This privacy policy explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") in the context of the provision of our services and within our online offering and the associated websites, functions and content as well as external online presences, such as our social media profile (hereinafter collectively referred to as "online offering"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Contact data protection officer:
Jon Kwiatkowski OÜ
Jonathan Bluemel
Harju maakond, Lasnamäe linnaosa, Sepapaja tn 6
Tallinn, 1551, Estonia
Contact: info@jon-kwiatkowski.com
The use of contact data published within the framework of the imprint obligation by third parties for the purpose of sending unsolicited advertising and information materials is hereby expressly prohibited. The operators of these pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.
Declaration of No Third-Party Analytics or Tracking Usage
We do not employ third-party analytics services such as Google Analytics, Matomo, or Google Tag Manager on our website. As such, we do not collect or process visitor data via these platforms.
Cookies and Tracking Technologies
Despite not using Google Analytics, Matomo, or Google Tag Manager, we may use cookies to ensure the basic functionality of our website. Our website uses only essential cookies required for the technical operation of the site, such as session cookies for login or maintaining state between pages. We do not use cookies or other tracking technologies for marketing or analytics purposes. You can manage or disable cookies through your browser settings. Please note that disabling essential cookies may affect the usability of our website.
Provision of website and creation of log files
If all you want to do is visit our website and access the information on it, you do not have to give us your personal details.
During your visit to our website, we collect and use only the data that your web browser transmits to us automatically:
- date and time one of our web pages was accessed
- if applicable, name and website of the requested file, at least method and Uniform Resource Identifier (URI) for each request – i.e. request type (e.g. GET, POST) – as well as the path without protocol and domain,
- your browser type you used when calling up the website (user agent header)
- your browser settings
- access status (HTTP status code)
- the operating system used when calling up the website, if it is transmitted as part of the user agent
- your IP address
- the website that initiated the request (referrer), meaning the pages you visited
We use this data for technical reasons to enable you to visit our website. In addition, we use this data in an appropriately secured environment for statistical purposes, for the purpose of (further) developing new or existing products and to improve the design and layout of our website. We store the IP address for the purpose of guaranteeing and maintaining IT security (e.g. recognition of, and defence against, DoS attacks) and to ensure the website functions properly. The legal basis for the temporary storage of data is point (f) of Article 6(1) GDPR.
As far as on our sides personal data (such as name, address or e-mail addresses) are collected, this is as far as possible on a voluntary basis. This data will not be passed on to third parties without your express consent.
We point out that data transmission over the Internet (eg communication by e-mail) security gaps. A complete protection of the data against access by third parties is not possible.
Children’s Personal Data
Our website is not directed towards children under the age of 16. We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected such data, please contact us immediately so we can delete it.
User Consent and Legal Basis for Processing
For any personal information you provide voluntarily (e.g., via contact forms), we process your data primarily based on your consent (Art. 6(1)(a) GDPR) or to fulfil our contractual obligations (Art. 6(1)(b) GDPR). You have the right to withdraw your consent at any time without affecting the lawfulness of prior processing.
If you wish to withdraw consent or have any questions regarding the processing of your data, please contact our Data Protection Officer at info@jon-kwiatkowski.com.
Terminology used
Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as "users").
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data.
"Pseudonymisation" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. For users from the area of application of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies if the legal basis is not mentioned in the data protection declaration:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR;
The legal basis for processing for the fulfilment of our services and implementation of contractual measures as well as answering enquiries is Art. 6 para. 1 lit. b GDPR;
The legal basis for processing for the fulfilment of our legal obligations is Art. 6 para. 1 lit. c GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 para. 1 lit. e GDPR.
The legal basis for processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR.The legal basis for processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR.
The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 para. 4 GDPR.
The processing of special categories of data (in accordance with Art. 9 para. 1 GDPR) is governed by the provisions of Art. 9 para. 2 GDPR.
Security measures
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and separation of the data. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted and we respond to data threats. Furthermore, we take the protection of personal data into account as early as the development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings.
Data Breach Notification
In the unlikely event of a personal data breach that risks your rights and freedoms, we will notify the relevant supervisory authority and affected data subjects in accordance with GDPR requirements.
Cooperation with processors, joint controllers and third parties
We share personal data with external parties that we carefully select, appoint, and supervise in accordance with a contractual data processing agreement under Article 28 of the GDPR. These providers follow our instructions and implement appropriate technical and organizational measures, as outlined in Article 32 of the GDPR, to safeguard the rights of individuals.
If we disclose data to other persons and companies (service providers, processors, joint controllers or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary to fulfil a contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we disclose, transfer or otherwise grant access to data to other companies in our group of companies, this is done in particular for administrative purposes as a legitimate interest and, in addition, on a basis corresponding to the legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to other persons or companies, this will only take place if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual authorisations, we only process or leave the data in a third country if the legal requirements are met. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognised special contractual obligations.
Automated Decision-Making and Profiling
We do not use automated decision-making or profiling processes that produce legal effects concerning you or similarly significantly affect you.
Rights of the data subjects
You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
You have the right to request the completion of data concerning you or the correction of incorrect data concerning you in accordance with the legal requirements.
In accordance with the legal requirements, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements. You have the right to request that the data concerning you that you have provided to us be received in accordance with the legal requirements and to request that it be transferred to other data controllers.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with the statutory provisions.
You have the right to withdraw your consent with effect for the future.
Right to object
You can object to the future processing of data concerning you at any time in accordance with the legal requirements. In particular, you may object to processing for direct marketing purposes.
Deletion of data
The data processed by us will be deleted or its processing restricted in accordance with the legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations.
If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
Changes and updates to the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your co-operation (e.g. consent) or other individual notification.
Making contact
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user's details will be used to process the contact enquiry and its handling in accordance with Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f. (other enquiries) GDPR. The user's details may be stored in a customer relationship management system ("CRM system") or comparable enquiry organisation.
We delete the enquiries if they are no longer required. We review the necessity every two years; the statutory archiving obligations also apply.
Hosting and e-mail dispatch
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services that we use for the purpose of operating this online offering.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in the efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of contract). Art. 28 GDPR (conclusion of order processing contract).
Collection of access data and log files
We, or our hosting provider, collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Security Measures
We implement technical and organisational security measures to protect personal data, especially from accidental or intentional manipulation, loss, disruption or from access by unauthorised persons. We constantly improve our security measures in line with technological developments. We would point out that when data is transmitted through the internet, third parties can take cognizance of this data or falsify it, despite any security measures deployed.
Use of Secure Connections
Our website uses secure HTTPS connections to protect your data during transmission. This encryption helps prevent unauthorized access to data
Contact
If you have any questions or suggestions about this data protection statement, please contact us at the address given on at the top of this page.
Updating our data protection guidelines
The ongoing technical further development of IT technology and the internet also means that we need to adapt our existing data protection statement. We therefore reserve the right to make amendments and changes to this data protection statement.
Effective since July 2025. Last update: 24.07.2025