Privacy Policy

1. Personal data controller

The controller of personal data processed in connection with use of the energytrend.pl website is:

ENERGY TREND Sp. z o.o.
Wojciechów-Kolonia Pierwsza 31A
24-204 Wojciechów-Kolonia Pierwsza, Poland
KRS: 0000865011
NIP: 7133110197
REGON: 387294272

Hereinafter referred to as the “Controller”, “Energy Trend” or “we”.

2. Contact regarding data protection

The Controller has not appointed a Data Protection Officer.

For matters concerning personal data, the exercise of rights under the GDPR or withdrawal of consent, please contact us at:
rodo@energytrend.pl.

3. Scope of this policy

This policy covers the processing of personal data in connection with use of the energytrend.pl website. The forms and contact channels available on the website are intended to initiate business enquiries to Energy Trend about our services, quotations, proposals and potential cooperation.

In particular, this policy covers the processing of data in connection with:

• submitting a business enquiry or requesting a proposal, quotation, consultation or contact about a specific service,
• using forms relating to individual Energy Trend services,
• providing documents and attachments required to assess an enquiry or prepare a proposal,
• contact initiated by a user through a form, email, telephone or WhatsApp, if this channel becomes available,
• Energy Trend responding to a submitted enquiry, including preparing and presenting a commercial proposal,
• using cookies and similar technologies,
• measuring website traffic, conversions and advertising effectiveness,
• giving separate consent to further marketing after a specific enquiry has been handled.

This policy does not comprehensively describe the processing of data when performing contracts concluded with customers. Additional information, contractual provisions or separate privacy notices may apply in such cases.

4. Where we obtain data

We may obtain data from:

• individuals using the website, forms, email, telephone or WhatsApp directly,
• documents submitted by users, such as invoices, contracts, proposals, floor plans, technical documentation or energy consumption reports,
• individuals contacting us on behalf of a company, institution, housing community, cooperative or another organisation,
• devices, web browsers, server logs, cookies and similar technologies,
• campaign parameters and website traffic sources.

5. What data we may process

5.1. Identification and contact details

Depending on the form or contact method, we may process, among other things:

• first and last name,
• name of the company, institution or organisation,
• job title or professional role, if provided,
• email address,
• telephone number,
• address or location of a facility, where needed to handle the enquiry.

5.2. Information about the enquiry and planned service

The scope of data depends on the service concerned. We may process information about, among other things:

• the type of service or area of support,
• the type, function, floor area and number of buildings or facilities,
• the availability of technical documentation,
• the purpose of an audit, report or planned investment,
• the type of planned upgrade and the project’s stage of preparation,
• consumption of electricity, gas, heat, fuels or other utilities,
• the number of electricity supply points (PPE), metering points or locations,
• the expiry date of the current electricity or gas contract,
• the electricity or gas procurement model,
• existing proposals, contracts, invoices or terms agreed with the supplier,
• installations, equipment, processes and technical parameters,
• information needed to carry out an audit, prepare a quotation, assess project eligibility or determine the appropriate service scope,
• message content, a description of the situation and additional information voluntarily supplied by the user.

5.3. Attachments and documentation

Forms may allow users to submit, among other things:

• invoices for electricity, gas or other utilities,
• contracts with electricity or gas suppliers,
• commercial proposals,
• energy consumption reports,
• technical documentation,
• drawings, plans and diagrams,
• photographs of facilities or installations,
• previous audits, certificates or other reports,
• other supporting files relating to the enquiry.

Please do not provide data that is not needed to deal with your enquiry, particularly special categories of personal data referred to in Article 9 of the GDPR, unless their disclosure has been agreed in advance and is necessary due to the particular nature of the matter.

If a document contains another person’s data, the person submitting it should have an appropriate legal basis for disclosure and limit the data to what is necessary.

5.4. Technical data and website usage information

Depending on the website configuration and consents given, we may process, among other things:

• IP address,
• connection date and time,
• device, operating system and browser information,
• cookie and similar technology identifiers,
• approximate location derived from an IP address,
• referring website address,
• traffic source, campaign and advertising parameters,
• pages visited and interactions with their elements,
• starting and submitting a form,
• clicking a telephone number or email address,
• adding an attachment,
• form category, service type and the page from which an enquiry was sent,
• information on consents given or withdrawn,
• data recorded in security and server logs.

