Effective date: 29 August 2026
This Privacy Policy explains how personal data are processed in connection with the website https://uttn.org and the activities of the Unified Trade & Technology Network (UTTN).
1. Data Controller
The controller of personal data is:
Aroks Group Sp. z o.o.
ul. Hugo Kołłątaja 3/15
20-006 Lublin, Poland
NIP: 8133842216
REGON: 386668701
For matters concerning personal data and privacy, please contact us at: system@uttn.org.
We have not appointed a Data Protection Officer. Questions concerning the processing of personal data may be sent directly to the address indicated above.
2. Scope of this Policy
This Policy applies to personal data processed in connection with:
- the use of the UTTN.org website;
- contact and enquiry forms;
- the “Submit a Request” form;
- applications to join or cooperate with the UTTN partner network;
- business, technology and project enquiries;
- research and verification of potential partners, experts and organisations;
- communication related to possible cooperation, introductions and projects;
- website analytics, security and, where consent has been given, marketing technologies.
3. Categories of Personal Data
Depending on the nature of your interaction with UTTN, we may process the following categories of personal data:
- Identification data: name, surname, position or professional role;
- Contact data: email address, telephone number and other contact details voluntarily provided by you;
- Business and professional data: company or organisation name, website, country, professional experience, expertise, project role and publicly available business information;
- Request and project data: information included in enquiries, project descriptions, business needs, technology requests, partnership requests and correspondence;
- Technical data: IP address, browser information, device information, server logs and online identifiers;
- Analytics and consent data: information about website interactions and choices made through the cookie consent mechanism, where applicable.
Please do not send confidential technical information, trade secrets, passwords, sensitive personal data or personal data of third parties through general website forms unless this is necessary and has been agreed with us in advance.
4. Sources of Personal Data
We may obtain personal data:
- directly from you through website forms, email, telephone calls, meetings or other correspondence;
- from a company, organisation or person acting on your behalf;
- from publicly available business sources, including company websites, public registers, professional directories and other publicly accessible professional information;
- from partners where this is necessary for a specific enquiry or cooperation process;
- automatically through the website, server logs and cookies or similar technologies.
Where personal data are obtained from sources other than directly from the data subject, we process them in accordance with Article 14 GDPR and applicable exemptions.
5. Purposes and Legal Bases for Processing
5.1. Handling enquiries and requests
We process data in order to analyse and respond to enquiries, understand the submitted need and determine whether UTTN or one of its partners may be able to assist.
Legal basis: Article 6(1)(f) GDPR, our legitimate interest in communicating with persons and organisations interested in UTTN activities, or Article 6(1)(b) GDPR where processing is necessary to take steps at your request before entering into an agreement.
5.2. Research, verification and partner search
Where you ask us to research a market, identify experts, verify potential partners or look for business, technology or project cooperation opportunities, we may process data necessary to perform such research and communicate its results.
Legal basis: Article 6(1)(b) GDPR where the activities are undertaken at your request in connection with potential cooperation, or Article 6(1)(f) GDPR, our legitimate interest in conducting business and professional research and developing cooperation opportunities.
5.3. Representation and introductions
Where agreed, UTTN may support initial communication with potential business partners, experts, research organisations, institutions or other relevant entities.
We do not disclose your contact details or non-public project information to a prospective partner without your prior agreement, unless such disclosure is necessary to take steps expressly requested by you.
Legal basis: Article 6(1)(b) GDPR or Article 6(1)(f) GDPR, depending on the circumstances.
5.4. Partner network
We process data of experts, companies and organisations interested in joining or cooperating with the UTTN network in order to assess their profile, maintain contact and identify possible future cooperation opportunities.
Legal basis: Article 6(1)(b) GDPR where steps are taken towards cooperation, and Article 6(1)(f) GDPR, our legitimate interest in developing and maintaining a professional partner network.
5.5. Website operation and security
Technical information and server logs may be processed to ensure the proper operation, stability and security of the website, prevent abuse and diagnose technical problems.
Legal basis: Article 6(1)(f) GDPR, our legitimate interest in ensuring the security and proper functioning of our IT systems.
5.6. Analytics
Where analytics tools requiring access to information stored on your device are used, they are activated only after obtaining the required consent through the cookie consent mechanism.
Legal basis for personal data processing: Article 6(1)(a) GDPR. Rules concerning storing or accessing information on terminal equipment are also governed by the applicable provisions of the Polish Electronic Communications Law.
5.7. Marketing technologies
If marketing pixels, remarketing tools or similar technologies are used on UTTN.org, they are activated only where the required consent has been given.
Legal basis: Article 6(1)(a) GDPR and applicable provisions of the Polish Electronic Communications Law.
