Privacy policy

1. Controller and contact

The data controller is Doradztwo Podatkowe Zbyszko Pora, ul. Promień 11/3, 51-659 Wrocław, Polska, tax number (NIP) 6112712298, REGON 544668930, Centralna Ewidencja i Informacja o Działalności Gospodarczej. Contact for privacy, security and data rights: kontakt@jtwpoland.com. Professional registration: Zbyszko Pora, doradca podatkowy, numer wpisu 14787. This policy covers the public website, downloads, My Library accounts, enquiries and the newsletter.

2. Data, purposes and legal bases

Public reading requires neither an account nor a newsletter subscription. Accounts use an email address, chosen name, password hash, preferences, acceptance records, saved publications, private notes and correspondence. Processing necessary to provide the free account and respond to requested assistance is based on GDPR Article 6(1)(b). Reading history is off by default and provided only when requested as an account feature. Switching it off stops new entries; a separate action deletes past history.

Security, short-lived abuse counters, audit records and proportionate evidence of cases and the first consultation rely on legitimate interests under Article 6(1)(f): protecting accounts, administering a one-time entitlement and establishing, exercising or defending claims. Specific statutory duties may require Article 6(1)(c); this does not authorise indefinite storage of all correspondence. Data comes from you and, for earlier consultations, our actual correspondence or contemporaneous records.

3. Private notes and first consultation

Notes are not automatically shown to experts or used for advertising. You may deliberately attach a copy to an enquiry; that copy becomes part of the case and is not changed by later edits to the private note. Administrators can access cases; experts can access assigned cases. There is no staff interface for browsing everyone’s private notes. Authorised technical personnel may have the access necessary to maintain the service. Server encryption is not end-to-end encryption.

The first-consultation record shows availability, reservation or completion, the case, date, channel and staff member. A reservation or organisational reply is not completion. Substantive completion or an earlier external consultation requires an explicit, evidenced entry. A pseudonymous email hash may preserve the used entitlement after account deletion; it remains personal data, not anonymous data. Registering again with that address does not renew a retained entitlement. The team verifies the entitlement against this register and its own records of earlier contacts. You can query an incorrect status.

4. Email documents and optional marketing

Documents may be submitted through an available form in an authorised case or advisor panel when uploads are enabled. Otherwise, agree a secure channel with the advisor. Submit only necessary information; never send passwords, MFA codes, signing keys or card details. An emailed document is not automatically added to the library.

Newsletter consent is separate and voluntary, with email confirmation (double opt-in). GDPR Article 6(1)(a) and Article 398 of the Polish Electronic Communications Law are the bases for email marketing. A subscription may trigger an educational sequence ending in an offer for a paid publication. We do not target advertising from private notes or reading history. Every marketing email provides an unsubscribe option without login; account settings offer it too. Withdrawal does not affect earlier lawful processing or library access. We do not buy address lists.

5. Optional analytics and browser storage

Public-page statistics begin only after optional consent. They aggregate page openings and visits where the page was actively visible for at least 15 seconds, by page and day. They are not unique-person counts or proof of reading. Aggregate rows contain no visitor identifier. There are no newsletter open-tracking pixels or marketing click-tracking redirects. A network request necessarily reaches the server with an IP address; separate hosting logs are described below. Optional processing relies on consent under Article 6(1)(a), with Article 399 of the Polish Electronic Communications Law applying to device access where relevant.

The necessary __Host-JTW session cookie supports login and form security. Reader sessions expire after 30 minutes of inactivity and no later than 12 hours; staff sessions after 15 minutes and no later than 8 hours. The cookie contains no notes or password. Existing download forms may use necessary security tokens for the requested function. Browser storage (localStorage) holds only settings that you choose yourself, without identifiers and without transmitting them to the website: the optional analytics choice (jtw_privacy_v1), for 180 days; the selected page theme (jtw_theme_v1); the dismissal of the information notice (jtw-cookie-note); the language and mode of the calculators and any parameters you change in the professional calculator (jtw_kalk_…, jtw_kalkpro_…); and the JTWPOLAND Plush settings — its position, whether it is hidden, the screen reader mode and other accessibility settings, the time of the last greeting and the state of the joke list, so that jokes are not repeated (jtw_pomocnik_v1, jtw_pomocnik_zarty_v2). For a logged-in reader, the JTWPOLAND Plush keeps in the browser tab’s storage (sessionStorage, which is deleted when the tab is closed) the name given in the profile, the number of matters in which the team has replied and a short to-do list (jtw_pomocnik_sesja_v1); it refreshes this information no more than once every 5 minutes, so as not to query the server on every page. These entries are not used for tracking or marketing; you can delete them by clearing the site data in your browser. Refusal of analytics is as easy as acceptance. The “Privacy settings” footer control allows changing or withdrawing the choice. Withdrawal stops new measurements; previously aggregated, non-identifiable counts cannot be removed for an identifiable person. Library history settings are kept in the account, not in an advertising cookie. Public files may use ordinary browser cache; private account responses prohibit caching.

