Privacy Policy

Last updated: 21 October 2026

1. Data Controller

The controller of personal data collected through https://shenton.app is:

• Legal name: Independent contractor
• Email: [email protected]

In this Privacy Policy, "we", "us", and "our" refer to the data controller identified above.

This Privacy Policy explains how we process personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, or GDPR) and applicable Polish data protection and electronic communications laws.

2. Personal Data We Collect

2.1. App Launch Notification Form

If you register your interest in our upcoming mobile application (the "App"), we collect the information you provide in the sign-up form:

• Name, if requested in the form.
• Email address.

We use these details only to manage your request and send you up to two email notifications concerning the App's launch and availability.

We do not use these contact details for unrelated marketing, newsletters, or ongoing promotional communications.

Providing your details is voluntary. However, if you do not provide a valid email address, we cannot send you the requested notifications.

2.2. Website Analytics

We use Google Analytics to understand how visitors use our Website and to improve its performance.

Analytics may involve the collection of:

• Pages viewed and interactions with Website content.
• Traffic sources and referring websites.
• Browser, operating system, and device information.
• Approximate location derived from technical information.
• Online identifiers, cookie identifiers, and usage information.

We do not intentionally send names or email addresses submitted through the notification form to Google Analytics. The analytics implementation must be configured to prevent such data from being transmitted, including through URLs, event parameters, or other analytics fields.

Google Analytics loads automatically on the public Website and is disabled on localhost and loopback development hosts. We configure Google Analytics with Google signals and ad personalization disabled. We do not intentionally send names or email addresses submitted through the notification form to Google Analytics.

2.3. Technical and Security Information

Our hosting provider and Website infrastructure may process technical information such as IP addresses, server logs, timestamps, and security-related events where necessary to operate, protect, and troubleshoot the Website.

3. Purposes and Legal Bases of Processing

Where the GDPR applies, we process personal data for the following purposes:

A. Sending App launch notifications

• Data: Name and email address.
• Purpose: To send up to two emails concerning the App's launch and availability.
• Legal basis: Your consent under Article 6(1)(a) GDPR, and any separate consent required under applicable Polish rules governing electronic marketing communications.
• Retention: Until the two notifications have been sent, your consent is withdrawn, or the notification service is discontinued, subject to any applicable legal obligations.

B. Website analytics

• Data: Website usage information, technical information, and online identifiers, as configured.
• Purpose: To measure Website traffic and understand visitor interactions.
• Legal basis: Our legitimate interests in measuring and improving the Website under Article 6(1)(f) GDPR, where this basis is available and following the applicable balancing assessment.
• Retention: According to our actual analytics configuration and the retention settings of the relevant service.

C. Website security and technical operation

• Data: Necessary technical logs and security information.
• Purpose: To maintain Website security, prevent abuse, diagnose technical issues, and establish or defend legal claims where necessary.
• Legal basis: Article 6(1)(f) GDPR, where our legitimate interests are applicable and do not override your rights and freedoms, or another lawful basis where required.
• Retention: For the period necessary for the relevant security, operational, or legal purpose.

We will not rely on consent where another legal basis is appropriate, nor will we use personal data for purposes incompatible with those described above without a valid legal basis.

4. Email Notifications and Withdrawal of Consent

By submitting the notification form and affirmatively consenting to receive launch notifications, you request up to two emails about the App's release.

These emails may announce the release and provide information necessary to access or download the App.

We will not send unrelated promotional campaigns or ongoing newsletters using the details submitted through this form.

You may withdraw your consent at any time by contacting [email protected]. Withdrawal will not affect the lawfulness of processing carried out before withdrawal.

If you withdraw consent before all notifications have been sent, we will stop sending further notifications and delete or otherwise appropriately dispose of your contact details, subject to any legal retention obligations.

We may retain limited evidence of consent or withdrawal where necessary to demonstrate compliance with applicable law.

5. Recipients and Service Providers

We may disclose personal data to service providers where necessary for the purposes described in this Privacy Policy.

Depending on the services actually used, these providers may include:

• Website hosting and infrastructure providers.
• Form-processing or database providers.
• Email delivery providers used to send launch notifications.
• Google Analytics, for Website analytics data configured not to include your name or email address.
• Professional advisers or public authorities where disclosure is required by law.

Where a provider processes personal data on our behalf, we will implement the contractual and other safeguards required by applicable law.

We do not sell personal data.

6. International Data Transfers

Some service providers may process personal data outside the European Economic Area (EEA).

Where personal data is transferred outside the EEA, we will use an appropriate transfer mechanism where required by the GDPR, such as an applicable adequacy decision or Standard Contractual Clauses, and implement any additional safeguards required in the circumstances.

Information about the applicable transfer safeguards can be requested from [email protected].

7. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected.

• Launch notification details: We intend to delete the name and email address after the two planned notifications have been sent, or earlier if you withdraw consent. We may retain limited evidence of consent or withdrawal where necessary for compliance.
• Analytics data: Retained in accordance with the actual Google Analytics retention settings and any applicable legal requirements.
• Technical and security logs: Retained for a period appropriate to the relevant operational or security purpose.

Where the Website uses backups or third-party systems, deletion may take additional time in accordance with documented backup cycles and applicable legal requirements.

8. Cookies and Similar Technologies

The Website may use cookies and similar technologies for essential technical functionality and analytics.

Google Analytics is configured as described in this Privacy Policy and loads automatically on the public Website. Analytics does not load on localhost or loopback development hosts. You can control cookies through your browser settings; blocking cookies may affect analytics measurement.

9. Your Rights Under the GDPR

Where the GDPR applies, you may have the right to:

• Obtain confirmation of whether we process your personal data and request access to it.
• Request correction of inaccurate or incomplete personal data.
• Request erasure of personal data where the legal conditions are met.
• Request restriction of processing.
• Receive certain personal data in a structured, commonly used, machine-readable format and transmit it to another controller where the right to data portability applies.
• Object to processing based on legitimate interests, on grounds relating to your particular situation.
• Withdraw consent at any time where processing is based on consent.
• Lodge a complaint with a competent supervisory authority.

To exercise your rights, contact [email protected]. We may need to verify your identity where reasonably necessary to protect your data.

In Poland, you may lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO). Official information is available at https://uodo.gov.pl/.

10. Whether You Must Provide Your Data

You are not legally required by us to register for App launch notifications. Providing your name and email address is voluntary.

If you choose to register, your email address is necessary for us to send the requested notifications. Your name is optional unless the form clearly indicates otherwise and there is a justified need to request it.

You may browse the informational Website without subscribing to launch notifications.

11. Security

We implement appropriate technical and organizational measures designed to protect personal data against accidental loss, unauthorized access, disclosure, alteration, or destruction.

Access to personal data is restricted to persons and service providers who need it for the relevant purposes.

No method of transmission or storage can guarantee absolute security.

12. Children's Privacy

The Website is not specifically directed at children. We do not knowingly collect children's personal data in violation of applicable law.

If you believe that a child has provided personal data in circumstances that violate applicable law, please contact us at [email protected].

13. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our processing activities, services, or legal requirements.

The current version and its effective date will be published on this page. Where required by law, we will provide additional information or seek consent for materially changed processing.

14. Contact

For questions or requests concerning this Privacy Policy or the processing of your personal data, contact:

Independent contractor
Email: [email protected]