Privacy Policy

This Privacy Policy explains how personal data is processed in connection with the website www.fragment.im (the “Website”), including when you visit the Website or send an enquiry through the contact form. It is intended to provide the information required under the EU General Data Protection Regulation (GDPR).

This policy concerns data processed in connection with the Website and website enquiries. If an enquiry develops into a client relationship, additional processing may take place for contract performance, billing, accounting and other business purposes, and additional information may be provided where required.

1. Data controller

The controller of personal data processed through the Website is:

• Business / legal name: Fragment Paweł Świniarski

• Business address: ul. Lipowa 6a/12, 81-572 Gdynia, Poland

• Email: pawel@fragment.im

• Website: www.fragment.im

2. What data is collected

Contact form

If you contact me through the Website, the form may collect the following information:

• name

• company

• email address

• estimated budget range

• the content of your message (“How can I help”)

Providing data through the form is voluntary, but the information required by the form is necessary for me to receive and respond to your enquiry.

Technical and usage data

When you access the Website, the website infrastructure and embedded services may process standard technical information necessary to deliver, secure and display the Website, such as IP address, browser and device information, timestamps, request data and anti-abuse or spam-prevention signals.

Framer Analytics

The Website uses Framer Analytics to understand general website traffic and usage. According to Framer, its built-in analytics are anonymised, do not use cookies or persistent identifiers, and do not collect information that identifies an individual visitor.

3. Why the data is processed and the legal basis

Responding to enquiries

Data submitted through the contact form is used to review and respond to your enquiry, discuss a potential project and, where relevant, take steps requested by you before entering into a contract. The legal basis is Article 6(1)(b) GDPR where the processing is necessary to take pre-contractual steps at your request. For general business enquiries that do not fall within that basis, the legal basis is Article 6(1)(f) GDPR, based on my legitimate interest in receiving and responding to business communications.

Operating and securing the Website

Technical data may be processed to provide the Website, protect it against abuse and spam, maintain security and troubleshoot technical issues. The legal basis is Article 6(1)(f) GDPR, based on my legitimate interest in operating a secure and reliable website.

Website analytics

Framer Analytics is used to understand aggregate website usage and improve the Website. Framer states that this analytics feature does not collect personal data from Website visitors.

4. Service providers and recipients

Personal data may be processed by service providers used to operate the Website and handle enquiries. These currently include:

• Framer B.V. - website hosting, native forms, spam protection and built-in analytics;

• Google (Gmail) - receiving and storing messages sent through the contact form;

• Spline, Inc. - delivery of interactive 3D content embedded on the Website.

These providers may use subprocessors where necessary to provide their services. I do not sell personal data to third parties.

5. International data transfers

Some service providers or their subprocessors may process data outside the European Economic Area, including in the United States. Where personal data is transferred outside the EEA, the transfer must rely on a lawful mechanism under Chapter V GDPR, such as an adequacy decision (including the EU-U.S. Data Privacy Framework where applicable) or Standard Contractual Clauses approved by the European Commission, together with any additional safeguards required by law.

6. How long data is kept

Personal data submitted through the contact form is kept for as long as reasonably necessary to handle the enquiry and any related pre-contractual communication. Data may be retained for longer where this is necessary to comply with a legal obligation or to establish, exercise or defend legal claims.

Technical information processed by service providers is retained in accordance with the relevant provider’s retention rules and only for as long as necessary for the purposes for which it is processed. Framer Analytics is designed to provide anonymised website statistics rather than visitor profiles.

7. Cookies, analytics and embedded content

The Website currently uses Framer Analytics. Framer states that its built-in analytics do not use cookies or persistent identifiers, so no consent is required solely for the use of Framer Analytics.

Google Analytics and advertising or marketing tracking tools are not currently used on the Website.

The Website contains interactive 3D content provided through Spline. When embedded Spline content is loaded, Spline may receive technical information needed to provide the service. Spline’s services can support cookies or similar browser storage in some configurations. Where optional, non-essential cookies or similar technologies are used and consent is required by applicable law, they must be activated only after the required consent has been obtained.

If the Website later introduces Google Analytics, advertising tools or other non-essential tracking technologies, this policy will be updated and an appropriate consent mechanism will be introduced where required.

8. Your rights

Subject to the conditions set out in the GDPR, you may have the right to:

• access your personal data;

• request correction of inaccurate or incomplete personal data;

• request erasure of your personal data;

• request restriction of processing;

• object to processing based on legitimate interests;

• receive personal data in a portable format where the right to data portability applies.

To exercise these rights, contact me at pawel@fragment.im.

You also have the right to lodge a complaint with a competent supervisory authority. In Poland, the supervisory authority is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych).

9. Automated decision-making

Personal data collected through the Website is not used for automated decision-making or profiling that produces legal or similarly significant effects.

10. Changes to this Privacy Policy

This Privacy Policy may be updated if the Website, the services used on it or applicable legal requirements change.