1. Who we are
adcfo.eu is operated by a business registered in Poland, trading under the brand name Ad/CFO. The operator of this website is the controller of the personal data described in this Privacy Policy, unless another organisation acts as an independent controller for its own processing.
Privacy questions and requests concerning your rights can be sent to hello@adcfo.eu. Full postal and tax registration details are set out in section 11.
2. Scope of this Privacy Policy
This Privacy Policy applies to personal data processed through adcfo.eu and in connection with business enquiries, introductory meetings, proposals, prospective engagements and client relationships.
Where a particular engagement requires additional privacy information or data-processing terms, those documents may apply in addition to this Privacy Policy.
3. Personal data we may process
Depending on how you interact with Ad/CFO, we may process the following categories of personal data:
- Contact and professional information, such as your name, business email address, company, job title or role and other professional details.
- Communications and business information, including enquiries, correspondence, meeting details, proposals, notes and information you choose to provide about your business or a potential engagement.
- Technical and security information, such as IP address, browser or device information, request and log data, referral information and security-related signals generated when you use the website.
- Contractual and relationship information, where relevant, including records relating to an engagement, services requested, commercial discussions and related administration.
- Other information you voluntarily provide to us in the course of a business interaction.
We may receive personal data directly from you or, where permitted by law, from your organisation, business partners, referrals, service providers or publicly available professional sources.
We do not intentionally seek special-category personal data through the public website. Please avoid sending sensitive personal information unless it is genuinely necessary for a specific business purpose.
4. How and why we use personal data
| Purpose | GDPR legal basis |
|---|---|
| Operating, securing, maintaining and troubleshooting our website and business systems | Legitimate interests — Art. 6(1)(f) |
| Responding to enquiries, arranging meetings and discussing a possible engagement | Steps taken at your request before entering into a contract — Art. 6(1)(b), and/or legitimate interests — Art. 6(1)(f) |
| Providing services and managing an established business relationship | Performance of a contract — Art. 6(1)(b) |
| Managing business administration, records, compliance and legal obligations | Legal obligation — Art. 6(1)(c), and/or legitimate interests — Art. 6(1)(f) |
| Protecting our business, systems, legal rights and preventing misuse or fraud | Legitimate interests — Art. 6(1)(f) |
Our legitimate interests include operating and securing the website and business systems, responding to B2B enquiries, managing business administration and records, protecting our legal rights, and preventing misuse or fraud. Where we rely on legitimate interests, we consider whether those interests are compatible with your rights and reasonable expectations. Where consent is required by law for a particular activity or technology, we will rely on consent instead.
6. International transfers
Some of our service providers may process personal data outside Poland or the European Economic Area.
Where the GDPR restricts such transfers, we use or require an appropriate transfer mechanism, such as an adequacy decision, Standard Contractual Clauses approved by the European Commission or another lawful safeguard recognised under applicable data-protection law.
Further information about applicable safeguards may be requested by contacting hello@adcfo.eu.
8. Data retention
We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.
The applicable retention period depends on factors including the nature of the information, the status of an enquiry or business relationship, contractual requirements, security needs, statutory accounting or tax obligations and limitation periods for potential legal claims.
When personal data is no longer required, we take reasonable steps to delete, anonymise or otherwise securely dispose of it, subject to applicable legal requirements.
9. Your GDPR rights
Subject to the conditions and exceptions set out in the GDPR, you have certain rights in relation to your personal data. These may include the right to:
- request access to your personal data;
- request correction of inaccurate or incomplete data;
- request erasure of personal data;
- request restriction of processing;
- receive certain personal data in a portable format;
- object to processing based on legitimate interests; and
- withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.
To exercise your rights, contact hello@adcfo.eu. We may request information reasonably necessary to verify your identity and protect personal data against unauthorised disclosure.
10. Complaints
You have the right to lodge a complaint with a competent data-protection supervisory authority, including the authority in the country of your habitual residence, place of work or the place of an alleged infringement, as provided by the GDPR.
The supervisory authority in Poland is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO). If your company is established elsewhere in the EEA, you may also lodge a complaint with the supervisory authority of that country.
11. Security, changes and contact
We use reasonable organisational and technical measures appropriate to the nature of the information we process. However, no method of internet transmission or electronic storage can be guaranteed to be completely secure.
We may update this Privacy Policy from time to time to reflect changes in our business, website, service providers, processing activities or legal requirements. The current version will be published on this page with its revision date.
Questions about this Privacy Policy, our processing of personal data or requests concerning your GDPR rights can be sent to hello@adcfo.eu, or in writing to the controller at the address below.
VG Consulting (Viacheslav Gubanov), trading as Ad/CFO
Powstańców Śląskich 9, 53-332 Wrocław, Poland
EU VAT identification number: PL8971961491