5.8. Establishing, exercising or defending legal claims
Personal data may be processed where necessary to document cooperation, protect our rights, handle complaints or establish, exercise or defend legal claims.
Legal basis: Article 6(1)(f) GDPR.
5.9. Compliance with legal obligations
Where required by applicable law, we may process data to comply with accounting, tax, regulatory or other legal obligations.
Legal basis: Article 6(1)(c) GDPR.
6. Is Providing Personal Data Mandatory?
Providing personal data through UTTN.org is generally voluntary.
However, certain information may be necessary for us to respond to an enquiry, evaluate a request, contact you or take steps towards cooperation. If the required information is not provided, we may be unable to process the request.
Consent to analytics or marketing cookies is voluntary and is not required to use the basic functions of the website.
7. Recipients of Personal Data
Personal data may be disclosed, where necessary, to:
- hosting, IT, website maintenance and cybersecurity providers;
- CRM, communication and workflow automation providers;
- email and cloud service providers;
- analytics and marketing technology providers, where the relevant consent has been given;
- professional advisers, including legal, accounting or tax advisers;
- UTTN partners, experts or potential project participants, but only where this is justified by the purpose of the enquiry and, where appropriate, agreed with you;
- public authorities where disclosure is required by law.
Where another entity processes personal data on our behalf as a processor, we use providers offering appropriate safeguards and conclude data processing arrangements where required by Article 28 GDPR.
8. Sharing Data with Potential Partners
One of UTTN’s functions is to research and facilitate possible cooperation between companies, experts, technology teams and organisations.
We may prepare anonymised or non-identifying summaries of a business or project request for the purpose of identifying potentially interested partners.
Contact details and non-public information identifying you or your project will normally be disclosed to a potential partner only after you have agreed to such an introduction or where disclosure is necessary to perform an action expressly requested by you.
9. Transfers Outside the European Economic Area
Some technology providers used by the website may process personal data outside the European Economic Area.
Where such transfers occur, they are carried out in accordance with Chapter V GDPR, in particular on the basis of:
- an adequacy decision adopted by the European Commission;
- the EU-US Data Privacy Framework, where applicable to the relevant provider;
- Standard Contractual Clauses approved by the European Commission;
- other safeguards permitted by GDPR.
10. Data Retention
We retain personal data only for as long as necessary for the purpose for which they were collected.
- General enquiries: for the duration of the correspondence and normally for up to 12 months after the last meaningful contact, unless longer retention is justified;
- Project and cooperation enquiries: for the duration of the assessment or cooperation process and afterwards where necessary for follow-up, documentation or legal claims;
- Partner applications and professional profiles: for as long as cooperation remains potentially relevant, with periodic review of whether the data are still necessary;
- Contractual and accounting data: for the periods required by applicable accounting and tax law;
- Server and security logs: for the period necessary to ensure security and investigate incidents;
- Analytics and marketing data: until consent is withdrawn or until the relevant cookie or identifier expires, whichever occurs earlier where applicable;
- Data necessary for legal claims: until the relevant limitation periods expire.
11. Your Rights
Subject to the conditions provided by GDPR, you have the right to:
- access your personal data;
- request rectification of inaccurate personal data;
- request erasure of personal data;
- request restriction of processing;
- object to processing based on legitimate interests;
- receive personal data in a portable format where the right to data portability applies;
- withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal;
- lodge a complaint with a supervisory authority.
In Poland, the competent supervisory authority is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych).
12. Automated Decision-Making and Profiling
UTTN does not use personal data to make decisions based solely on automated processing that produce legal effects or similarly significantly affect you within the meaning of Article 22 GDPR.
If analytics or advertising platforms are enabled with your consent, those providers may use profiling mechanisms for analytics, audience measurement or advertising purposes in accordance with their own privacy policies.
13. Cookies and Similar Technologies
UTTN.org uses technologies necessary for the proper operation and security of the website. Other technologies, including analytics or marketing cookies, are used only where the required consent has been obtained.
You may change or withdraw your consent through the website’s cookie settings.
Detailed information about the cookies used, their purposes, providers and storage periods is available in our Cookie Policy.
14. Data Security
We apply technical and organisational measures appropriate to the nature and risks of the processing in order to protect personal data against unauthorised access, loss, alteration, disclosure or destruction.
Access to personal data is limited to persons and entities that need such access for legitimate purposes.
15. Changes to this Privacy Policy
We may update this Privacy Policy when our services, technologies, partners or legal requirements change.
The current version is always published on UTTN.org together with its effective date.
16. Contact
For questions concerning privacy or the exercise of your data protection rights, please contact:
Aroks Group Sp. z o.o.
ul. Hugo Kołłątaja 3/15
20-006 Lublin, Poland
Email: system@uttn.org