Draft notice: this page is a structural draft, not yet reviewed by a lawyer. Do not treat it as final.
1. General
1.1. This Policy describes how personal data is processed on effingtop.com (the "Service").
1.2. This document follows Regulation (EU) 2016/679 (GDPR), which applies to the Operator as an EU-established data controller regardless of where a given user is located.
2. Data controller
2.1. The data controller is:
ul. Grottgera 13A/9, 64-920 Piła, Poland
VAT ID: PL7642697963
email: [email protected]
2.2. For anything data-related, contact [email protected].
3. What we process
No account is required. We process:
3.1. Email address — if you provide it when paying, to send a confirmation and, where relevant, a receipt.
3.2. Payment and transaction data — transaction id, amount, status, date, and the URL/profile submitted. We do not collect or store card details or banking credentials — Dodo Payments, our payment processor and Merchant of Record, handles those and your billing details directly.
3.3. Technical and usage data — IP address, browser/device type, visit date and time, analytics events (for statistics and security).
4. Purposes and legal bases
| Purpose | Legal basis (GDPR) |
|---|---|
| Providing the service (creating/raising an Entry, payment handling) | Art. 6(1)(b) |
| Handling complaints and contact | Art. 6(1)(b) and (f) |
| Statistics and improving the Service (analytics) | Art. 6(1)(a) or (f) |
| Security and abuse prevention | Art. 6(1)(f) |
| Legal obligations (e.g. accounting) | Art. 6(1)(c) |
5. Recipients and processors
- Dodo Payments — payment processing and Merchant of Record.
- Cloudflare, Inc. — hosting, CDN, and database (Cloudflare Pages / D1).
- Google (Google Analytics 4) — traffic analytics.
- Mixpanel, Inc. — event analytics (EU instance).
6. Transfers outside the EEA
Some providers (e.g. Google, Cloudflare) may process data outside the EEA. Transfers rely on Standard Contractual Clauses approved by the European Commission or other GDPR-recognized safeguards.
7. Retention
7.1. Transaction data — for as long as required by law (e.g. tax rules) and to establish or defend legal claims.
7.2. Analytics data — per the retention settings of the analytics tools used.
7.3. An email address given for confirmation — for as long as needed to provide the service and handle any complaint.
8. Your rights
You have the right to access, correct, delete, or restrict processing of your data, to data portability, to object, and — where processing relies on consent — to withdraw it at any time (without affecting the lawfulness of processing before that withdrawal).
You can also lodge a complaint with a data protection authority — in Poland, the President of the Personal Data Protection Office (UODO) (ul. Stawki 2, 00-193 Warsaw), or your own EU/EEA member state's authority under GDPR Art. 77. Contact: [email protected].
9. Cookies and analytics
9.1. The Service uses cookies required for it to function, and — with consent — for analytics (Google Analytics 4, Mixpanel).
9.2. You can change cookie settings in your browser; restricting them may affect some features.
10. Security
The controller uses technical and organizational measures appropriate to the risk, including an encrypted connection (HTTPS).
11. Changes to this Policy
The controller may update this Policy. The current version, with its date, is published on the Service.
12. Contact
For anything privacy-related: [email protected].