Legal

Privacy Policy

Last updated: 4 November 2026 · Version 2.0 · Controller: UTUBEO sp. z o.o.

On this page
1. Who we are2. What this policy covers3. What data we process, why, and on what legal basis4. When we work on your accounts (client services)5. Use of AI tools6. Cookies and similar technologies7. Who receives your data8. Transfers outside the European Economic Area9. Your rights10. Profiling and automated decisions11. How we protect your data12. Do you have to give us your data?13. Children14. Changes to this policy

1. Who we are

This Privacy Policy explains how we handle personal data when you visit www.utubeo.com, contact us, book a call, buy a digital product or work with us. The controller of your personal data is UTUBEO spółka z ograniczoną odpowiedzialnością (UTUBEO sp. z o.o.), ul. Towarowa 20-B, 10-417 Olsztyn, Poland, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court in Olsztyn, VIII Commercial Division of the National Court Register, under KRS number 0000830285, NIP (tax ID / VAT EU) PL7393937798, REGON 385598625 (“Utubeo”, “we”, “us”).

You can reach us about anything related to your data at hello@utubeo.com or by post at the address above. We have not appointed a Data Protection Officer, because the law does not require it for a business of our size and type. Your messages go directly to the management board.

We apply Regulation (EU) 2016/679 (the General Data Protection Regulation, “GDPR”), the Polish Act of 10 May 2018 on the protection of personal data, the Polish Electronic Communications Law of 12 July 2024 (in particular Articles 398–400 on cookies and direct marketing), the Polish Act of 18 July 2002 on providing services by electronic means, and Regulation (EU) 2024/1689 (the AI Act) where it concerns our use of AI tools.

2. What this policy covers

This policy covers personal data we process:

  • when you browse our website;
  • when you send us a message through a form, by email or through Upwork;
  • when you book a call or buy a digital product (for example through our Stan Store page);
  • when you or your company become our client, and when we act on accounts you give us access to;
  • when we contact business representatives about our services;
  • when you interact with our profiles on YouTube, LinkedIn, Facebook, Instagram, Pinterest or Upwork.

Other websites we link to, and the platforms we use to sell or deliver services (such as Upwork, Stan Store or Stripe), have their own privacy policies. Where those companies decide on their own how to use your data, they are separate controllers.

3. What data we process, why, and on what legal basis

The table below lists each situation, the data involved, our purpose and legal basis, and how long we keep the data.

SituationDataPurpose and legal basisHow long we keep it
Contact form, email, Upwork messageName, email, company, website, the content of your message, any other details you choose to giveTo reply and to take steps you ask for before signing a contract (Art. 6(1)(b) GDPR). For messages from company representatives, our legitimate interest in business communication (Art. 6(1)(f) GDPR).Until your enquiry is handled, then up to 2 years for follow-up and record keeping, unless you object earlier or we sign a contract.
Booking a callName, email, chosen date and time, notes you add, call detailsTo arrange and hold the call (Art. 6(1)(b) GDPR).Up to 2 years after the call, or longer if a contract follows.
Buying a digital productName, email, billing details, tax ID if you buy as a company, order and payment status (we never see your full card number)To conclude and perform the contract and deliver the product (Art. 6(1)(b) GDPR); to issue invoices and keep accounting records (Art. 6(1)(c) GDPR); to handle complaints and claims (Art. 6(1)(f) GDPR).For the duration of the contract, then until claims expire (in most cases 6 years, or 3 years for business claims, counted to the end of the calendar year). Accounting records: 5 years from the end of the year in which the tax payment deadline passed.
Working with us as a clientContact details of your representatives, contract and billing data, project communication, materials and account access you provideTo perform the contract (Art. 6(1)(b) GDPR) or, for representatives of a company, our legitimate interest in performing the contract with that company (Art. 6(1)(f) GDPR); accounting and tax duties (Art. 6(1)(c) GDPR).For the duration of cooperation, then as for claims and accounting records above.
Newsletter and free resourcesEmail, name if given, which emails you open and clickTo send you the resource and our emails with tips and offers, only with your consent (Art. 6(1)(a) GDPR and Art. 398 of the Electronic Communications Law).Until you unsubscribe or withdraw consent. After that we keep a minimal record that you opted out, so we do not write to you again.
Contacting business representatives (prospecting)Name, job title, company, business email or profile, publicly available information about the companyTo introduce our services to companies that may need them – our legitimate interest (Art. 6(1)(f) GDPR). We send commercial information by email only where the law allows it.Up to 12 months after the last contact, unless you become a client. If you object, we keep only what is needed to respect your objection.
Website analytics and advertisingCookie identifiers, device and browser data, pages viewed, clicks, approximate location, ad interactionsTo measure how the website works and how our ads perform, and to show our ads to relevant people – only with your consent (Art. 6(1)(a) GDPR and Art. 399 of the Electronic Communications Law). See section 6.Until you withdraw consent, and no longer than the lifetime of each cookie listed in section 6 and the retention settings of each tool.
Security and website operationIP address, request data, technical logsTo keep the website available and secure and to block abuse – our legitimate interest (Art. 6(1)(f) GDPR).Usually up to 30 days, longer only when a log is needed to investigate an incident.
Our social media profilesYour public profile name, comments, messages and reactionsTo run our profiles and reply to you – our legitimate interest (Art. 6(1)(f) GDPR). For Facebook and Instagram page statistics we are joint controllers with Meta Platforms Ireland Ltd.As long as the content stays on the platform, or until you object.
Claims, complaints and legal requestsData needed for the specific caseTo establish, pursue or defend claims and to answer authorities (Art. 6(1)(c) and (f) GDPR).Until the case and any limitation period end.

