Privacy Policy
Information on the processing of personal data by ILUN Systems Sp. z o.o.
Version 3.0 · Last updated: May 2026
1. Data Controller
The controller of your personal data is ILUN Systems Sp. z o.o., ul. Lipowa 4/2, 64-600 Oborniki, Poland, NIP: 6060117513, KRS: 0001103612 (hereinafter: "Rotech Group" or "we").
Contact for data protection matters: kontakt@rotechgroup.eu
2. What data we collect
- Contact data - first and last name, e-mail address, phone number, company name, job title (contact form, feedback form)
- Technical data - IP address, browser type, pages visited within the website (server logs)
- Correspondence data - content of messages sent through forms
3. Purpose and legal basis for processing
Contact form / request for quotation
Purpose: responding to your inquiry and possible entering into a business relationship.
Legal basis: Art. 6(1)(b) GDPR (necessity to take steps prior to entering into a contract) or Art. 6(1)(f) GDPR (legitimate interest of the controller).
Feedback form
Purpose: publication of customer references on the website.
Legal basis: Art. 6(1)(a) GDPR (consent).
Server logs
Purpose: ensuring the security and proper operation of the website.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest).
4. Selected data protection measures
We apply technical and organisational measures appropriate to the risk of processing:
- Transmission encryption (SSL/TLS) - communication between the browser and the server is encrypted with an SSL certificate. HTTP to HTTPS redirection is enforced.
- Strong passwords and 2FA - access to administrative systems (hosting, mail, CMS) protected by strong passwords and two-factor authentication.
- Backups - regular backups of website data and configuration carried out by the hosting provider (LH.pl) and by our own procedures.
- Restricted access - only authorised persons trained in GDPR compliance have access to personal data.
- Security updates - systematic updates of server software and website components.
Despite the protective measures applied, no IT system provides a hundred percent security guarantee. If you suspect a data breach, please contact us: kontakt@rotechgroup.eu
5. Hosting
The rotechgroup.eu website is hosted in Poland by LH.pl Sp. z o.o. (ul. Franklina Roosevelta 22, 60-829 Poznań, NIP: 7811822968), with whom ILUN Systems Sp. z o.o. has concluded a data processing agreement in accordance with Art. 28 GDPR.
The server stores access logs containing:
- client IP address
- date and time of the request
- URL of the requested resource
- HTTP response code (e.g., 200, 404)
- browser type and version (User-Agent)
- referring page address (Referer)
Server logs are used exclusively for diagnostic and security purposes. They are stored for a maximum of 12 months and then automatically deleted. LH.pl processes this data only on the documented instructions of ILUN Systems Sp. z o.o.
6. Data retention period
- Contact form - for the duration of handling the inquiry, and then until any claims become time-barred (max. 3 years)
- Feedback form - until the consent is withdrawn or the testimonial is deleted
- Server logs - maximum 12 months, then deleted
- GA4 analytics cookies (_ga, _ga_*) - 2 years (Google default setting); data aggregated in Google Analytics - 14 months
7. Rights of the data subject
You have the right to:
- access your data and receive a copy of it
- rectification (correction) of data
- erasure of data ("right to be forgotten")
- restriction of processing
- data portability
- object to processing
- withdraw consent (where processing is based on consent)
- lodge a complaint with the President of UODO (Polish Data Protection Authority), ul. Stawki 2, 00-193 Warsaw, Poland
To exercise the rights listed above, please contact us: kontakt@rotechgroup.eu
8. Data recipients and transfers outside the EEA
We do not sell personal data. We use external service providers to whom we entrust data processing for specific purposes. Below is a list of recipients along with information on any data transfers outside the European Economic Area (EEA):
| Recipient | Country | Purpose | Transfer basis |
|---|---|---|---|
| LH.pl Sp. z o.o. | Poland (EEA) | Website hosting | Data processing agreement (Art. 28 GDPR) |
| Formspree Inc. | USA (outside EEA) | Contact form handling | Standard Contractual Clauses (SCC 2021/914) |
| Google LLC | USA (outside EEA) | Google Analytics 4, Google Tag Manager | SCC + Data Privacy Framework (DPF) |
| EmailJS Ltd | USA (outside EEA) | Email notifications (optional) | Standard Contractual Clauses (SCC) |
| OpenStreetMap Foundation | UK (adequate protection) | Map on the contact page | EC adequacy decision (Art. 45 GDPR) |
| YouTube LLC (Google) | USA (outside EEA) | Video playback (youtube-nocookie.com) | SCC + Data Privacy Framework (DPF) |
The Standard Contractual Clauses (SCC) approved by the European Commission in Decision 2021/914 ensure an adequate level of protection for data transferred to the USA. Up-to-date information on SCC and DPF is available on the European Commission website.
9. Cookies and Google Analytics
The rotechgroup.eu website uses two categories of cookies:
9.1 Necessary (technical) cookies
Required for the website to function properly. They do not require user consent. They are deleted after the session ends or stored for the short term (e.g., interface preferences).
9.2 Analytics cookies - Google Analytics 4 (GA4)
With your consent, we use Google Analytics 4 to analyse website traffic (number of visits, traffic sources, user behaviour). GA4 is provided by Google LLC (USA) and uses the following cookies:
- _ga - user identifier, validity: 2 years
- _ga_[ID] - session identifier, validity: 2 years
Data collected by GA4 is anonymised (IP anonymisation enabled) and transferred to Google LLC (USA) on the basis of Standard Contractual Clauses. Data retention in Google Analytics: 14 months.
You can withdraw consent for analytics cookies at any time - clear cookies in your browser settings or use the Google Analytics Opt-out Browser Add-on.
Legal basis: Art. 6(1)(a) GDPR (consent) + Art. 173 of the Polish Telecommunications Act.
10. Managing cookies
You can manage cookies yourself in your browser settings. Below are links to instructions for the most popular browsers:
On mobile devices:
- Android (Chrome) - Settings → Privacy and security → Cookies
- iOS (Safari) - Settings → Safari → Privacy and security → Block all cookies
Blocking all cookies may affect the functionality of certain features of the website.
11. Data Protection Officer
ILUN Systems Sp. z o.o. is not required to appoint a Data Protection Officer (DPO) under Art. 37 GDPR. For matters related to personal data protection, please contact the Controller directly: kontakt@rotechgroup.eu
12. Changes to the policy
We reserve the right to update this policy. We will inform you of any significant changes by posting a new version on this page, indicating the date of the update and the version number. Previous versions of the policy are available on request at kontakt@rotechgroup.eu.