6. Purposes and legal bases of processing

6.1. Handling business enquiries, sales contact and preparing proposals

The forms and contact details on the website are provided so that users can enquire about Energy Trend services. If a user submits a form or email, provides a telephone number or otherwise contacts us about a proposal, quotation or cooperation, we process their data in order to:

• receive and assess the business enquiry,
• identify the appropriate service and scope of potential cooperation,
• respond to the enquiry by email or telephone,
• obtain further information needed to prepare a proposal,
• prepare and present a proposed scope of work, quotation or commercial offer,
• continue discussions concerning that specific enquiry until it is closed or a contract is concluded.

The legal basis is:

• Article 6(1)(b) GDPR – where processing is necessary to take steps at the request of the data subject before entering into a contract,
• Article 6(1)(f) GDPR – where an individual contacts us on behalf of a company, institution or other organisation, or where processing is necessary for business communication, handling an enquiry and preparing a proposal for the organisation represented.

We do not require separate consent to process personal data in order to respond to a business enquiry submitted by a user, prepare a proposal or communicate about that specific enquiry.

Providing a telephone number in a form is generally voluntary. If a user provides their number to receive contact about an enquiry, we may use it to discuss that enquiry, prepare a proposal and make related arrangements.

6.2. Handling correspondence and recording arrangements

We may process data to conduct correspondence, retain contact history and document information exchanged. The legal basis is Article 6(1)(f) GDPR – the Controller’s legitimate interest in efficient communication and being able to demonstrate the course of discussions and arrangements.

6.3. Reviewing documents supplied by users

We process documents and attachments only to the extent needed to assess an enquiry, prepare a proposal or take steps requested by the user from Energy Trend. The legal basis, as applicable, is Article 6(1)(b) or (f) GDPR.

6.4. Disclosing data to an electricity or gas supplier or a partner

If justified by the enquiry and the agreed scope of work, data may be disclosed to a selected electricity or gas supplier, technical partner, subcontractor, suitably qualified professional or another entity involved in preparing or delivering the service.

We disclose only data required for the relevant purpose. The legal basis may be Article 6(1)(b) GDPR or Article 6(1)(f) GDPR. If a particular disclosure requires separate consent, we will obtain it before sharing the data.

The recipient may act as a processor on behalf of Energy Trend or as an independent data controller. In the latter case, the recipient applies its own data protection rules.

6.5. Further marketing after a specific enquiry has been handled

Contact in response to a user’s enquiry, including providing a proposal and continuing discussions about that enquiry, is described in section 6.1 and does not require separate marketing consent.

Separate consent may, however, be required if, after handling a particular enquiry, we wish to contact the person for other marketing purposes, for example to provide information about other Energy Trend services, new offers, expert materials or regulatory changes, or to make another commercial proposal not directly related to the original enquiry.

If a user gives such separate and voluntary consent, we may use their contact details for further marketing through the channels indicated, such as email, telephone or WhatsApp.

In this case, the legal basis for processing personal data is Article 6(1)(a) GDPR. The use of telecommunications terminal equipment to send commercial information, including direct marketing, requires prior consent under Article 398 of Poland’s Electronic Communications Law.

Consent to further marketing is voluntary, is not a condition of submitting an enquiry, receiving a response or having a proposal prepared, and may be withdrawn at any time.

6.6. Analytics and statistics

With appropriate consent, we may use analytics tools to analyse traffic, measure interactions with forms, assess traffic sources and improve the website. The legal basis for processing personal data is Article 6(1)(a) GDPR; storing or accessing information on a user’s device is governed by Article 399 of Poland’s Electronic Communications Law.

6.7. Advertising, remarketing and conversion tracking

With appropriate consent, we may use advertising tools to track conversions, assess campaign performance, build audiences, conduct remarketing, personalise ads and, if implemented, enable features such as enhanced conversion measurement.

The legal basis for processing personal data is Article 6(1)(a) GDPR. Storing or accessing information on a user’s device is governed by Article 399 of Poland’s Electronic Communications Law.

If we implement features using data provided by the user, such as enhanced conversions or audience lists built from contact details, they will only be used after the relevant consent and tool-configuration requirements have been met.

6.8. Website security and preventing misuse

We may process technical data to protect the website and its forms against spam, bots, attacks, unauthorised access and other misuse. The legal basis for processing personal data is Article 6(1)(f) GDPR – the Controller’s legitimate interest in safeguarding the website, data and infrastructure.

