Privacy Policy – winkeypro.com

Effective date: 22.03.2026

1. General Information

1. This Privacy Policy applies to the website operating at https://winkeypro.com (the “Service”).
2. The data controller is Raponit Patryk Bzyl, address: ul. Dębowa 5, 63-421 Antonin, Poland, Tax ID / EU VAT ID: PL6222845712, REGON: 523964434 (the “Controller”).
3. Contact email for privacy matters: info@winkeypro.com.
4. The Controller processes personal data in line with GDPR and other applicable data protection laws.

2. Purposes and Legal Bases of Processing

1. Order handling and digital key delivery – contract performance.
2. Payment processing and invoicing – contract performance and legal obligation.
3. Customer support and complaint handling – contract performance, legal obligation, legitimate interest.
4. Fraud prevention, security and service administration – legitimate interest.
5. Tax and accounting compliance (including VAT determination for digital services) – legal obligation.
6. Marketing communications (if used) – consent and/or legitimate interest, depending on context and applicable law.

3. Categories of Data

1. Identity and contact data (name, email, phone, billing data, company details if provided).
2. Transaction data (order ID, payment status, amount, currency, payment method).
3. Technical data (IP address, browser/device information, logs, cookie identifiers).
4. Support and complaint correspondence data.

4. Data Recipients

1. Data may be shared with trusted processors and partners only where necessary, including:
   • hosting and IT infrastructure providers,
   • store system and technical service providers,
   • payment operators (including Stripe and related payment method providers),
   • accounting/tax and legal service providers,
   • security/anti-fraud service providers.
2. Where required, data sharing is based on data processing agreements and legal safeguards.

5. International Transfers

1. Data is primarily processed within the EEA.
2. If data is transferred outside the EEA, appropriate safeguards are applied (e.g. Standard Contractual Clauses), as required by law.

6. Data Retention

1. Order and invoicing data: for the period required by tax/accounting law.
2. Complaint/support data: for the period needed to resolve claims and for limitation periods.
3. Consent-based data: until consent is withdrawn.
4. Technical and log data: for security and operational periods necessary for the Service.

7. Your Rights

1. You may have the right to access, rectify, erase, restrict processing, object, and data portability, subject to applicable law.
2. Where processing is based on consent, you may withdraw consent at any time.
3. You may lodge a complaint with a competent data protection authority (for Poland: President of the Personal Data Protection Office, UODO).

8. Cookies and Similar Technologies

1. The Service uses cookies and similar technologies.
2. Cookies are used for:
   • necessary operation (session, login, cart, security),
   • functional preferences,
   • analytics,
   • marketing (where consent is required and granted).
3. You can manage your cookie preferences at any time via the cookie settings tool.
4. Disabling certain cookies may affect website functionality.

9. Server Logs and Security

1. The Controller uses technical and organizational safeguards, including encrypted transmission (SSL/TLS), software updates and access controls.
2. Server logs may include IP, timestamp, requested URLs, browser/system information and HTTP errors for security and diagnostics.

10. Automated Decision-Making

1. Anti-fraud and risk systems may be used to protect transactions and the Service.
2. No solely automated decisions producing legal effects are made, unless required and permitted by applicable law.

11. Policy Updates

1. This Privacy Policy may be updated due to legal, technical or organizational changes.
2. The current version is always available at /privacy-policy.

12. Contact

For privacy questions, contact: info@winkeypro.com.

COOKIE SETTINGS