1. Controller and contact details
The controller of personal data is Vadym Rekel, trading as VADYM REKEL, tax identification number (NIP) 6793053128, business register number (REGON) 121398530, sworn translator of Ukrainian, registration number TP/27/17. Address: ul. Kielecka 2/53, 31-526 Kraków, Poland. For personal data matters, write to or the office address; telephone +48 883 040 483 and +48 735 753 383.
This notice concerns the public website at vadymrekel.pro and contact with the office. The private Repertorium is a separate panel requiring login. The public website contains only a link and does not disclose repertory entries or client data.
2. What data we receive and where it comes from
Data provided directly by a client may include their name, organisation name, contact details, billing details, organisational information, and documents and correspondence needed to prepare a quotation and perform the service.
A document may contain data about other people, such as parties to proceedings, witnesses, representatives or people named in a certificate. This data comes from material received from the client, an authorised person or the competent authority. Its scope depends on the particular document and may include identification, professional, financial, family, health or proceedings-related data.
When you visit the website, the hosting infrastructure receives technical data such as your IP address, the time of the request, the resource address, browser parameters and error information. This does not mean that text entered in the local form or calculator is transmitted.
Please provide only material needed to define or carry out the commission. Documents containing particularly sensitive data should be sent through an agreed channel, rather than entered in the general enquiry description.
3. Purposes and legal bases for processing
Handling an enquiry from a client who is a natural person, preparing a quotation and performing a contract: Article 6(1)(b) GDPR. Contact with an organisation's representative, correspondence and organisational arrangements: Article 6(1)(f) GDPR — the legitimate interest in efficient communication and handling the commission.
Fulfilling the translator's legal obligations, including maintaining the repertory and duties relating to certification, as well as tax and accounting obligations: Article 6(1)(c) GDPR in conjunction with the applicable legislation, in particular the Act on the Profession of Sworn Translator.
Establishing, exercising or defending legal claims, preventing abuse and ensuring website security: Article 6(1)(f) GDPR — protecting the rights and security of the controller and people using the services. For third-party data in documents, the legal basis and necessary scope of processing are assessed separately. A contract with the person commissioning the service does not automatically provide a basis under Article 6(1)(b) for processing the data of everyone named in the material.
Special categories of data require an additional condition under Article 9(2) GDPR, for example necessity for establishing, exercising or defending legal claims or, where appropriate, the data subject's explicit consent or another applicable statutory basis. Data relating to criminal convictions, offences or related security measures is subject to the separate requirements of Article 10 GDPR: processing must be under the control of official authority or authorised by Union or national law providing appropriate safeguards. The lawfulness and necessary scope of processing are assessed for the particular activity before the material is accepted. A contract alone, or general consent to processing personal data, does not replace these requirements.
Consent is relied upon only where it is required and has actually been given, for example when enabling the optional map. Marketing consent is not a condition for obtaining a quotation. The form is not a newsletter sign-up form. Merely displaying the contact window does not trigger profiling or send data to an advertising system.
4. The form, calculator, contact window and map
The form creates a draft locally. The office does not receive the information entered unless you send the message yourself through your email service. Opening your email application passes the recipient's address, subject and, where applicable, message body to that application. Copying places the text on your device's clipboard. Once sent, the correspondence and attachments are processed to handle the enquiry or commission.
The calculator performs its calculations in your browser. It does not send text off your device, save content in the office's database or decide whether a commission will be accepted or what its binding price will be.
The public website's code does not run advertising analytics, marketing pixels or cookies for measuring behaviour. The form, calculator and contact window use only the current page's memory; they do not save their data in localStorage or sessionStorage. Clipboard contents and a draft in an external email application are governed by those applications' features and are not cleared by closing the website.
The Google map is optional and remains disabled until you deliberately click the button after reading the information beside it. Enabling it establishes a connection to Google, discloses information including your IP address and browser data, and may involve Google's cookies or similar technologies. You can hide the map, which removes the embed from the page. Data already received by Google and its cookie settings are governed by Google's policies and your browser settings. The office address is also available without using the map.
Links to maps, LinkedIn and Repertorium open separate services. Embedded LinkedIn widgets and Repertorium content are not loaded during ordinary browsing. If you follow a link to an external service, its privacy information also applies.
