Privacy Policy
Last updated · May 2026
1. Who is the data controller
The data controller responsible for personal data processed on this website is Twój Startup, the Polish business incubator that handles bookings, payments and invoicing for Russian with Julia. Detailed legal and accounting information about the company is available on request. For any privacy-related question, you can reach us at verbiloulia785@gmail.com.
2. What data we collect
We only collect the personal data that is strictly necessary to deliver the service you purchased:
- Identity & contact: first name, last name (if provided), email address.
- Lesson scheduling: date and time of the introductory lesson; for packs, the dates of scheduled lessons.
- Payment data: handled entirely by Stripe (our payment provider). We never see or store your card details — only the transaction reference and amount.
- Account data (video courses): email address used to log in and the list of video courses you have purchased.
- Email correspondence: messages you send us when you contact support.
- Usage data (analytics): with your consent, anonymous statistics about how you use the site (pages viewed, traffic source, approximate region), collected via Google Analytics and the Meta Pixel. See our Cookies Policy and section 4 below.
3. Why we process your data (legal basis)
- Performance of the contract (Art. 6.1.b GDPR): processing payments, scheduling lessons, sending purchase confirmations, granting access to video courses.
- Legal obligation (Art. 6.1.c GDPR): keeping accounting records as required by tax law.
- Legitimate interest (Art. 6.1.f GDPR): preventing fraud, securing our service.
4. Who we share your data with
We never sell your data. We share it only with the technical providers strictly required to deliver the service, all bound by GDPR-compliant data processing agreements:
- Stripe (payment processing) — processes your payment data. Stripe is certified under EU Standard Contractual Clauses.
- Convex (database) — stores your account, lesson and pack data. Hosted in the EU (eu-west-1).
- Vercel (web hosting) — serves the website and processes incoming requests.
- Resend (email delivery) — sends the confirmation and transactional emails you receive from us.
- Google Calendar / Google Meet — we create a calendar event with you as attendee for each lesson; you receive an invitation by email and the lesson is held over Google Meet.
- Cloudflare R2 (video storage) — stores the video course files served on /courses.
- Google Analytics (audience measurement) — only if you accept analytics cookies. Processes anonymous usage statistics. Retention: 14 months.
- Meta (Facebook/Instagram — reach measurement) — only if you accept marketing cookies. Processes pixel events. Conversion data retention: 90 days.
5. International transfers
Some of our providers (Stripe, Vercel, Cloudflare, Google) may process data outside the European Economic Area. In all cases, we ensure transfers are covered by the EU Standard Contractual Clauses or equivalent guarantees, in accordance with Articles 44-49 GDPR.
6. How long we keep your data
- Account & lesson data: for the duration of our commercial relationship + 3 years after your last lesson (commercial limitation period).
- Accounting records: 10 years, as required by tax law.
- Email correspondence: up to 3 years from the last exchange.
7. Your rights (GDPR)
Under GDPR (and equivalent laws in your country), you have the right to:
- Access the personal data we hold about you.
- Request correction of inaccurate data.
- Request deletion of your data (subject to our legal obligations, e.g. accounting records).
- Object to or restrict processing.
- Request portability of your data.
- Lodge a complaint with your local data protection authority (in Poland: UODO — Urząd Ochrony Danych Osobowych).
To exercise any of these rights, email us at verbiloulia785@gmail.com. We will respond within 30 days.
8. Security
We rely on industry-standard providers (Stripe, Convex, Vercel, Cloudflare, Google) that implement encryption in transit (HTTPS) and at rest, regular security audits, and access controls. We never store passwords or card details ourselves.
9. Cookies
See our Cookies Policy for details on how we use cookies.
10. Changes to this policy
We may update this policy to reflect changes in our service or in applicable law. The date of the latest update is shown at the top of this page.