Where we rely on our legitimate interest, you can object at any time (see section 9). Where we rely on your consent, you can withdraw it at any time. Withdrawal does not affect what we did lawfully before.

4. When we work on your accounts (client services)

To deliver our services, clients often give us access to their YouTube channels, Google Ads, Meta Business, analytics, CRM or similar accounts. These accounts can contain personal data of the client’s own customers, leads, viewers or audiences.

For that data we act as a processor on behalf of the client, under Article 28 GDPR. We use it only to deliver the agreed service, on the client’s instructions, and we do not use it for our own purposes. The data processing terms are part of our Terms of Use (section “Personal data and processing for clients”) unless we sign a separate data processing agreement.

We ask for access through user roles and permissions, not shared passwords, wherever the platform allows it. When a project ends, we remove our access or ask the client to remove it.

5. Use of AI tools

We use AI tools in our work, for example to help with research, analysis of performance data, drafting reports and scripts, and producing or editing images, audio and video. This is how we handle that:

  • Only Utubeo has access to our AI tools and accounts. No third party can see what we enter.
  • We give AI tools only the data needed for the task. Where possible we use aggregated or anonymised data instead of personal data.
  • Where the tool offers it, we use business or API settings under which the provider does not use our inputs to train its models.
  • The providers of these tools act as our processors or service providers. Some are based outside the EEA; section 8 explains how such transfers are protected.
  • A person at Utubeo reviews every result before we use it or send it to you. We do not make decisions about you based solely on automated processing.
  • If we ever let you talk to an AI system on our behalf (for example a chat assistant), we will tell you clearly that you are dealing with AI, as required by Article 50 of the AI Act.
  • When we publish images, audio or video that were generated or substantially changed with AI and could be mistaken for real, we label them as such, in line with the AI Act and platform rules (such as YouTube’s altered or synthetic content disclosure).

6. Cookies and similar technologies

Cookies are small files stored on your device. Similar technologies include pixels, tags and local storage. We use only strictly necessary ones by default. Analytics and marketing tools load only after you agree.

When you first visit, a banner lets you accept all, reject all, or choose categories. You can change or withdraw your choice at any time with the Cookie settings button at the bottom of every page. Rejecting is as easy as accepting, and the website works either way. We pass your choice to Google tags through Google Consent Mode. We keep your choice for up to 12 months and then ask again.

CategoryTool and providerWhat it doesMain cookies and lifetime
Strictly necessary (no consent needed)UtubeoRemembers your cookie choiceub_consent (local storage), 12 months
Strictly necessaryCloudflare, Inc.Delivers the website and protects it against bots and attacksSecurity cookies such as __cf_bm, up to 30 minutes
Strictly necessaryCloudflare Web AnalyticsCounts visits in aggregate, without cookies and without identifying youNo cookies
Strictly necessaryZoho (Bigin form)Runs the contact form when you open itTechnical cookies set by the form, session
Analytics (consent)Google Analytics 4 – Google Ireland LtdShows how visitors use the website_ga, _ga_* – up to 2 years
Analytics (consent)Microsoft Clarity – Microsoft Ireland Operations LtdHeatmaps and session recordings of clicks and scrolling; text typed into forms is masked_clck – 1 year, _clsk – 1 day, CLID – 1 year
Marketing (consent)Google Ads and Google Tag Manager – Google Ireland LtdMeasures ad conversions and builds remarketing audiences_gcl_au – 90 days, IDE / test_cookie (doubleclick.net) – up to 13 months
Marketing (consent)Meta Pixel and Conversions API – Meta Platforms Ireland LtdMeasures Facebook and Instagram ads and builds audiences_fbp – 90 days
Marketing (consent)Pinterest Tag – Pinterest Europe LtdMeasures Pinterest ads_pin_unauth, _pinterest_ct_ua – up to 1 year
Marketing (consent)Microsoft Advertising (UET) – Microsoft Ireland Operations LtdMeasures Microsoft and Bing ads_uetsid – 1 day, _uetvid – 13 months, MUID – 13 months

Some of our tags send data through a server-side tagging container that we run on Google Cloud. It forwards only data you consented to and helps us limit what third parties receive.

