# Privacy policy

- Link: https://stratumearth.eu/privacy-policy/
- Published: 2026-07-16T18:46:31+02:00
- Author: admin

1. This Privacy Policy sets out the rules for processing personal data collected
through the website **www.greendemocracy.com**, hereinafter referred to as the “
Website”. 2. The owner of the Website and the Data Controller is **Starflix Dublin
Limited, NIP: IE3587664KH, T12Y446 Douglas, Cork, 3 Saint Patrick’s Terrace, Douglas
West**, hereinafter referred to as the Controller. 3. Personal data collected by
the Controller through the Website is processed in accordance with **Regulation (
EU) 2016/679 of the European Parliament and of the Council** of 27 April 2016 on
the protection of natural persons with regard to the processing of personal data
and on the free movement of such data, and repealing Directive 95/46/EC (**General
Data Protection Regulation**), also referred to as **GDPR**. 4. The Controller takes
special care to respect the privacy of Clients visiting the Website.

## § 1 Types of processed data, purposes and legal basis

 **1.** The Controller collects information about natural persons performing legal
actions not directly related to their business activity, natural persons conducting
business or professional activity in their own name, and natural persons representing
legal entities or organizational units without legal personality that are granted
legal capacity by law, conducting business or professional activity in their own
name, hereinafter collectively referred to as **Clients**. **2.** The Controller
processes personal data of Clients in connection with the use of the contact form
service on the Website for the purpose necessary to perform a contract or to take
steps prior to entering into a contract – processing basis under Art. 6(1)(b) GDPR.**
3.** When using the contact form service, the Client provides the following data:

 * **email address**
 * **first name**
 * **phone number**

 **4.** While using the Website, additional information may be collected, including:
the IP address assigned to the Client’s computer or the external IP address of the
Internet provider, domain name, browser type, access time, operating system type.
Navigational data may also be collected from Clients, including information about
links and references they choose to click or other actions taken on the Website 
for purposes related to service provision, as well as for technical, administrative,
analytical and statistical purposes – in this regard, the processing basis is also
Art. 6(1)(f) GDPR, i.e. necessity for purposes arising from the Controller’s legitimate
interest, which is ensuring IT security and Website management, as well as improving
the functionality of the Website and services provided.

## § 2 Data recipients

 **1.** The Client’s personal data is transferred to service providers used by the
Controller in operating the Website. Service providers to whom personal data is 
transferred, depending on contractual arrangements and circumstances, either follow
the Controller’s instructions regarding the purposes and methods of processing such
data (**processors**) or independently determine the purposes and methods of their
processing (**controllers**).

 * **1.1. Processors.** The Controller uses providers who process personal data 
   solely on the Controller’s instructions. These include, among others, providers
   offering hosting services, accounting services, marketing systems, website traffic
   analysis systems, and marketing campaign effectiveness analysis systems.
 * **1.2. Controllers.** The Controller uses providers who do not act solely on 
   instructions and independently determine the purposes and methods of using Clients’
   personal data. They provide electronic payment and banking services.

 **2. Location.** Service providers are based mainly in Poland and in other countries
of the European Economic Area (EEA). 3. Upon request, the Controller discloses personal
data to authorized state authorities, in particular to organizational units of the
Prosecutor’s Office, Police, the President of the Personal Data Protection Office,
the President of the Office of Competition and Consumer Protection, or the President
of the Office of Electronic Communications.

## § 3 Data retention period

 **1.** Clients’ personal data is retained:

 * 1.1. Where the basis for processing personal data is consent, the Client’s personal
   data is processed by the Controller until the consent is withdrawn, and after
   withdrawal of consent for a period corresponding to the limitation period for
   claims that the Controller may raise and that may be raised against them. Unless
   a specific provision provides otherwise, the limitation period is six years, 
   and for periodic performance claims and claims related to business activity –
   three years.
 * 1.2. Where the basis for processing data is the performance of a contract, the
   Client’s personal data is processed by the Controller for as long as is necessary
   to perform the contract, and thereafter for a period corresponding to the limitation
   period for claims. Unless a specific provision provides otherwise, the limitation
   period is six years, and for periodic performance claims and claims related to
   business activity – three years.

