Privacy Policy

General information

This document sets out the Privacy Policy of the website cybroskill.com (hereinafter the “Website”). The controller of the Website is Skrobo.Tech P.S.A. with its registered office in Tarnów, ul. Pułaskiego 50A/63, 33-100 Tarnów, Poland, NIP (tax ID): 9930711786, REGON: 543016360. [TO BE VERIFIED: current company registration data — registered address, KRS number, NIP/REGON]

The website cybroskill.com and the Cybroskill brand are operated by Skrobo.Tech P.S.A.

Personal data collected by the Website’s controller are processed 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ EU L 119, p. 1), hereinafter: the GDPR.

The Website’s controller takes particular care to protect the privacy of, and the information provided by, the Website’s users. The controller selects and applies, with due diligence, appropriate technical measures, including software-related and organisational measures, ensuring the protection of the processed data; in particular, it protects the data against disclosure to unauthorised persons, unauthorised disclosure, loss and destruction, unauthorised modification, as well as against processing in breach of applicable law.

The services available on the Website are addressed to adults — parents and legal guardians of children aged 6–14 — and to businesses. Contracts for the services are concluded exclusively by adults. Children’s personal data (such as first name, age and interests) are processed only to the extent necessary to provide the educational services, and only on the basis of the consent, and with the knowledge, of the child’s parent or legal guardian.

Personal data

Data controller

The controller of your personal data is:

Skrobo.Tech P.S.A.

Regarding your personal data, you can contact the data controller via:

  • email: info@cybroskill.com
  • post: ul. Pułaskiego 50A/63, 33-100 Tarnów, Poland
  • phone: +48 508 240 464

Purposes and legal bases of the processing of personal data

The data controller processes your personal data for the following purposes and to the following extent:

  • handling the contact form and starter lesson requests, i.e. taking steps prior to entering into a contract at your request — we process the data provided in the contact form: full name, email address, the content of the message and, if you provide them, the child’s age and interests. The form is handled by a script on the Website’s server (an email message is sent to the controller); the form data are not stored in external databases;
  • providing online mentoring services and performing the contract, including the shipping of 3D prints — we process the data provided at the conclusion of the contract, such as the parent’s or guardian’s full name, email address, phone number, shipping address, and the child’s data necessary to conduct the lessons (first name, age, interests);
  • sending the newsletter — we process the email address provided when signing up for the newsletter, on the basis of your consent. The newsletter is sent via an external service provider — MailerLite; the processing of subscribers’ data (email addresses) has been entrusted to this provider under a data processing agreement;
  • establishing, pursuing and enforcing claims and defending against claims in court proceedings and before other enforcement authorities — we may process your personal data provided when using the services, as well as other data necessary to prove the existence of a claim or resulting from a legal requirement, a court order or another legal procedure;
  • handling complaints, grievances and requests and answering users’ questions — we process the personal data you provide in the contact form, complaints, grievances and requests, as well as data concerning the ordered services giving rise to the complaint, grievance or request, and data contained in documents attached thereto;
  • ensuring the IT security of the Website — the server hosting the Website records standard access logs (including IP address, browser and operating system data, time of the request); these logs are processed exclusively for security and technical diagnostic purposes. The Website does not use external analytics or marketing tools.

The Website contains a link to a community run on the external Discord service. Joining the “Cybroskillers” server entails the processing of data by Discord Inc. in accordance with that provider’s privacy policy — the controller is not responsible for data processing on Discord beyond the scope of server moderation.

The sale of products (3D prints, digital courses) will be conducted in an online shop on a separate subdomain. The rules for processing data in connection with purchases (customer account, orders, payments, delivery) will be set out in the shop’s privacy policy upon its launch.

Categories of personal data concerned

The data controller processes the following categories of personal data:

  • contact data;
  • data concerning enquiries and correspondence (contact form, starter lesson);
  • data concerning the performance of services, including the shipping of 3D prints;
  • data concerning complaints, grievances and requests;
  • newsletter subscribers’ data.

Voluntary provision of personal data

Providing the required personal data is voluntary and is a condition for the provision of services by the data controller through the Website.

Data retention period

Personal data will be processed for the period necessary to perform the services, marketing activities and other services provided to the user. Personal data will be erased in the following cases:

  • when the data subject requests their erasure or withdraws the consent given;
  • when the data subject takes no action for more than 10 years (inactive contact);
  • upon obtaining information that the stored data are outdated or inaccurate.

Some data, namely the email address and full name, may be stored for a further period of 3 years for evidentiary purposes and for handling complaints, grievances and claims related to the services provided through the Website — these data will not be used for marketing purposes.

Data concerning orders for paid services will be stored for a period of 5 years from the date the service was performed.

