Privacy Policy

Last updated: February 20, 2026

This Privacy Policy explains how UNASHAMED ("we", "us", "our") collects, uses, and protects your personal data when you visit unashamed.app or purchase our products. We are committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR — Regulation (EU) 2016/679), the Polish Act on Personal Data Protection (Ustawa o ochronie danych osobowych), and applicable EU legislation.

1. Data Controller

Paweł Szczabel
NIP: 9910361892
ul. Wygonowa 51/2A, 45-402 Opole, Poland
Email: tony.unashamed@gmail.com
Website: https://unashamed.app

We are not required to appoint a Data Protection Officer (DPO) under Article 37 GDPR, as we do not carry out large-scale processing of special categories of data.

2. What Data We Collect

Data	Purpose	Legal Basis (Art. 6 GDPR)
IP address, browser type, device info	Website analytics, security	Legitimate interest (Art. 6(1)(f))
Page views, click events	Improving our website and ads	Consent (Art. 6(1)(a))
Email address (if provided)	Order fulfillment, support	Contract performance (Art. 6(1)(b))
Payment data	Payment processing	Contract performance (Art. 6(1)(b))

We do not collect sensitive data (health, religion, sexual orientation, political opinions) as defined in Art. 9 GDPR.

3. Cookies and Tracking

We use the following third-party services:

• Google Analytics (Firebase) — for website analytics. Data processed under Google's Privacy Policy.
• Google Ads (gtag.js) — for conversion tracking. Conversion ID: AW-17965460464. Used to measure ad effectiveness. No personally identifiable information is shared with Google beyond anonymized click/conversion data.

You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

You can manage cookie preferences in your browser settings at any time.

4. Payment Processing

Payments are processed by EasyCart (easycart.pl). We do not store your credit card details. Payment data is handled entirely by the payment processor in accordance with PCI DSS standards. See EasyCart's Privacy Policy.

5. Data Retention

• Analytics data: Retained for 14 months, then automatically deleted.
• Purchase records: Retained for 5 years as required by Polish tax law (Ustawa o rachunkowości).
• Support emails: Retained for 2 years after last contact, then deleted.

6. Your Rights Under GDPR

Under GDPR (Articles 15-22), you have the right to:

• Access your personal data (Art. 15)
• Rectify inaccurate data (Art. 16)
• Erase your data ("right to be forgotten") (Art. 17)
• Restrict processing (Art. 18)
• Data portability — receive your data in a machine-readable format (Art. 20)
• Object to processing based on legitimate interest (Art. 21)
• Withdraw consent at any time (Art. 7(3))

To exercise any of these rights, email us at tony.unashamed@gmail.com. We will respond within 30 days as required by Art. 12(3) GDPR.

7. International Data Transfers

Some of our service providers (Google, Firebase) may transfer data outside the EEA. These transfers are protected by Standard Contractual Clauses (SCCs) approved by the European Commission (Art. 46(2)(c) GDPR) and the EU-US Data Privacy Framework.

8. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

• HTTPS/TLS encryption on all pages
• Secure hosting on Vercel (SOC 2 Type II certified)
• No local storage of payment data
• Access limited to the data controller only

9. Children's Privacy

Our services are not directed at individuals under 18 years of age. We do not knowingly collect data from minors. If we learn that we have collected data from a child under 18, we will delete it immediately.

10. Right to Lodge a Complaint

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych — PUODO):

Urząd Ochrony Danych Osobowych
ul. Stawki 2, 00-193 Warszawa, Poland
https://uodo.gov.pl

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date. Continued use of the website after changes constitutes acceptance.

12. Contact

For any privacy-related questions, contact us at:
tony.unashamed@gmail.com