where permitted |
| Website analytics, session recording and heatmaps, to measure and improve the Website | Consent (Art. 6(1)(a)), given through our cookie banner |
| Advertising measurement, conversion tracking, remarketing and audience building on Google and Meta platforms | Consent (Art. 6(1)(a)), given through our cookie banner |
| Securing our Website and systems, preventing fraud and abuse | Legitimate interests (Art. 6(1)(f)) |
| Establishing, exercising or defending legal claims | Legitimate interests (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) |
Where we rely on legitimate interests, we have assessed that our interest in operating and growing a business-to-business service does not override your rights and freedoms, taking into account that the data is professional in nature, the contact relates to the recipient’s job function, and an opt-out is available in every message.
Where we rely on consent, you may withdraw it at any time through the Cookie Settings link in the Website footer, without affecting the lawfulness of processing carried out before withdrawal.
5. Business Communications and Outreach
If you receive a business email from us, the following applies:
- Every message identifies PT78 clearly, states our postal address, and contains a working unsubscribe link or a plain instruction on how to opt out.
- We honour opt-out requests promptly and in any case within ten (10) business days, and we add the address to a suppression list so it is not contacted again.
- We contact business addresses in a professional capacity about services relevant to the recipient’s role. We do not contact private individuals for marketing purposes.
- On request, we will tell you the source from which we obtained your contact details.
- In jurisdictions where prior consent is required for commercial email to business recipients, we contact recipients only on the basis of consent or an existing business relationship, as permitted by the applicable law.
To opt out of all communications at any time, email info@pt78.space with “Unsubscribe” in the subject line.
6. Cookies, Analytics and Advertising Technologies
We use Google Tag Manager to manage the following tools on this Website: Google Analytics 4, Google Ads conversion tracking and remarketing, the Meta Pixel, and Microsoft Clarity session recording and heatmaps.
None of these is activated until you give consent through our cookie banner, and you may withdraw consent at any time. We apply Google Consent Mode so that Google services adjust their behaviour according to your choice. Full details, including every cookie, its provider and its retention period, are set out in our Cookie Policy.
For the collection and transmission of data through the Meta Pixel, PT78 and Meta Platforms Ireland Ltd act as joint controllers under Article 26 GDPR. Meta’s subsequent processing of that data takes place under its own responsibility. You may exercise your rights in respect of that processing against either party; for Meta, see its Privacy Policy.
7. Who We Share Data With
We do not sell personal data for money. We share it with:
- Analytics and advertising platforms — Google Ireland Ltd / Google LLC (Google Analytics, Google Ads, Google Tag Manager), Meta Platforms Ireland Ltd (Meta Pixel) and Microsoft Corporation (Clarity), where you have consented to the corresponding cookie category.
- Service providers acting on our instructions — website hosting, email delivery and outreach platforms, scheduling tools, CRM and project management systems, accounting and payment providers, and communication tools. A current list is available on request.
- Professional advisers — lawyers, accountants and auditors, where necessary and under a duty of confidentiality.
- Authorities — where we are required to disclose data by law, court order or a lawful request from a competent authority.
- A successor entity — in connection with a merger, acquisition or transfer of all or part of our business, subject to the protections in this Policy.
Service providers act under a written agreement that limits them to processing data for the purposes we specify. Advertising and analytics platforms may act as independent or joint controllers for parts of their processing, as described in section 6.
8. International Transfers
We operate from Ukraine and Poland and use service providers located in the European Economic Area, the United Kingdom, the United States and other countries. This means your personal data may be transferred outside the country in which you are located.
Where personal data is transferred from the EEA or the UK to a country that is not covered by an adequacy decision, we rely on appropriate safeguards — principally the European Commission’s Standard Contractual Clauses (and the UK Addendum where relevant), the EU–US Data Privacy Framework where the recipient is certified, supported by additional technical and organisational measures where necessary. A copy of the relevant safeguards is available on request.
9. How Long We Keep Data
| Category | Retention period |
|---|---|
| Enquiries that do not lead to a contract | 24 months from the last contact |
| Client records and correspondence | Duration of the engagement plus 3 years |
| Contracts, invoices and accounting records | As required by applicable tax and accounting law (generally 5–10 years) |
| Marketing contact data and outreach records | Until you opt out, or 24 months of inactivity, whichever comes first |
| Suppression list (opt-out records) | Retained indefinitely, so we can honour your opt-out |
| Website analytics data | Up to 14 months, as configured in Google Analytics |
| Session recordings and heatmaps | In line with the retention period applied by Microsoft Clarity, currently up to 13 months |
| Advertising identifiers and audiences | Up to 13 months, or the shorter period configured on the platform |
| Server and security logs | Up to 12 months |
When a retention period ends, we delete the data or irreversibly anonymise it.
10. Security
We apply technical and organisational measures appropriate to the risk, including encryption of data in transit (TLS), access control on a need-to-know basis, multi-factor authentication on business-critical accounts, password management tooling, regular backups, staff confidentiality obligations, and vendor due diligence. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
11. Your Rights
11.1 If you are in the EEA, the UK, Switzerland or Ukraine
You have the right to: access your data; rectify inaccurate data; request erasure; restrict processing; data portability; object to processing based on legitimate interests, including profiling; object to direct marketing at any time, absolutely and free of charge; and withdraw consent at any time without affecting processing carried out before withdrawal.
To exercise any right, email info@pt78.space. We respond within one month and may extend this by two further months for complex requests, telling you if we do. We may ask for information to verify your identity. Exercising your rights is free of charge unless a request is manifestly unfounded or excessive.
You also have the right to lodge a complaint with a supervisory authority in your country of residence, place of work or the place of the alleged infringement. In Poland this is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw). We would appreciate the chance to address your concern first.
11.2 If you are a resident of California or another US state with privacy legislation
Depending on your state, you may have the right to know what personal information we have collected about you and the categories of sources and recipients; to obtain a copy of it; to request its deletion; to correct inaccurate information; to opt out of the sale or sharing of personal information and of targeted advertising; and not to be discriminated against for exercising these rights.
We do not sell personal information for money. However, when you accept marketing cookies, identifiers are disclosed to Google and Meta for advertising measurement and remarketing, which is treated as “sharing” for cross-context behavioural advertising under California law and as targeted advertising under comparable state laws.
You can opt out at any time by declining or withdrawing marketing cookies through the Cookie Settings link in the Website footer. We also honour the Global Privacy Control signal where your browser sends one, and treat it as a valid opt-out request.
To make any other request, email info@pt78.space. You may use an authorised agent, in which case we will require proof of authorisation.
11.3 If you are in the United Arab Emirates, Saudi Arabia or elsewhere in the GCC
Where the UAE Personal Data Protection Law, the Saudi Personal Data Protection Law or a comparable regional law applies, you may request access to your personal data, its correction or deletion, restriction of processing, and withdrawal of consent, subject to the conditions and exemptions set out in those laws. Requests go to the same address: info@pt78.space.
12. Automated Decision-Making
We do not make decisions producing legal or similarly significant effects about you based solely on automated processing.
13. Children
Our Website and services are not directed at anyone under 18, and we do not knowingly collect their personal data. If you believe a child has provided us with personal data, contact us and we will delete it.
14. Changes to This Policy
We may update this Policy to reflect changes in our practices or in the law. The current version is always published on this page with the date of the last update. Where changes are material, we will take reasonable steps to notify you.
15. Contact
Questions, requests or complaints about this Policy:
- Email: info@pt78.space
- Post: PT78, Poznańska 37, 00-689 Warsaw, Poland
