§Document
Privacy Policy
In short: this website uses no cookies, analytics or third-party scripts and does not log visitors’ IP addresses. I process personal data when you write to me, when you become a client and when you use the AI agent. Details below.
1. Controller
- The controller is Paweł Borkowski, trading as Neurabs, ul. Dywizjonu 303 149/17, 01-470 Warsaw, Poland, EU VAT ID PL1181788652, REGON 147161841. For anything concerning your personal data, write to hello@neurabs.com.
- I have not appointed a data protection officer, as I am not required to.
2. Visiting neurabs.com
- This website uses no cookies or similar technologies, analytics tools, advertising pixels or third-party scripts. Fonts and images are served from my server, so your browser does not connect to other companies.
- To send the page to your browser, the server has to use your IP address briefly. I do not record it in access logs. Legal basis: my legitimate interest in making the website available (Article 6(1)(f) GDPR).
3. E-mail contact
- When you write to me, I process your e-mail address, name, the content of your message and any other data you provide – to reply and prepare an offer.
- Legal basis: steps taken at your request before entering into a contract (Article 6(1)(b) GDPR) or my legitimate interest in answering correspondence (Article 6(1)(f) GDPR).
- If we do not conclude a contract, I keep the correspondence for up to 12 months after the last message, and longer only where needed to establish, exercise or defend legal claims.
4. Clients and contracts
- I process the data needed to conclude and perform a contract: name, company name, address, tax/VAT ID, e-mail address, phone number (if you give it), invoicing and payment data, and correspondence.
- Purposes and legal bases:
- concluding and performing the contract (Article 6(1)(b) GDPR),
- accounting and tax obligations, including invoices (Article 6(1)(c) GDPR),
- establishing, exercising and defending legal claims and keeping the services secure – my legitimate interest (Article 6(1)(f) GDPR).
- Retention: for the duration of the contract, then until the limitation periods for claims expire (under Polish law generally 6 years, and 3 years for claims related to business activity and periodic payments, counted to the end of the calendar year). Accounting records are kept for 5 years from the end of the calendar year in which the tax payment deadline passed.
5. AI agent and monitoring of conversations
- If you use the AI agent, I process: the content of your messages and the agent’s replies, uploaded files, your Telegram account ID and name, timestamps and the changes made to the website.
- Purposes and legal bases:
- carrying out your instructions, i.e. providing the service (Article 6(1)(b) GDPR),
- monitoring conversations – personally and with automated filters – to keep the service secure and compliant with the terms, detect abuse and illegal content, fix errors, improve the agent and establish, exercise or defend legal claims – my legitimate interest (Article 6(1)(f) GDPR).
- Retention: 90 days from the message or, where it relates to a reported violation, dispute or proceedings, until it is resolved.
- I do not use these conversations to train AI models. Please do not send the agent health data or other special categories of data, passwords, card numbers or identity documents.
- Automated filters may stop an instruction; blocking an account or ending a contract is decided by a human. The AI agent does not take decisions about you that produce legal effects.
6. Domains
- In plans with a domain I register the domain in your name, so I pass your data to the registrar and the domain registry – to perform the contract (Article 6(1)(b) GDPR). Registries may publish some registrant data in WHOIS under their own rules; data of individuals is usually redacted.
7. My clients’ websites
- Data of visitors to the websites I host for clients, and data placed on those websites, are processed on my clients’ behalf under a data processing agreement (section 16 of the Terms). The controller is the owner of the website – see its privacy policy.
8. Recipients
- Data may be received – only as needed for the purpose in question – by:
- my server provider (OVHcloud – servers in the European Union),
- my code repository and deployment automation provider (GitLab),
- my e-mail provider,
- the AI-model provider – for the AI agent,
- Telegram – when you write to the AI agent; Telegram processes data as a separate controller under its own privacy policy,
- domain registrars and registries, my bank and the people handling my accounting,
- public authorities – where required by law.
9. Transfers outside the EEA
- Some providers (e.g. GitLab, the AI-model provider, Telegram) may process data outside the European Economic Area, including in the USA. This is based on a European Commission adequacy decision (e.g. the EU-US Data Privacy Framework) or standard contractual clauses adopted by the Commission. You can get a copy of the safeguards by writing to me.
10. Your rights
- You have the right to access, rectify and erase your data, to restrict its processing and to data portability, and – where I rely on legitimate interest – to object on grounds relating to your particular situation.
- You may lodge a complaint with a supervisory authority – in Poland the President of the Personal Data Protection Office (UODO, ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl) – or with the authority in the EU country where you live or work.
- Providing data is voluntary, but without it I cannot answer your message or conclude and perform a contract; invoicing data is required by tax law.
11. Security
- I use encrypted connections (HTTPS), limit server access to myself over an authenticated connection, install security updates and keep backups. I never ask for passwords to Telegram, e-mail or banking.
12. Changes
- If the way I process data changes, I will update this policy and, if you are a client, tell you by e-mail. This policy is effective from 21 October 2026.