Trust record / working draft
Privacy must describe the system that actually runs.
This is an implementation-ready structure, not legal advice or a lawyer-approved notice. Missing facts are kept visible instead of being invented.
EAIS / system view
Signal → system
Human control / on
Release gate / legal review required
The registered firm, address, sole-proprietor form, owner identity, NIP and REGON are verified. Do not treat this route as the final privacy notice until controller status, hosting, retention, processor and rights information is supplied and legally reviewed.
Data map
Working privacy record
Controller and contact
Website operator: AMA Łukasz Kretowicz, Polish sole proprietorship (jednoosobowa działalność gospodarcza), Emilewo 37/A, 62-640 Barłogi, NIP 6661935788, REGON 311552687. Firm, owner, identifiers, active status and the registered/delivery address were checked in the official CEIDG entry and certificate on 2026-07-16; VAT status: Czynny. Formal data-controller role and a dedicated privacy contact remain pending legal verification.
Corporate Audit Console
The brief may contain process descriptions plus contact name, company, work email and an optional phone number. The current local-safe configuration has no delivery transport: an attempted submission returns delivery_not_configured and the server does not persist the brief. Production purpose, legal basis, destination and retention require owner and legal approval before activation.
Analytics and consent
The current corporate app contains Google Analytics 4 measurement that loads only after an affirmative choice. Page and interaction events must not contain brief text, secrets or personal field values. The exact controller configuration, retention, Google settings and international-transfer disclosure require legal verification.
Technical logs and hosting
A public web server may process IP address, request time, requested path, user agent and security events in technical logs. PENDING OWNER DATA: hosting provider, log fields, access roles and retention. These facts must be taken from the deployed environment, not inferred from source code.
Course platform boundary
Course catalog, checkout, payment, account, entitlement and transactional email use a separate operational flow with their own pre-contract documents. This corporate working notice must not silently replace the course privacy notice or change payment records.
Processors and recipients
PENDING OWNER AND LEGAL REVIEW: hosting, analytics, form delivery, email, payment and any CRM or automation providers. A provider is listed only when it is actually configured for the relevant route.
Retention and deletion
No generic period is invented here. Each data class needs a documented purpose, owner, retention trigger and deletion or archival rule. The Audit Console must remain fail-closed until that contract is approved.
Your rights and complaints
PENDING LEGAL REVIEW: access, correction, deletion, restriction, objection, portability where applicable, withdrawal of consent and the competent supervisory authority. Final wording depends on the verified controller and processing bases.