If a security technology stores or accesses information on the user’s device in a way that does not fall within the exemption for technologies necessary to provide a requested service, it will only be activated after the required consent has been obtained.

6.9. Establishing, exercising or defending legal claims

Data may be processed to establish, exercise or defend claims related to use of the website, correspondence or documents supplied. The legal basis is Article 6(1)(f) GDPR.

7. Is providing data mandatory?

Providing data is voluntary, but some information is needed for us to assess a business enquiry, contact the user and prepare an appropriate proposal. Required fields are marked with an asterisk in the form.

In particular:

• an email address is required in forms where it is the primary channel for responding to an enquiry,
• a telephone number is generally optional; providing one means that we may use it to contact the user about the submitted enquiry and the proposal being prepared,
• qualifying information, such as the type of facility, purpose of the audit, number of buildings, type of service or utility, may be required where the enquiry cannot be properly assessed or a proposal prepared without it,
• submitting documents and attachments is generally optional, but they may be needed at a later stage of analysis or quotation preparation.

Without information required by a particular form, we may be unable to respond or prepare a proposal.

Separate consent to further marketing after a specific enquiry has been handled is always optional and does not affect the ability to submit a form, discuss an enquiry or receive a proposal.

8. Recipients of personal data

Data may be made available to:

• authorised Energy Trend employees and associates,
• Zenbox – for website and email hosting, server infrastructure and backups,
• Cloudflare – for website protection, traffic filtering, security and content delivery,
• Google – in connection with Google Analytics 4, Google Tag Manager, Google Ads and Google reCAPTCHA, depending on website configuration and consents given,
• providers of CRM systems, virtual drives, cloud services, backups and work-management tools, if implemented,
• IT support, website administration, cybersecurity and technical-support providers,
• Meta / WhatsApp – if a WhatsApp widget or contact channel is introduced,
• electricity or gas suppliers where disclosure is necessary to deliver the requested service or obtain proposals,
• technical partners, subcontractors, auditors and specialists involved in delivering a specific scope of work,
• entities entitled to receive data under applicable law.

Processors acting on our behalf may use the data only to the extent permitted by their agreement, the Controller’s instructions and applicable law.

9. Transfers of data outside the European Economic Area

Some providers of the technologies we use, particularly Google, Cloudflare, Meta or WhatsApp, may process data outside the European Economic Area.

Depending on the provider and processing location, such transfers may rely on a European Commission adequacy decision, including the EU–US Data Privacy Framework, standard contractual clauses approved by the European Commission or another mechanism permitted under the GDPR.

10. Data retention periods

We retain data only for as long as necessary for the purpose for which it was collected. Retention periods are determined according to the following criteria:

• enquiries and correspondence – for the time needed to handle the matter, prepare a proposal and conduct reasonably justified follow-up discussions, and then, where necessary, for the period required to establish, exercise or defend claims,
• documents and attachments – for the time needed to assess the enquiry, prepare a proposal and deliver the agreed scope; if no further cooperation takes place and there is no other basis for retention, documents should be deleted when no longer needed,
• marketing data – until consent is withdrawn, an objection is raised or marketing activities through the channel concerned end,
• consent records – for the period needed to demonstrate that consent was validly given or withdrawn,
• logs and security data – for the period dictated by security needs, system configuration and infrastructure providers’ policies, or longer in the event of an incident or where irregularities need to be investigated,
• cookies and similar technologies – in accordance with the lifespan of individual cookies and the settings described in the Cookie Policy.

The same principles apply to copies of data held in email, CRM systems, virtual drives, work computers and backups, taking account of backup overwrite cycles.

11. Rights of data subjects

Depending on the legal basis and circumstances of processing, you may have the right to:

• access your data and obtain a copy,
• rectify your data,
• erase your data,
• restrict processing,
• data portability, where the GDPR requirements are met,
• object to processing based on Article 6(1)(f) GDPR,
• object to direct marketing at any time,
• withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before its withdrawal,
• lodge a complaint with the President of Poland’s Personal Data Protection Office (UODO).

Requests concerning personal data can be sent to rodo@energytrend.pl.

Before acting on a request, we may ask for information to verify the identity of the person making it.