At your request, the JTWPOLAND Plush can read page content aloud using the browser’s speech synthesis. The website does not use the microphone, does not record audio and does not itself send text to any speech service. We select voices installed on the device; if the browser offers only its vendor’s online voices, their operation is governed by that vendor’s own terms. In the My Library account area, reading aloud works only with voices installed on the device, so account content does not leave your device. You switch on the screen reader mode yourself — the website does not detect screen readers or other assistive technologies. Description of browser storage and of the JTWPOLAND Plush features as at 24 September 2026.

6. Recipients and international transfers

Hosting, mail, database and content delivery: IONOS Cloud Ltd. (United Kingdom) — website hosting, database and e-mail; a processor acting under the data processing agreement that forms part of its terms of service; sub-processors as listed by IONOS. Other actual providers and mail forwarding: apart from the hosting provider, the data are not disclosed to other recipients; access to the hosting panel and to the data is held solely by the controller. Authorised staff, properly engaged service providers and authorities where legally required may also receive necessary data. We do not sell personal data.

Transfers outside the EEA and applicable safeguards: Data are processed in the United Kingdom or in a country of the European Economic Area. Transfers to the United Kingdom are based on the European Commission’s adequacy decision (Article 45 GDPR), valid until 27 December 2031. Contact us for information or a copy of relevant safeguards. External sites linked from the service, including external shops, have their own terms; a link alone does not transfer your account data.

7. Retention

Account data, saved publications and private notes remain until account deletion. Unactivated registrations: 7 days; activation links: 24 hours; password-reset links: 1 hour. Reading history: until deletion and at most 180 days per entry. Evidence of the first consultation remains during the active account and normally for 3 years after deletion; an external consultation without an account normally for 3 years after recording. Closed case content normally remains for 3 years after closure. A documented specific obligation or dispute can justify a reviewed extension.

An active newsletter subscription lasts until withdrawal. Pending subscriptions: 7 days; minimum consent and withdrawal evidence: up to 3 years, without continued marketing. An email used only for a free download is retained for up to 72 hours; download links normally last 48 hours. Processed queue payloads are removed after 7 days from creation; unresolved queue items last at most 30 days; operational metadata normally 90 days. Audit records: 3 years. Abuse counters: the applicable period, no more than 24 hours. Aggregated page statistics: 396 days.

Hosting logs: The hosting provider keeps server log files (access and error logs) for a maximum of 8 weeks, after which they are deleted. Backups: the hosting provider creates daily backups of the website files from the last 14 days and backups of the database from the last 7 days. Restoration must apply the newer deletion and opt-out ledger; without reliable evidence, marketing is paused until consent has been established again. Backups must not reactivate deleted accounts or withdrawn consent. Staff must also apply retention to mailboxes and exports outside the portal.

Technical blocks following a complaint or permanent delivery failure retain only a pseudonymous address hash and reason until removal after a necessity review. We review continued retention at least annually. This is not marketing consent; removing the block does not reinstate a subscription. You may request an explanation or object.

8. Your rights

Subject to the GDPR, you may request access, correction, erasure, restriction, portability of automated data processed under consent or contract, withdrawal of consent and objection to processing based on legitimate interests. Objection to direct marketing does not require special personal circumstances. You may complain to the Polish supervisory authority, the President of UODO (uodo.gov.pl), or another competent supervisory authority.

Account settings provide an export and account deletion. This does not limit a wider rights request to kontakt@jtwpoland.com. We normally respond within one month; where a lawful extension is needed we explain it within that month. Identity verification is proportionate and does not routinely require an identity-document scan. Account details are voluntary but necessary for the account. Marketing and analytics are optional. We do not make solely automated decisions producing the effects described in GDPR Article 22.

9. Advisor professional records and external settlements

The advisor panel holds professional indemnity policies, professional registration evidence, cooperation and authority documents, and data-protection arrangements. Advisors may link client authorisations, external invoices or payment evidence to a case, including amount, currency, date, reference and counterparty. The system records authors, dates, versions and reviews. Access is limited to the advisor with an active role and MFA and the portal owner; other advisors and administrators do not gain access solely through their role. Authorised infrastructure support may have technical access. This is not end-to-end encryption.

Purposes are organising cooperation, checking eligibility for new services, and documenting settlements and responsibility. Necessary data of an individual contracting party relies on GDPR Article6(1)(b); cooperation checks, security and evidence for claims rely on Article6(1)(f). A statutory duty applies only to information actually covered by it. Data comes from the advisor, operator and identified registers. Missing required records may suspend new services, but does not authorise deletion of an existing account or contracts.

Records evidence the cooperation terms and activities for their relevant period. Expiry of insurance or authority does not automatically erase historical evidence. After cooperation ends, continued retention is assessed for the specific purpose, claim and applicable duty. The operator should provide the advisor with the agreed retention schedule before collecting these records. Withdrawing a file from use preserves the original; erasure or restriction requests require separate consideration.