Privacy Policy

Last updated: 20 July 2026

§1 Data Controller

The data controller is Michał Wójtowicz, ClubHQ, ul. Łosiowa 87, 43-300 Bielsko-Biała, Poland, NIP (Tax ID): 6762446401, REGON: 361062286, email: contact@clubhq.cloud (the "Controller").

§2 What data we process and why

1. Waitlist sign-up form: email address, optionally a name — purpose: sending updates about the Service launch, legal basis: Art. 6(1)(a) GDPR (consent).
2. Formation and performance of the contract for the ClubHQ Service (Account data, Club data, billing data) — legal basis: Art. 6(1)(b) GDPR (performance of a contract).
3. Payment processing via Przelewy24 (PayPro SA) — legal basis: Art. 6(1)(b) and (c) GDPR (performance of a contract, tax/accounting obligations).
4. Handling support requests and complaints sent by email — legal basis: Art. 6(1)(b) and (f) GDPR.
5. Establishment, exercise or defence of legal claims and fulfilment of tax/accounting obligations — legal basis: Art. 6(1)(c) and (f) GDPR.

§3 Recipients of data

Personal data may be shared with the following categories of recipients, only to the extent necessary for the purposes listed in §2:

• payment operator Przelewy24 (PayPro SA), ul. Kanclerska 15, 60-327 Poznań, Poland — to process payments;
• sign-up form provider Web3Forms — to handle submissions from the homepage sign-up form;
• website hosting provider GitHub Pages (GitHub, Inc. / Microsoft) — to host and serve the website;
• providers of accounting and legal services to the Controller.

§4 Transfers outside the EEA

Some providers listed in §3 (e.g. Web3Forms, GitHub Pages) may process data on servers located outside the European Economic Area, in particular in the USA. Such transfers rely on appropriate safeguards required by the GDPR, including standard contractual clauses or the provider's participation in the EU-U.S. Data Privacy Framework.

§5 Data retention

1. Data related to performance of the Service contract — for the duration of the contract and until claims become time-barred or tax/accounting obligations expire (generally 5 years from the end of the year in which the tax obligation arose).
2. Data collected via the waitlist sign-up form — until consent is withdrawn or an objection is raised.
3. Data contained in complaint correspondence — for 3 years from the end of the correspondence or resolution of the complaint.

§6 Rights of data subjects

Data subjects have the right to: access their data, rectify their data, erase their data, restrict processing, data portability, object to processing based on legitimate interest and to processing for marketing purposes, and to withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal. Data subjects also have the right to lodge a complaint with the Polish Data Protection Authority (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa). To exercise these rights, contact the Controller at contact@clubhq.cloud.

§7 Voluntary provision of data

Providing data is voluntary but necessary to conclude and perform the Service contract or to join the waitlist.

§8 Cookies and similar technologies

The clubhq.cloud website does not use its own cookies for tracking or profiling. The site relies on external resources necessary for it to function — Google Fonts and the Web3Forms sign-up form service — whose providers may process data in accordance with their own privacy policies. Cookie settings can be changed at any time in your browser settings.

§9 Automated decision-making

The Controller does not make decisions about data subjects based solely on automated processing, including profiling, that would produce legal effects concerning them.

§10 Changes to this Privacy Policy

The Controller reserves the right to amend this Privacy Policy, and will announce changes by publishing a new version at clubhq.cloud.