Privacy Policy for the TRIVO.LIFE Website
1. Scope
- This Privacy Policy applies only to the informational website available at www.trivo.life, together with the waitlist sign-up form.
- This Policy does not apply to the TRIVO mobile or web application (the coaching platform), which is governed by separate Terms of Use and Privacy Policy, published separately once the application becomes available.
2. Data Controller
- The controller of your personal data is TRIVO.LIFE Prosta Spółka Akcyjna, with its registered office in Lublin, ul. Gospodarcza 26, 20-213 Lublin, entered in the Register of Entrepreneurs of the National Court Register (KRS) under number KRS 0001255469, NIP: 9462770429, REGON: 545290154.
- For matters concerning personal data, you may contact the Controller at kontakt@trivo.life or at the correspondence address indicated above.
- The Controller has not appointed a Data Protection Officer.
3. Processing Purposes, Legal Bases, and Retention Periods
| Purpose | Data categories | Legal basis | Retention period |
|---|
| Waitlist sign-up and notification of service launch | email address | Art. 6(1)(a) GDPR — consent | until consent is withdrawn, no longer than 12 months from sign-up, or until you are granted access to the Application, whichever comes first |
| Establishing, pursuing, and defending legal claims | email address, sign-up date, IP address | Art. 6(1)(f) GDPR — legitimate interest: pursuing and defending against claims | until claims become time-barred (generally 6 years) |
| Website security and fraud prevention | IP address, event logs | Art. 6(1)(f) GDPR — legitimate interest: detecting unauthorized access and abuse | 12 months from the event being recorded |
4. Voluntariness of Providing Data
- Providing your email address is voluntary but necessary to sign up for the waitlist. Without it, we cannot send you a notification when the service launches.
5. Data Recipients
| Recipient | Type of service | Role |
|---|
| Notion Labs, Inc. | database used to store submissions from the waitlist sign-up form | data processor |
| Vercel Inc. | website hosting and content delivery (CDN) | data processor |
6. Transfer of Data Outside the European Economic Area
- Notion Labs, Inc. and Vercel Inc. are headquartered in the United States. To the extent that data is actually transferred to the United States, we base such transfers on: (a) a European Commission adequacy decision (Art. 45 GDPR), including with respect to entities participating in the EU-US Data Privacy Framework (Implementing Decision (EU) 2023/1795), or (b) standard contractual clauses adopted by Commission Implementing Decision (EU) 2021/914 (Art. 46(2)(c) GDPR), depending on the certification status of the given provider.
7. Cookies
- The website uses only cookies that are strictly necessary for its proper functioning (e.g., maintaining the form session). These cookies do not require your consent under Art. 399 of the Act of 12 July 2024 — Prawo komunikacji elektronicznej (Electronic Communications Law).
- The website does not currently use cookies or similar technologies for analytics, statistics, or marketing purposes. Should such tools be introduced in the future, this Policy will be updated accordingly, and we will display a banner allowing you to give or refuse consent before they are applied.
8. Your Rights
| Right | Basis | What it means |
|---|
| Access to data and a copy | Art. 15 GDPR | you can find out whether and what data we process, and receive a copy of it |
| Rectification | Art. 16 GDPR | you can request correction of inaccurate data or completion of incomplete data |
| Erasure | Art. 17 GDPR | you can request deletion of your data where one of the grounds under this provision applies |
| Restriction of processing | Art. 18 GDPR | you can request that we temporarily suspend operations on your data |
| Data portability | Art. 20 GDPR | applies to data processed on the basis of consent, by automated means — you will receive it in a machine-readable format |
| Objection | Art. 21 GDPR | applies to data processed on the basis of legitimate interest |
| Withdrawal of consent | Art. 7(3) GDPR | at any time, without affecting the lawfulness of processing carried out before withdrawal |
To exercise your rights, you may submit a request by email to kontakt@trivo.life or in writing to the correspondence address indicated in section 2 of this Policy. We respond without undue delay, and no later than one month from receiving the request.
9. Complaint to the Supervisory Authority
If you believe that we are processing your data unlawfully, you may lodge a complaint with the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warszawa.
10. Changes to the Policy
- We may amend this Policy, in particular in the event of changes to the law, to the scope of the website, or to the tools and providers we use.
- We will notify you of material changes at least 14 days before they take effect, via a notice on the website.