## § 4 Cookies mechanism, IP address

 1. The Website uses small files called cookies. They are stored by the Controller
on the end device of the person visiting the Website, provided the web browser allows
it. A cookie file typically contains the domain name from which it originates, its“
expiry time”, and an individual, randomly selected number identifying the file. 
Information collected using such files helps to customize the products offered by
the Controller to the individual preferences and actual needs of persons visiting
the Website. 2. The Controller uses two types of cookies:

 * **2.1. Session cookies:** after the browser session ends or the computer is turned
   off, the stored information is deleted from the device memory. The session cookies
   mechanism does not allow the collection of any personal data or any confidential
   information from Clients’ computers.
 * **2.2. Persistent cookies:** they are stored in the memory of the Client’s end
   device and remain there until they are deleted or expire. The persistent cookies
   mechanism does not allow the collection of any personal data or any confidential
   information from Clients’ computers.

 3. The Controller uses its own cookies for the purpose of:

 * 3.1. analysis, research and audience auditing, and in particular for creating
   anonymous statistics that help understand how Clients use the Website, which 
   enables improvement of its structure and content.

 4. The Controller uses external cookies for the purpose of:

 * 4.1. presenting on informational pages of the Website a map indicating the location
   of the Controller’s office, using the maps.google.com service (external cookie
   controller: Google Inc based in the USA).

 5. The cookies mechanism is safe for the computers of Clients visiting the Website.
In particular, it is not possible for viruses or other unwanted software or malicious
software to enter Clients’ computers through this method. Nevertheless, Clients 
have the ability in their browsers to limit or disable access of cookie files to
computers. If this option is used, the use of the Website will be possible, except
for functions that by their nature require cookie files. 6. The Controller may collect
Clients’ IP addresses. An IP address is a number assigned to the computer of a person
visiting the Website by the Internet service provider. The IP number enables access
to the Internet. In most cases, it is assigned to the computer dynamically, i.e.
it changes with each connection to the Internet and for this reason is commonly 
treated as non-personal identifying information. The IP address is used by the Controller
to diagnose technical problems with the server, create statistical analyses (e.g.
determining from which regions the most visits are recorded), as information useful
in administering and improving the Website, as well as for security purposes and
possible identification of unwanted automated programs browsing the Website content
that burden the server.

## § 5 Rights of data subjects

 Persons whose data is processed are entitled to: **1. The right to withdraw consent
to data processing at any time:**

 * 1.1. The Client has the right to withdraw any consent they have given.
 * 1.2. Withdrawal of consent takes effect from the moment of withdrawal.
 * 1.3. Withdrawal of consent does not affect the lawfulness of processing carried
   out on the basis of consent before its withdrawal.
 * 1.4. Withdrawal of consent does not entail any negative consequences for the 
   Client, but may prevent further use of services or functionalities that the Controller
   may legally provide only with consent.

 **2. The right to object to data processing:**

 * 2.1. The Client has the right to object at any time – on grounds relating to 
   their particular situation – to the processing of their personal data based on
   Art. 6(1)(e) or (f) GDPR, including profiling based on those provisions. The 
   Controller may no longer process such personal data unless they demonstrate compelling
   legitimate grounds for the processing which override the interests, rights and
   freedoms of the data subject, or grounds for the establishment, exercise or defence
   of legal claims.
 * 2.2. Opting out by email from receiving marketing communications about products
   or services shall constitute the Client’s objection to the processing of their
   personal data, including profiling for those purposes.

 **3. The right to erasure of data (“right to be forgotten”):**

 * 3.1. The Client has the right to request the erasure of all or some of their 
   personal data.
 * 3.2. The Client has the right to request the erasure of personal data if:
    - 3.2.1. the personal data are no longer necessary in relation to the purposes
      for which they were collected or otherwise processed;
    - 3.2.2. they have withdrawn the specific consent, to the extent that the personal
      data was processed on the basis of their consent;
    - 3.2.3. they have objected pursuant to Art. 21(1) GDPR to the processing and
      there are no overriding legitimate grounds for the processing, or they have
      objected pursuant to Art. 21(2) GDPR to the processing;
    - 3.2.4. the personal data has been unlawfully processed;
    - 3.2.5. the personal data must be erased for compliance with a legal obligation
      in Union or Member State law to which the Controller is subject;
    - 3.2.6. the personal data has been collected in relation to the offer of information
      society services.
 * 3.3. Despite a request for erasure of personal data, in connection with an objection
   or withdrawal of consent, the Controller may retain certain personal data to 
   the extent that processing is necessary for the establishment, exercise or defence
   of legal claims, as well as for compliance with a legal obligation requiring 
   processing under Union or Member State law to which the Controller is subject.
   This applies in particular to personal data including: first name, last name,
   email address, which data is retained for the purposes of handling complaints
   and claims related to the use of the Controller’s services, or additionally residential
   address/correspondence address, order number, which data is retained for the 
   purposes of handling complaints and claims related to concluded sales contracts
   or provision of services.

