Privacy Policy
SALWIUS & LAZAREVA SP. Z O.O. PRIVACY POLICY & DATA INSULATION PROTOCOL.
1. PREAMBLE & INSTITUTIONAL DEFINITIONS
1.1. The Entity: Salwius & Lazareva Sp. z o.o. (hereinafter "the Firm", "S&L", "Company", "Administrator", "we", "our" or "us"), a limited liability company incorporated under the laws of the Republic of Poland, registered in the National Court Register (KRS) under the jurisdiction of the District Court for the Capital City of Warsaw.
1.2. The User: Any individual, corporate entity, or sovereign representative accessing the S&L digital infrastructure or engaging S&L for strategic coordination.
1.3. Licensed Partners: Independent, state-licensed or state-registered professionals (including but not limited to sworn legal advocates [Adwokaci/Radcowie Prawni], chartered accountants [Biegli Rewidenci], registered architects, and MSWiA-registered professional lobbyists [Zarejestrowani Zawodowi Lobbyści]) vetted by S&L to execute regulated projects.
2. DESIGNATION OF THE DATA CONTROLLER The exclusive Data Controller (Administrator) for all information collected via this or any S&L infrastructure is Salwius & Lazareva Sp. z o.o., The Firm operates under the strict parameters of the EU General Data Protection Regulation (RODO).
3. CATEGORIES, PURPOSES, AND LEGAL BASES OF PROCESSING We process your data with surgical precision, exclusively for the following purpose of:
3.1. Contractual Execution (Art. 6(1)(b) RODO): To negotiate, establish, and execute strategic coordination agreements and manage billing.
3.2. Regulatory Compliance (Art. 6(1)(c) RODO): To fulfill statutory obligations imposed on the Firm by the Polish Ministry of Finance (KAS), including tax archiving and corporate registry maintenance.
3.3. Legitimate Strategic Interests (Art. 6(1)(f) RODO): To protect our digital infrastructure from cyber-intrusions, enforce our Terms of Use, and defend against or pursue legal claims.
4. DATA INSULATION & THIRD-PARTY TRANSFERS
4.1. The Strategic Relay Protocol: The Firm does not sell, broker, or commercially exploit User data. Data is strictly insulated protected by high-level security protocols.
4.2. Licensed Partner Handoff: To achieve your operational objectives, it is structurally necessary to transfer relevant data to our vetted network of Independent Licensed Partners (Attorneys, Auditors, Architects, etc.). By engaging our services, you explicitly acknowledge and consent that your data may be transferred to our network of Independent Licensed Partners (including but not limited to sworn attorneys, chartered accountants, and architects) solely when necessary to execute a specific project work. Crucial Notice: Upon the transfer of data to a Licensed Partner for the execution of a regulated project, that Partner becomes an independent Data Controller regarding that specific action, subject to their own professional secrecy laws (e.g., Legal Professional Privilege, etc.).
4.3. State Authorities: Data will only be disclosed to Polish or international law enforcement or tax authorities upon the presentation of a legally binding, sovereign judicial order.
5. RETENTION VECTORS Data is not held indefinitely; it is managed according to strict temporal protocols:
5.1. Active Engagements: Maintained for the duration of the strategic project.
5.2. Post-Engagement Archiving: Financial, tax, and contractual data is retained for a mandatory period of five (5) years following the end of the calendar year in which the tax obligation arose, in strict accordance with the Polish Accounting Act.
5.3. Claim Defense: Data necessary for the defense against legal claims is held until the expiration of the statutory limitation periods under the Polish Civil Code.
6. SOVEREIGN RIGHTS OF THE DATA SUBJECT Under RODO, the User possesses absolute, unalienable rights regarding their data:
Right of Access (Art. 15): To demand full transparency on what data we hold.
Right of Rectification (Art. 16): To demand immediate correction of inaccurate data.
Right of Erasure ("Right to be Forgotten") (Art. 17): Applicable only where data is no longer necessary for the purposes collected and not superseded by state retention laws.
Right to Restriction (Art. 18) & Portability (Art. 20).
Right to Object (Art. 21): To object to processing based on legitimate interests.
7. ENFORCEMENT & ESCALATION Should the User believe that S&L has deviated from RODO protocols, they possess the right to lodge a formal complaint with the Polish supervisory authority: The President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych - PUODO), located in Warsaw.
8. INTERNATIONAL TRANSFERS (OUTSIDE THE EEA) S&L’s primary server infrastructure is located within the European Economic Area (EEA). Should strategic operations require data transfer to jurisdictions outside the EEA, S&L ensures such transfers are protected by Standard Contractual Clauses (SCCs) approved by the European Commission.
9. AMENDMENTS We may revise this Privacy Policy from time to time. The revised Policy will apply to the use of our website from the date of publication. Please check this page regularly to ensure you are familiar with the current version.