KARMOS.
DRAFT — NOT YET LEGAL COPY

Written to be accurate about what the scorecard actually does, so a lawyer is reviewing facts rather than inventing them. Every highlighted field needs filling, and the whole thing needs a Polish lawyer's sign-off before the first live lead. Delete this box when it has one.

Privacy policy

LAST UPDATED [date]

This policy explains what happens to your personal data when you use the dating scorecard at coachkarmos.com, buy an e-book, or book a call. It is written to meet the EU General Data Protection Regulation (GDPR) and Polish law.

01WHO IS RESPONSIBLE

The controller of your personal data is [registered business name], [street address, postal code, Wrocław, Poland], NIP [NIP], REGON [REGON], trading as Coach Karmos.

For anything in this policy, including any of the rights in section 08, write to [privacy@yourdomain].

Needed: these fields cannot be filled until the JDG is registered. A privacy policy without an identifiable controller and a working contact address is not a valid one, so registration genuinely does have to come first.

02WHAT WE COLLECT

When you take the scorecard

When you book a call or buy something

[To be completed once the booking page and checkout exist — expect a calendar booking with name, email and possibly phone number, and payment handled by a payment provider who receives your card details directly. We do not see or store card numbers.]

Automatically

Our hosting provider records standard server log data, including IP address, browser type and the pages requested, in order to serve the site and protect it from abuse.

Decide: if you add Google Analytics, Meta Pixel, or any other tracking, this section and section 07 both change, and you will need a cookie consent banner. Right now the site has none, which is why it does not have one.

03WHY WE USE IT, AND ON WHAT LEGAL BASIS

What forLegal basis
Calculating and showing your scorecard result, and emailing you a copy Performance of a contract, or steps taken at your request before entering one — GDPR Art. 6(1)(b). You asked for the result; this is how it is delivered.
Sending you marketing emails about coaching, e-books and offers Your consent — GDPR Art. 6(1)(a), and art. 398 of the Polish Prawo komunikacji elektronicznej. Given by ticking an optional box that is unticked by default, separately from your request for your results. You can withdraw it at any time, and every email carries an unsubscribe link.
Sorting leads by score, bottleneck and stated budget so follow-up is relevant Our legitimate interest in running the business efficiently — GDPR Art. 6(1)(f). You can object; see section 08.
Reading your scorecard before a call you have booked, so the call is useful Performance of a contract, or steps at your request — Art. 6(1)(b).
Keeping invoices and accounting records Legal obligation under Polish tax law — Art. 6(1)(c).
Establishing or defending legal claims Legitimate interest — Art. 6(1)(f).

Profiling

Your answers are used to place you in a segment and to decide which offer you are shown and which emails you receive. This is profiling in the sense of GDPR Art. 4(4). It produces no legal or similarly significant effect on you: nothing is refused, no price changes, and a human makes every decision that matters. You can object to it under Art. 21.

04WHO ELSE SEES IT

We use the following processors. Each one only receives what it needs, and each is bound by a data processing agreement.

ProviderWhat it does
NetlifyHosts the website. Sees server log data including your IP address. United States.
Make.comPasses your scorecard submission from the website to our email platform. [Confirm which region your Make organisation is in — EU or US.]
systeme.ioStores your contact record, holds your scorecard result, sends emails, and handles checkout and booking. France.
Google FontsServes the typefaces used on the site. Your browser requests them from Google's servers, which means Google receives your IP address. [Removable — see the note below.]
[payment provider][Processes payments. Receives your payment details directly.]
Fix available: the Google Fonts row exists only because both pages load Montserrat from Google's CDN. German courts have awarded damages over exactly this. Hosting the font file yourself removes the third-country transfer, removes the row, and makes the page load faster. Ask and it is a fifteen-minute change.

We do not sell your data, and we do not share it with anyone for their own marketing.

05TRANSFERS OUTSIDE THE EEA

Some providers above are in the United States. Where that is the case, the transfer relies on the European Commission's Standard Contractual Clauses, on the provider's certification under the EU–US Data Privacy Framework, or both. You can ask us for details of the safeguards that apply to any specific provider.

Verify: check each provider's current DPF certification status before publishing rather than taking this sentence on trust.

06HOW LONG WE KEEP IT

07COOKIES AND BROWSER STORAGE

The site sets no advertising or analytics cookies.

When you start the scorecard from the landing page, your first name and email are held briefly in your browser's session storage so the quiz can carry them to the next page. It is deleted the moment the quiz reads it, and in any case when you close the tab. It never leaves your device except as part of the submission you complete. Storage that is strictly necessary to deliver something you asked for does not require consent.

If we ever add analytics or advertising tools, we will ask for your consent first and update this policy.

08YOUR RIGHTS

Under the GDPR you can ask us to:

You can withdraw consent to marketing emails at any time, either through the unsubscribe link in any email or by writing to us. Withdrawing it does not make anything we did beforehand unlawful.

Write to [privacy@yourdomain] and we will respond within one month.

If you think we have handled your data badly, you can complain to the Polish supervisory authority: Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl.

09IS IT REQUIRED

Giving us your name and email is voluntary, but without them we cannot send you your result. Agreeing to marketing emails is entirely optional, sits behind a separate box that is unticked by default, and you get your result whether you tick it or not.

Matches the build: the scorecard asks for an email in order to deliver the result, and puts marketing behind a separate unticked box. This paragraph and the second row of the section 03 table describe that. If the form changes, change these too.

10AGE

This service is for adults. It is not directed at anyone under 18 and we do not knowingly collect data from anyone under 18.

11CHANGES

If we change this policy we will update the date at the top. Material changes affecting how we use data you have already given us will be emailed to you.