 **4. The right to restriction of processing:**

 * 4.1. The Client has the right to request restriction of the processing of their
   personal data. Filing such a request, until it is resolved, prevents the use 
   of certain functionalities or services the use of which involves processing of
   data covered by the request. The Controller will also not send any communications,
   including marketing ones.
 * 4.2. The Client has the right to request restriction of the use of personal data
   in the following cases:
    - 4.2.1. when they contest the accuracy of their personal data – the Controller
      restricts their use for the time needed to verify the accuracy of the data,
      but for no longer than 7 days;
    - 4.2.2. when data processing is unlawful and instead of erasure, the Client
      requests restriction of their use;
    - 4.2.3. when the personal data is no longer necessary for the purposes for 
      which it was collected or used, but it is needed by the Client for the establishment,
      exercise or defence of legal claims;
    - 4.2.4. when the data subject has objected to the processing of their data –
      until it is determined whether the legitimate grounds on the Controller’s 
      side override the grounds of the data subject’s objection.

 **5. The right to request access to personal data and to receive a copy thereof:**

 * 5.1. The Client has the right to obtain from the Controller confirmation as to
   whether personal data is being processed, and where that is the case, the Client
   has the right to:
    - 5.1.1. obtain access to their personal data;
    - 5.1.2. obtain information about the purposes of processing, the categories
      of personal data being processed, the recipients or categories of recipients
      of such data, the planned period of storing the Client’s data or the criteria
      for determining that period (where it is not possible to determine the planned
      processing period), the rights available to the Client under GDPR and the 
      right to lodge a complaint with a supervisory authority; where personal data
      has not been collected from the data subject – any available information about
      its source; information about automated decision-making, including profiling
      referred to in Art. 22(1) and (4) GDPR, and – at least in those cases – meaningful
      information about the logic involved, as well as the significance and the 
      envisaged consequences of such processing for the data subject; and information
      about safeguards applied in connection with the transfer of personal data 
      outside the European Union;
    - 5.1.3. obtain a copy of their personal data. The right to obtain a copy must
      not adversely affect the rights and freedoms of others.

 **6. The right to rectification (correction) of data:**

 * 6.1. The Client has the right to request that the Controller rectify without 
   undue delay inaccurate personal data concerning them. Taking into account the
   purposes of the processing, the data subject has the right to have incomplete
   personal data completed, including by means of providing a supplementary statement,
   by directing a request to the email address in accordance with §6 of the Privacy
   Policy.

 **7. The right to data portability:**

 * 7.1. The Client has the right to receive their personal data which they have 
   provided to the Controller, and then to transmit it to another data controller
   of their choice. The Client also has the right to request that the personal data
   be transmitted by the Controller directly to such controller, where technically
   feasible. In such a case, the Controller will transmit the Client’s personal 
   data in a CSV file format, which is a commonly used, machine-readable format 
   that allows the received data to be transmitted to another data controller.

 **8. The right to lodge a complaint with a supervisory authority:**

 * 8.1. The Client has the right to lodge a complaint with the President of the 
   Personal Data Protection Office regarding any violation of their data protection
   rights or other rights granted under GDPR.

 9. Where the Client exercises a right arising from the above rights, the Controller
fulfils the request or refuses to fulfil it without undue delay, but no later than
within one month of receipt. However, if – due to the complex nature of the request
or the number of requests – the Controller is unable to fulfil the request within
one month, it shall fulfil it within the next two months, informing the Client in
advance within one month of receipt of the request of the intended extension and
its reasons. 10. The Client may submit complaints, enquiries and requests to the
Controller regarding the processing of their personal data and the exercise of their
rights.

## § 6 Changes to the Privacy Policy

 **1.** The Privacy Policy may be changed, and the Controller is not obliged to 
inform about such changes. **2.** Questions related to the Privacy Policy should
be directed to the following email address: **[jayashree.chandrapa@gmail.com](https://stratumearth.eu/privacy-policy/jayashree.chandrapa@gmail.com)****
3.** Date of last modification: **August 13, 2026**