You can also block or delete cookies in your browser settings. Blocking strictly necessary cookies may stop parts of the website from working.

7. Who receives your data

We do not sell personal data. We share it only with companies that help us run the business, and only as far as needed:

  • Cloudflare, Inc. (USA) – hosting, content delivery, security and cookie-free web analytics;
  • Google Ireland Ltd / Google LLC – Google Workspace (email, calendar, files), Google Analytics, Google Tag Manager, Google Cloud (server-side tagging) and Google Ads;
  • Zoho Corporation B.V. (Netherlands, EU data centre) – Bigin CRM and our website forms;
  • Stan (stan.store, USA) – the store and booking pages where you buy products or book calls;
  • Stripe Payments Europe Ltd (Ireland) – card and online payments;
  • Fakturownia sp. z o.o. (Poland) – invoicing;
  • Meta Platforms Ireland Ltd, Microsoft Ireland Operations Ltd and Pinterest Europe Ltd – analytics and advertising, only with your consent;
  • Upwork Inc. (USA) – when we work with you through Upwork;
  • providers of the AI tools we use (see section 5);
  • our accounting office, legal advisers and IT support, who are bound by confidentiality;
  • public authorities, courts and other bodies, when the law requires it.

Stripe, Upwork, Stan, Meta, Google (for its advertising services), Microsoft and Pinterest also process some data as independent controllers under their own privacy policies. A current list of our processors is available on request.

8. Transfers outside the European Economic Area

Some of the providers above are based in, or use servers in, countries outside the EEA, mainly the United States. We transfer data only with a lawful safeguard:

  • the European Commission adequacy decision of 10 July 2023 on the EU–U.S. Data Privacy Framework, for providers certified under it;
  • the Standard Contractual Clauses approved by the European Commission (Decision (EU) 2021/914), for other providers;
  • other adequacy decisions of the European Commission, for example for the United Kingdom.

You can ask us for a copy of the safeguards that apply by writing to hello@utubeo.com.

9. Your rights

Under the GDPR you have the right to:

  • access your data and receive a copy (Art. 15);
  • correct inaccurate or incomplete data (Art. 16);
  • have your data erased (Art. 17);
  • restrict processing (Art. 18);
  • data portability, for data you gave us based on consent or a contract (Art. 20);
  • object at any time to processing based on our legitimate interest, for reasons relating to your situation, and to direct marketing without giving any reason (Art. 21);
  • withdraw your consent at any time, without affecting earlier processing (Art. 7(3));
  • not be subject to a decision based solely on automated processing that has legal or similar significant effects (Art. 22).

To use any of these rights, write to hello@utubeo.com. We reply within one month. In complex cases we may extend this by two more months and will tell you why. We may ask you to confirm your identity.

You also have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warsaw, Poland, uodo.gov.pl, or with the data protection authority in the EU country where you live or work.

10. Profiling and automated decisions

If you agree to marketing cookies, Google, Meta, Microsoft and Pinterest may use them to place you in advertising audiences (for example people who visited our website) and to show you our ads. This is profiling for advertising. It does not lead to any decision with legal or similarly significant effects for you. We do not make such decisions by automated means.

11. How we protect your data

We use technical and organisational measures suited to the risk: encrypted connections (HTTPS), two-factor authentication on our accounts, access limited to people who need it, permission-based access to client accounts, regular updates and reputable providers. If a personal data breach occurs that is likely to put your rights at risk, we will report it to the supervisory authority within 72 hours and inform you where the law requires it.

12. Do you have to give us your data?

Giving data is voluntary. Some data is needed to reply to you, deliver a product or perform a contract. Without it we cannot do that. Tax law requires certain data on invoices.

13. Children

Our services are for businesses and adults. We do not knowingly collect data from children under 16. If you think a child has given us personal data, write to hello@utubeo.com and we will delete it.

14. Changes to this policy

We review this policy when the law, our tools or our services change. The current version is always on this page with its date. If we make important changes that affect you, for example a new purpose of processing, we will tell you by email or with a notice on the website. This version applies from 4 November 2026.

This policy is also available in Polish. Both versions have the same content.