Privacy Policy

This Privacy Policy describes how we collect, use, store, and protect your personal data when you interact with our website or services.

We are committed to ensuring that your privacy is respected and that personal data is processed in compliance with applicable law, in particular the 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 (commonly known as GDPR, or RODO in Poland).

1. Data Controller

The administrator (controller) of your personal data is:

Digital Rockers Studio Spółka z ograniczoną odpowiedzialnością

Brand: ForePrime

KRS: 0001060946

NIP: 7831888753

REGON: 526562251

Registered office: ul. Święty Marcin 29/8, 61-806 Poznań, Poland

Email: [insert email, e.g., hello@foreprime.co]

2. What Data We Collect and Why

We only collect personal data necessary for specific, legitimate purposes outlined below.

a) Website Use & Functionality

We collect basic technical data (e.g., IP address, device identifiers, browser type) when you visit our website.

Purpose: To enable functionality, security, and performance of the site.

Legal Basis: Article 6(1)(b) GDPR — performance of a service (site access)

b) Newsletter Subscription

If you subscribe to our newsletter, we collect your email address and possibly name, phone number, or profession (if applicable).

Purpose: To send updates, news, and curated content.

Legal Basis: Article 6(1)(a) GDPR — consent (which can be withdrawn at any time).

c) Cookies and Analytics

We use cookies to enhance user experience, ensure session continuity, and monitor engagement (e.g. via Google Analytics).

Legal Basis: Article 6(1)(f) GDPR — legitimate interest in optimizing the site, except for strictly necessary cookies, which are required for operation.

You can manage cookie settings through your browser or decline non-essential cookies when prompted.

d) Legitimate Interest

We may process specific data to analyze site usage, defend against legal claims, or improve our services.

Legal Basis: Article 6(1)(f) GDPR — our legitimate interest, always balanced against your rights.

3. Use of Cookies

Cookies are small text files stored on your device. Our website uses:

  • Essential cookies (e.g. session maintenance, fraud protection)
  • Functional cookies (e.g. save display preferences)
  • Analytical cookies (e.g. user activity via Google Analytics)

You can manage cookies through your browser at any time. Please note that disabling cookies may impact your experience or prevent access to certain functions.

4. Data Retention

We retain personal data only for as long as necessary:

  • Consent-based data (e.g. newsletter): until consent is withdrawn
  • Contractual data: for the duration of the agreement + statutory limitation period
  • Legal obligation-based data: as long as required by law
  • Legitimate interest-based data: as long as the interest exists

We may retain data longer if necessary for the establishment or defence of legal claims. Afterward, data is deleted or anonymized.

5. Data Recipients

We may share your data with:

  • Trusted external service providers (e.g., legal, IT, marketing, accounting)
  • Public authorities, when legally required

All third-party processors operate under strict data protection obligations and only to the extent necessary for the purposes stated.

6. International Data Transfers

Some of our providers may operate outside the European Economic Area (EEA). In such cases, we ensure appropriate safeguards are in place, such as:

  • Standard Contractual Clauses (SCCs)
  • EU-U.S. Data Privacy Framework certification (where applicable)

We transfer data only when it meets GDPR adequacy standards.

7. Your Rights Under GDPR

You have the right to:

  • Access your data (Art. 15)
  • Rectify inaccuracies (Art. 16)
  • Request deletion ("right to be forgotten", Art. 17)
  • Restrict processing (Art. 18)
  • Data portability (Art. 20)
  • Object to processing (Art. 21) — including direct marketing
  • Withdraw consent at any time (Art. 7)
  • Complain with the President of the Personal Data Protection Office (UODO) in Poland.

We may continue processing your data if there are overriding legitimate grounds or for legal claim purposes.

8. Data Security

We implement appropriate technical and organizational safeguards to protect your data from unauthorized access, loss, or destruction. Access is restricted to authorized personnel only.

9. Changes to This Policy

We may update this Privacy Policy in response to legal, technical, or operational changes. Updated versions will be published on this page with a new “Effective as of” date.