Privacy Policy
coldtoclose.ai — Last updated: 24 March 2026
This Privacy Policy sets out the rules for the processing of personal data collected through the website coldtoclose.ai (hereinafter: the Website). The Policy complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter: GDPR), the Polish Personal Data Protection Act of 10 May 2018, and the Telecommunications Act of 16 July 2004.
1. Data Controller
The controller of personal data processed through the Website is: Sławomir Kwaśny, operating as a sole proprietorship under the trade name Sky Profit, Tax ID (NIP): 9372752190 (hereinafter: the Controller).
For all matters relating to the protection of personal data, including the withdrawal of consent, please contact:
Email: kontakt@coldtoclose.ai
2. Purposes and Legal Bases for Data Processing
The Controller processes users' personal data for the following purposes and on the following legal bases:
2.1. Contact Form and Consultation Booking
The Website allows users to submit enquiries via a contact form (/pl/contact, /en/contact) and to book a free consultation through Cal.com. Data processed for this purpose includes: name, email address, optionally phone number, and message content.
Legal basis: Art. 6(1)(b) GDPR (steps taken at the data subject's request prior to entering into a contract) and Art. 6(1)(f) GDPR (the Controller's legitimate interest in handling enquiries).
Retention period: until the enquiry has been fully resolved, then for the limitation period for potential claims (3 years).
2.2. ROI Calculator
The Website provides an interactive return-on-investment calculator (/pl/kalkulator). Data entered into the calculator (number of enquiries, average visit value) is processed locally in the user's browser and is not stored on the Controller's servers, unless the user voluntarily provides an email address to receive the results.
If the user provides an email address: legal basis is Art. 6(1)(a) GDPR (consent). Data retained until consent is withdrawn.
2.3. Newsletter
The Controller operates a newsletter through Kit (formerly ConvertKit). Subscribing to the newsletter requires an email address and is voluntary.
Legal basis: Art. 6(1)(a) GDPR (consent) in conjunction with Art. 10(2) of the Polish Act on the Provision of Electronic Services.
The user may withdraw consent at any time by clicking the unsubscribe link in any newsletter message or by writing to kontakt@coldtoclose.ai.
Retention period: until consent is withdrawn or the user unsubscribes.
2.4. Contract Performance
When a contract for AI automation services is concluded, the Controller processes data necessary for its performance: full name, company name, Tax ID (NIP), address, email address, and phone number.
Legal basis: Art. 6(1)(b) GDPR (performance of a contract). Data retained for the duration of the contract and 5 years thereafter (tax and accounting obligations).
2.5. Analytics, Tag Management, and Marketing
The Website uses the following analytics, tag management, and marketing tools:
| Tool | Provider | Data Scope | Legal Basis | Retention |
|---|---|---|---|---|
| Google Tag Manager (GTM) | Google Ireland Ltd. | Tag and script management. Processes: IP address, browser technical data. | Art. 6(1)(f) GDPR | Session duration |
| Google Analytics 4 (GA4) | Google Ireland Ltd. | Traffic analysis. Collects: _ga cookie identifier, IP address (anonymised), device type, traffic source, pages visited. | Art. 6(1)(a) GDPR (consent) | 26 months |
| Meta Pixel (Facebook) | Meta Platforms Ireland Ltd. | Remarketing. Collects: browser identifier, IP address, on-site events. | Art. 6(1)(a) GDPR (consent) | 180 days |
| Cal.com | Cal.com Inc. | Consultation booking. Collects: name, email, phone number, appointment time. | Art. 6(1)(b) GDPR | Until enquiry resolved |
| Kit (ConvertKit) | Kit, Inc. (USA) | Newsletter. Collects: email, open-rate statistics. | Art. 6(1)(a) GDPR (consent) | Until unsubscribed |
| Vercel | Vercel Inc. (USA) | Hosting. Processes: IP address, server logs. | Art. 6(1)(f) GDPR | 30 days |
| Cloudflare | Cloudflare Inc. (USA) | DNS and DDoS protection. Processes: IP address, HTTP headers. | Art. 6(1)(f) GDPR | 4 hours |
For tools provided by US-based entities (Vercel, Cloudflare, Kit), data transfers are carried out on the basis of Standard Contractual Clauses (SCCs) or the EU-US Data Privacy Framework.
3. Cookies
3.1. Types of Cookies
- Necessary – required for the Website to function properly (always active).
- Analytical (GA4) – help the Controller understand how users interact with the Website.
- Marketing (Meta Pixel) – enable the display of more relevant advertisements.
3.2. Cookie Management
On first visit, a cookie consent banner is displayed, allowing the user to accept or reject each category of cookies. Consent may be changed or withdrawn at any time through the browser settings.
4. Rights of Data Subjects
Under the GDPR, you have the following rights:
- Right of access to your data (Art. 15 GDPR).
- Right to rectification (Art. 16 GDPR).
- Right to erasure – “right to be forgotten” (Art. 17 GDPR).
- Right to restriction of processing (Art. 18 GDPR).
- Right to data portability (Art. 20 GDPR).
- Right to object to processing (Art. 21 GDPR).
- Right to withdraw consent at any time (without affecting the lawfulness of processing carried out before withdrawal).
To exercise any of these rights, please write to kontakt@coldtoclose.ai. We will respond within 30 days.
You also have the right to lodge a complaint with the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, Poland.
5. Data Security
The Controller implements appropriate technical and organisational measures to protect personal data, including:
- Encrypted connections via SSL/TLS.
- Infrastructure protection through Cloudflare (DNS, DDoS mitigation).
- Encryption of data at rest on Vercel servers.
- Access to personal data restricted to authorised personnel only.
6. Data Recipients
Personal data may be disclosed to the following categories of recipients:
- IT service providers (hosting, analytics, tag management) – as listed in Section 2.5 above.
- Accounting and legal service providers – to the extent necessary to fulfil tax and legal obligations.
- Public authorities – in cases provided for by applicable law.
7. Changes to This Privacy Policy
The Controller reserves the right to update this Privacy Policy. Significant changes will be communicated on the Website. The current version is always available at coldtoclose.ai/en/privacy-policy.
Last updated: 24 March 2026.
Questions regarding this Privacy Policy should be directed to: kontakt@coldtoclose.ai.