5. Recipients and processing outside the EEA
To the extent necessary, data may be received by hosting and security providers, email and IT support providers, billing and payment service providers, postal or courier operators where delivery has been agreed, and authorities entitled to receive it under the law. The scope of access depends on the task performed and the applicable legal basis. This does not mean that every such recipient receives the full contents of documents.
The public domain vadymrekel.pro uses Vercel infrastructure. The optional map is provided by Google. These providers use international infrastructure, so processing may take place in countries outside the European Economic Area, including the USA. Transfers of data outside the EEA must meet the conditions of Chapter V GDPR. The basis may be an adequacy decision, if it covers the specific recipient and transfer, or appropriate safeguards, such as standard contractual clauses together with supplementary measures where necessary.
For details of recipients, the applicable transfer mechanism and how to obtain a copy of the safeguards, please contact the controller. Links to the providers' information are included at the end of this page. Enabling the map is optional; the office's other features can be used without it.
6. How long we retain data
Data collected by a sworn translator in connection with translation is retained for four years from the end of the calendar year in which it was collected, in accordance with Article 29c of the Act on the Profession of Sworn Translator. After that period, the data must be deleted unless further retention is necessary to protect rights or pursue claims.
Tax and accounting records are subject to the applicable statutory obligations. Tax books and related documents are generally retained until the tax liability becomes time-barred, usually for five years from the end of the year in which the tax payment deadline fell. Suspension or interruption of the limitation period may affect how long the records are retained. This does not mean that all source materials are automatically kept for five years.
Other correspondence unrelated to a translation or statutory obligation is retained for as long as needed to deal with the matter, and thereafter only to the extent and for the period necessary to protect rights or pursue claims. Retention of technical data depends on the purpose of the log, the type of event and the need to maintain the website's operation and security. Further retention after that purpose has ended requires a separate basis.
Where processing is based on consent, withdrawing it ends processing for that purpose unless there is another independent basis for continued processing. The statutory repertory and mandatory records are not deleted merely because consent has been withdrawn.
7. Your rights and the rules specific to sworn translators
Within the limits set by law, you may request access to your data, rectification, erasure or restriction of processing, and data portability where the statutory conditions are met. You have the right to object to processing based on legitimate interests, subject to the specific exception described below. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
Under Article 29a(1) of the Act on the Profession of Sworn Translator, Article 15(1) and (3), Article 18 and Article 19 GDPR apply to the extent that they do not breach the duty of professional secrecy. In addition, under Article 29a(2), the right to object under Article 21(1) GDPR does not apply to data obtained by the translator in connection with translation. This is not a general exclusion of data protection. Each request is assessed within the scope provided by law. A statutory retention obligation may restrict the possibility of erasing data.
You may lodge a complaint with the President of the Polish Personal Data Protection Office (UODO). Current submission methods and the address for complaints are available at uodo.gov.pl. You can submit a request to the office using the details in section 1. A reply is provided without undue delay, normally within one month. Where justified by the complexity or number of requests, this period may be extended by a further two months. Notice of the extension and its reasons is provided within the first month. If there are reasonable doubts, the controller may request information necessary to confirm your identity.
8. Voluntary provision, indirect sources and security
Providing data for an enquiry is voluntary. However, without information necessary to contact you, define the scope or perform the contract, it may not be possible to reply or provide the service. Some data is required by the rules on certification, the repertory or billing.
Article 14 GDPR applies to data received from another person, subject to the exceptions it provides. In particular, Article 14(5)(d) may apply where the data must remain confidential under a statutory obligation of professional secrecy. This does not exclude the obligation to provide the appropriate information to a person from whom the office collects data directly. We do not impose a general obligation on clients to obtain consent from everyone named in the material where processing has another appropriate legal basis.
Information obtained in connection with translation remains covered by professional secrecy after the service has ended. Under Article 29b of the Act on the Profession of Sworn Translator, this obligation does not cease when the President of UODO requests disclosure. Access, transfer and storage arrangements use measures appropriate to the risk. The public form is not intended for submitting case files; please agree file-transfer arrangements directly with the office.
The public website does not make automated decisions that produce legal effects or similarly significantly affect a person, nor does it carry out profiling for such decisions. The information about the local calculator describes how that calculator works, rather than every tool that might be used for an individual commission. A material change in processing arrangements requires the information to be updated accordingly.