12. Automated decision-making and profiling

We do not make decisions about users that produce legal effects or similarly significantly affect them solely on the basis of automated processing.

We may, however, categorise business enquiries by service type, facility, project size, investment stage or information provided; route forms to the appropriate person or team; analyse the source of an enquiry and the advertising campaign; and, with appropriate consent, create advertising audiences and conduct remarketing.

13. Cookies and similar technologies

13.1. Categories of technologies

The website may use:

• essential – required for website operation, security, forms and remembering consent preferences,
• statistical / analytical – used to measure traffic and how the website is used,
• marketing – used for advertising measurement, remarketing, audience creation and ad personalisation,
• functional – enabling additional non-essential features.

13.2. Managing consent

The Complianz tool may be used to manage cookie preferences.

On their first visit, users may accept optional technologies, reject them or select individual categories. Essential technologies remain active only insofar as necessary for the website to function correctly or to provide a feature requested by the user.

Consent to optional technologies can be changed or withdrawn at any time using the consent-management mechanism available on the website.

13.3. Detailed list of cookies

A detailed list of the cookies used, their providers, purposes and retention periods is available in the document
Cookie Policy.

14. Google Analytics 4 and Google Tag Manager

The website may use Google Analytics 4 to analyse traffic and user behaviour and Google Tag Manager to manage tags and scripts used on the website.

Google Analytics may process information about devices, browsers, traffic sources, website interactions, events and approximate location. The tools’ operation depends on the website configuration and users’ cookie preferences.

15. Google Ads

The website may use Google Ads to run advertising campaigns, measure conversions, assess ad effectiveness, conduct remarketing, create audiences and personalise ads.

If features such as enhanced conversions or the use of user-supplied data for measurement or audience creation are introduced, they will only be used after the relevant consent and configuration requirements have been met. Users’ preferences may be passed to Google tools through Google Consent Mode.

16. Cloudflare

The website uses Cloudflare services to support security, protection against attacks, traffic filtering, abuse prevention, availability and content delivery.

Cloudflare may process technical data such as IP addresses, device and browser information, request dates and times, and information needed to assess connection security. Energy Trend’s legal basis for processing personal data is Article 6(1)(f) GDPR.

17. Google reCAPTCHA

Forms may be protected by Google reCAPTCHA, which helps prevent spam, bots and automated misuse.

reCAPTCHA may analyse technical information about devices, browsers, IP addresses and how users interact with the website. Energy Trend’s legal basis for processing personal data is Article 6(1)(f) GDPR – its legitimate interest in protecting the website and forms.

If the reCAPTCHA configuration involves storing or accessing information on users’ devices in a way that requires consent under Poland’s Electronic Communications Law, the service should be activated in accordance with users’ cookie preferences.

18. WhatsApp

If a widget or button enabling contact via WhatsApp is introduced on the website, using it may result in the processing of a telephone number, profile name or identifier, message content, files sent, contact date and time, and technical data related to the widget or app.

Energy Trend will process this data to handle the conversation and enquiry. At the same time, the WhatsApp provider or Meta group companies may process the data under their own policies.

If the WhatsApp widget uses non-essential scripts, cookies or similar technologies while the page is being displayed, it should load only after appropriate consent has been obtained or the user has knowingly activated it.

Contacting us through WhatsApp does not constitute consent to subsequent marketing. Marketing messages will be sent only after appropriate consent has been obtained.

19. Links to external websites

The website may contain ordinary links to external websites, maps, social media platforms, videos or other services. Simply including a link does not automatically transfer data to an external website. An external provider may process data after a user clicks a link and visits its website or app.

If external widgets, maps, videos or feeds that connect to third-party servers as soon as a page loads are embedded in the future, the consent mechanism and this policy will be updated accordingly.

20. Data security

We apply appropriate technical and organisational measures to protect data against unauthorised access, accidental loss, alteration, destruction or disclosure to unauthorised persons. Data is accessible to those who need it to fulfil their duties or deliver agreed services.

Please note that transmitting data over the internet or by email is not entirely risk-free. Users should limit the data they submit to the information genuinely needed to prepare a response or provide a service.

21. Changes to this policy

This policy may be updated, particularly following changes in legislation, how forms operate, the providers we use, the introduction of new analytics or advertising tools, a CRM system, WhatsApp, a newsletter or other features involving personal data processing.

The current version of the policy is published on energytrend.pl together with its effective date.