Privacy Policy

Data Controller

The controller responsible for the processing of your personal data under the General Data Protection Regulation (GDPR) is:

Pluco Group Sp. z o.o. — Desivo Consulting Group
Warsaw, Poland
Email: support@desivo.de
Phone: +48 795 010 135

What Personal Data We Collect

We collect and process the following categories of personal data:

• Contact information: name, email address, phone number, company name
• Account credentials: email address and encrypted password (stored via Firebase Authentication)
• Company profile data: country, engagement type, and other information provided during registration
• Communication records: messages submitted via our contact form
• Private demo request data: business name, city, existing website, project goals, consent wording version, and request and confirmation timestamps
• Usage data: pages visited, session duration, browser type, and IP address (collected automatically)
• Cookie data: session cookies and functional cookies used to operate the client portal

How and Why We Use Your Data

We process your personal data for the following purposes, each with a corresponding legal basis under GDPR Article 6:

Provision of services (Art. 6(1)(b) — Contract): To register your account, provide access to the client portal, and deliver the consulting services you have engaged us for.

Communication (Art. 6(1)(b) — Contract / Art. 6(1)(f) — Legitimate Interest): To respond to contact form submissions, send project updates, invoices, and service-related notifications.

Legal compliance (Art. 6(1)(c) — Legal Obligation): To maintain invoicing and accounting records as required by Polish and EU law.

Security (Art. 6(1)(f) — Legitimate Interest): To authenticate users, protect the client portal from unauthorized access, and detect fraud.

Email verification (Art. 6(1)(b) — Contract): To verify ownership of the email address provided during registration before granting portal access.

Requested private demo (Art. 6(1)(b) — Pre-contract steps): To verify the request, review the submitted business information, prepare the requested concept, and respond about that specific request. Confirming a demo request does not create permission for general marketing.

Newsletter and promotional email (Art. 6(1)(a) — Consent): To send the Desivo Business Briefing, Desivo offers, and clearly labelled sponsored advertising only after you have actively subscribed and confirmed your email address. You may withdraw consent at any time using the unsubscribe link in every edition.

How Long We Retain Your Data

We retain personal data only for as long as necessary for the purposes for which it was collected:

— Account and client data: retained for the duration of the client relationship and for 3 years thereafter, in accordance with our contractual obligations and legitimate interests.
— Invoice and financial records: retained for 5 years as required by Polish accounting law.
— Contact form and private demo submissions: retained for 12 months, or for as long as necessary to respond and document the permitted scope.
— Newsletter records: active subscription data is retained until you unsubscribe. After unsubscribe, a minimal suppression and consent record may be retained as needed to demonstrate compliance and prevent further marketing email.
— Session cookies: expire after 14 days or upon logout.

Service Providers & Data Transfers

We use the following third-party services that may process personal data on our behalf:

Google Firebase (Google LLC) — Authentication and Firestore database. Data may be stored in the EU or US. Google processes data under Standard Contractual Clauses.

Zoho Mail / SMTP Provider — For sending transactional emails such as verification codes and welcome messages.

Vercel Inc. — Hosting of the Desivo website and client portal. Data is processed in accordance with Vercel's data processing agreement.

We do not sell or rent personal data to third parties. We do not use personal data for advertising profiling.

Cookies & Session Data

We use only strictly necessary cookies required for the operation of the website and client portal:

— __session: An httpOnly session cookie used to authenticate logged-in clients. This cookie is essential and cannot be disabled while using the portal. It expires after 14 days.

We do not use advertising cookies, analytics cookies from third-party providers, or social media tracking cookies. You can clear cookies at any time through your browser settings.

Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights:

• Right of access (Art. 15): Request a copy of the personal data we hold about you.
• Right to rectification (Art. 16): Request correction of inaccurate or incomplete data.
• Right to erasure (Art. 17): Request deletion of your personal data, subject to legal retention obligations.
• Right to restriction of processing (Art. 18): Request that we restrict processing of your data in certain circumstances.
• Right to data portability (Art. 20): Receive your data in a machine-readable format.
• Right to object (Art. 21): Object to processing based on legitimate interests.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting lawfulness of prior processing.

To exercise any of these rights, contact us at support@desivo.de. We will respond within 30 days. You also have the right to lodge a complaint with the Polish supervisory authority (UODO): uodo.gov.pl.

Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These include encrypted transmission (HTTPS/TLS), httpOnly session cookies, password hashing, and access controls on our Firestore database. Despite these measures, no system can guarantee absolute security. You use the portal at your own risk and should use a strong, unique password.

Desivo Business Briefing

The newsletter signup collects your email address, preferred language, signup source, consent wording and version, and relevant consent, confirmation, and unsubscribe timestamps. We use a double opt-in process: after opting in, you must confirm your email address before promotional messages begin. If you choose the optional newsletter checkbox while creating a Desivo account, completing account email verification also confirms the newsletter request; Google signup may use the already verified Google email identity.

The private demo form separates permission to respond to the requested demo from optional promotional consent. Confirming the request permits Desivo to respond about that demo. Later promotional offers are permitted only when the separate optional marketing choice was selected and the email address was confirmed.

The briefing may contain Desivo offers and clearly identified sponsored advertising. Desivo does not provide subscriber email addresses to advertisers. Confirmation and unsubscribe tokens are stored in hashed form. You can unsubscribe immediately through the link included in every newsletter or contact support@desivo.de.

AI Transparency

Desivo uses AI-assisted tools to create, improve, and automate parts of our digital experience, including selected content, customer support workflows, and business automation systems.

When you interact with a Desivo AI assistant, we clearly identify it as AI. Important requests, business decisions, and sensitive cases may be reviewed by our human team.

Some public content may be created or improved with AI support and is labelled where appropriate.

KI-Transparenz

Desivo nutzt KI-gestützte Tools, um Teile unserer digitalen Erfahrung zu erstellen, zu verbessern und zu automatisieren, einschließlich ausgewählter Inhalte, Kundenservice-Workflows und Business-Automatisierungssysteme.

Wenn Sie mit einem Desivo KI-Assistenten interagieren, wird dies klar gekennzeichnet. Wichtige Anfragen, geschäftliche Entscheidungen und sensible Fälle können von unserem menschlichen Team geprüft werden.

Einige öffentliche Inhalte können mit KI-Unterstützung erstellt oder verbessert werden und werden, wenn angemessen, entsprechend gekennzeichnet.

Updates to This Policy

We may update this Privacy Policy from time to time. Where changes are material, we will notify registered clients by email. The current version is always available at desivo.de/privacy.