Recipients of personal data

We transfer your personal data to the following categories of recipients:

  • state authorities, e.g. the public prosecutor’s office, the Police, the President of the Personal Data Protection Office (PUODO), the President of the Office of Competition and Consumer Protection (UOKiK), if they request it from us;
  • service providers we use to operate the Website, in particular: hosting providers, the newsletter delivery provider (MailerLite), postal operators and courier companies (when shipping 3D prints). Depending on contractual arrangements and circumstances, these entities act on our behalf or independently determine the purposes and means of data processing. [TO BE ADDED: full list of service providers processing data]

Rights of the data subject

Under the GDPR, you have the right to:

  • request access to your personal data;
  • request the rectification of your personal data;
  • request the erasure of your personal data;
  • request the restriction of the processing of your personal data;
  • object to the processing of your personal data;
  • request the portability of your personal data.

The data controller shall, without undue delay — and in any event within one month of receipt of the request — provide you with information on the action taken on your request. Where necessary, the one-month period may be extended by a further two months, taking into account the complexity of the request or the number of requests.

In any event, the data controller will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

To exercise any of the rights described below (Articles 15–18, 20 and 21 of the GDPR) or to withdraw consent, submit your request to: ul. Pułaskiego 50A/63, 33-100 Tarnów, Poland, or info@cybroskill.com. In the case of the newsletter, you may also use the unsubscribe link included in every message.

The rights of access (Art. 15), rectification (Art. 16), erasure — the “right to be forgotten” (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), objection (Art. 21) and the right to withdraw consent apply to the extent and under the conditions set out in the GDPR. Despite a request for the erasure of personal data, the data controller may continue to process your data in order to establish, pursue or defend claims, of which you will be informed.

Complaint to the supervisory authority

If you believe that the processing of your personal data infringes the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.

In Poland, the supervisory authority within the meaning of the GDPR is the President of the Personal Data Protection Office (PUODO).

Cookies and browser storage

Cookies are small text files stored on your end device in connection with the use of websites. Their purpose is the correct operation of websites.

The cybroskill.com website does not embed external social media plugins or advertising pixels and does not run cookie-based marketing. To analyse traffic we use Google Analytics 4 — only after you have given your consent (details in the “Google Analytics 4” section below).

The Website uses the browser’s localStorage mechanism solely to remember, on your device, the currency you have selected for displaying prices (key “cs_currency”). This information is not sent to the server and does not allow you to be identified.

Using your browser settings, you can delete the data stored in localStorage and manage cookies yourself at any time. Detailed information on the options and methods of handling cookies is available in the settings of your software (web browser).

The online shop launched on a separate subdomain may use its own cookies — the rules of their use will be set out in the shop’s privacy policy.

Google Analytics 4 (visit statistics) [subject to lawyer approval]

To analyse how the Website is used and to improve it, we use Google Analytics 4 (GA4), provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). For processing of data outside the European Economic Area, the associated entity is Google LLC, based in the USA.

Legal basis: your freely given consent (Art. 6(1)(a) GDPR), expressed through the cookie consent banner. Until consent is given, GA4 stores no cookies and sends no data — we use the Google Consent Mode v2 mechanism, in which all consents (including analytics) are denied by default, and the analytics tool is only activated after your acceptance.

Purpose and scope: creating anonymous visit statistics (number of users, pages viewed, traffic sources, device and browser type). The IP address is anonymised. We do not link this data to your identity and do not use it for marketing or advertising profiling (we do not use Google Ads).

Transfer outside the EEA: data may be processed by Google on servers in the USA. The basis for the transfer is the Standard Contractual Clauses and Google’s participation in the Data Privacy Framework. [TO BE VERIFIED: current transfer basis and Google’s DPF status]

Retention period: data in GA4 is retained for [TO BE VERIFIED: set in the GA4 panel, e.g. 14 months], after which it is automatically deleted.

Withdrawing consent: you can change or withdraw your consent at any time using the “Cookie settings” link in the Website footer. Withdrawing consent does not affect the lawfulness of processing carried out before its withdrawal. You are also entitled to all the rights described in the “Rights of the data subject” section.

Children: the target audience of the Website’s services are children aged 6–14 (although contracts are concluded by parents or legal guardians). The GA4 configuration for this group — including disabling Google Signals, anonymising the IP address and disabling ad personalisation — requires approval by the Controller’s lawyer. [subject to lawyer approval]

Commercial information (newsletter)

You can subscribe to our newsletter by providing your email address and consenting to the processing of your personal data for the purpose of sending commercial and marketing information. We will inform you (by email) about the latest offers, news and promotions. You can unsubscribe at any time by clicking the dedicated link included in every message sent to you, or by writing to us at: ul. Pułaskiego 50A/63, 33-100 Tarnów, Poland, or info@cybroskill.com.

The newsletter is sent on our behalf by MailerLite — an entity entrusted with the processing of subscribers’ data under a data processing agreement.

Final provisions

This Privacy Policy is effective from [TO BE ADDED: effective date].

It may become necessary to update this Privacy Policy in the future. Its latest version will always be available on our website. We will inform you of any change to the content of the Privacy Policy, e.g. changes concerning the purpose for which we use your personal data or your rights.

This English version of the Privacy Policy is provided for information purposes only. The binding version of this document is the Polish version.