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THE FIRST Monogram
LEGAL // GDPR DATA PROCESSING NOTICE

Privacy Policy

EFFECTIVE: 2026-10-23 · CONTROLLER: ZORDON INTELLIGENCE SP. Z O.O. · KRS 0001190915 · NIP 7252358503 · REGON 542545843 · Łódź

1. Controller

The controller of personal data is Zordon Intelligence sp. z o.o., Łódź, Poland, KRS 0001190915, NIP 7252358503, REGON 542545843. Contact: hi@zordonintelligence.pl.

2. What we process

PayPal transaction data: name, e-mail, country, amount, currency, payment ID, date — passed to us by PayPal as the seller.

Correspondence: your e-mail address and message content when you write about an order, invoice or complaint.

Analytics: anonymous Google Analytics 4 events (page views, buy-button clicks) — only after you accept the cookie banner. Before consent we send no request to Google.

We run no sign-up forms, no profiling, and we never sell data.

3. Legal bases and purposes

Art. 6(1)(b) GDPR — performance of the contract: delivering the file, payment, invoices.

Art. 6(1)(c) GDPR — legal obligations: accounting and tax records.

Art. 6(1)(f) GDPR — legitimate interest: complaints, claims, site security.

Art. 6(1)(a) GDPR — consent: Google Analytics 4. You may withdraw consent at any time with no effect on prior processing.

4. Recipients and transfers outside the EEA

PayPal (PayPal Europe S.à r.l. et Cie S.C.A.) — payments. Vercel Inc. — hosting. Google Ireland Ltd. / Google LLC — analytics after consent. Our accounting office — bookkeeping.

Vercel and Google may process data in the USA under Standard Contractual Clauses and, for Google, the EU–US Data Privacy Framework.

5. Retention

Sales records: 5 years from the end of the tax year.

Correspondence: up to 12 months after the matter closes, longer only where needed against a claim.

Analytics: up to 14 months, per the GA4 retention setting.

6. Cookies

Essential: remembering your consent decision (localStorage), site operation and security. No consent needed.

Analytics: Google Analytics 4 with Consent Mode v2 — loaded only after you click “Accept”. On “Reject” we send nothing to Google.

You can clear cookies and site data in your browser; the consent question will then be asked again.

7. Your rights

Access, rectification, erasure, restriction, portability, and objection to processing based on legitimate interest. Consent can be withdrawn at any time.

Send requests to hi@zordonintelligence.pl. We reply without undue delay, within one month.

You may lodge a complaint with the Polish supervisory authority (UODO, ul. Stawki 2, 00-193 Warsaw, https://uodo.gov.pl) or with your local authority.

8. Security and minimisation

The site is static: no customer database, no user accounts, no card data. Your workbook notes stay in the PDF on your device — we never upload them.

Only the person handling sales has access to correspondence, and data goes only to the processors listed in section 4.

NEWSLETTER // ONE MAIL A WEEK

One exercise a week. No motivational noise.

A short mail: one exercise from the workbook, one observation from real conversations. No offer in every message.

[CHECKOUT] // ART. 38 PKT 13

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