This Privacy Policy sets out the rules for using the Internet website and provides information on the personal data privacy protection methods regarding the users of the Internet website located at, hereinafter referred to as “Website”


§1. Administrator of personal data

The administrator of personal data of the Website users is Headway Sp. z o.o. (hereinafter: Headway) with its registered office at ul. Prosta 36, 53-508 Wrocław, entered into the Register of Entrepreneurs kept by the District Court for Wrocław – Fabryczna, 6th Commercial Division, under the National Court Register number 13071, with a share capital pf PLN 200,000 (paid in full), NIP 8942611446, REGON 932182436.


§2. Whose data do we process

Headway processes the data of persons who:

  1. visit the Website,
  2. have sent a query via the contact form provided on the Website subpages,
  3. order services on the Website,
  4. use the services provided by Headway.


§3. For what purpose, in what scope and on what legal basis do we process personal data

The data of persons visiting the Website remains anonymous to us and is processed only for statistical purposes that serve to test user activity on the Website. During the session, the Website saves cookie files to the user’s browser memory. We provide statistical data for the processing of Google Inc. using Google Analytics.

We also process your personal data because it is necessary to execute the contract concluded with you, including:

  1. enabling the provision of the service by electronic means, in particular the service consisting in: website lease, online store lease, domain lease;
  2. handling requests that you send to us (e.g. via the contact form);
  3. handling a complaint in the event you make such a complaint;
  4. contacting you, including for purposes related to the provision of services.

In addition, the law requires us to process your data for tax and accounting purposes. We also process your personal data for the purposes set out below, based on the legitimate interest of Headway, which is:

  1. contacting you, including for purposes related to permitted marketing activities, through available communication channels, in particular and with your consent – via e-mail and telephone;
  2. handling your requests, in particular sent to the customer service department and via the contact form in a situation where they are not directly related to the execution of the contract;
  3. ensuring the safety of the services we provide you by electronic means, including enforcing compliance with internal rules of Headway and counteracting fraud and abuse as well as ensuring traffic safety;
  4. debt collection; conducting court proceedings;
  5. organisation of loyalty programs, competitions and promotional campaigns in which you can take part;
  6. conducting statistical analyses;
  7. toring data for archiving purposes and ensuring accountability (showing compliance with our obligations resulting from legal provisions).


§4. Period of personal data storage.

  1. Personal data necessary to perform the service is kept for the entire duration of the contract, and after its completion the personal data of customers contained in the settlement documentation will be processed for the period necessary to conduct financial reporting.
  2. Personal data may be processed after the end of the contract in order to claim for unsettled payments until the financial settlement of the Parties is completed.
  3. Other personal data will be stored only until the purpose for which they were collected is fulfilled.


§5. The rights of the data subject.

We guarantee the fulfilment of all your rights under the general Data Protection Regulation, i.e. the right to access, rectify and delete your data, limit its processing, the right to transfer its, not to be subject to automated decision making, including profiling, and the right to object to the processing of your personal data.


§6. Providing data

We require you to provide the following personal data in order to be able to conclude and execute the contract concluded with you, and thus provide you with the service:

  1. name, surname or information about your company,
  2. address data,
  3. e-mail address and phone number.

If required by law, we may require you to provide other data necessary, for example, for accounting reasons. Apart from these cases, providing your data is voluntary.


§7. Cookies

The Website uses small files called cookies. They are saved by the server on the computer of the visitor of the Website pages. We use cookies for the following purposes:

  1. keeping information concerning the user’s session, e.g. information concerning logging in,
  2. statistical – information concerning the first/last visit to the website, duration of visits, viewed subpages, sources from which the user has visited the website,

The cookies used by the website do not allow to identify the person’s identity. The user can restrict or disable file access in the settings – options in their browser.


§8. Access to data by third parties

Direct access to personal data processed by Headway is only granted to persons authorised by the personal data administrator for such access.
Personal data processed in Headway files may be made available to entities authorised to receive it under applicable law, in particular competent judicial authorities


§9. Security and protection of personal data

Headway declares that it processes personal data provided or entrusted by Users in accordance with the Act of 29 August 1997 on the protection of personal data and that it applies technical and organisational measures ensuring data protection adequate to the threats and categories of data protected, in particular protecting Users’ personal data against making it available to unauthorised persons, loss or damage.


§10. Contact with us

Any additional questions related to the Privacy Policy should be directed to the address


§11. Changes to the Privacy Policy

Headway reserves the right to make changes to the Privacy Policy