Privacy Policy

The controller of your personal data is Appunite S.A. (operating the EmpoweredHouse brand), a joint-stock company organized under the laws of Poland.

• Registered office: Droga Debinska 3A/3, 61-555 Poznan, Poland
• KRS: 0000964739
• VAT ID (NIP): PL 7831812112
• Contact for privacy matters: privacy@empowered.house

We have appointed a Data Protection Officer, Karol Wojtaszek, whom you can reach at privacy@empowered.house.

This policy covers the EmpoweredHouse marketing website and direct correspondence with us. Shugyo (shugyo.ai) is a separate site with its own privacy policy; links from this Site to Shugyo are external.

Data you give us through the fit-call booking form or by email:

• Identity and contact data: your name, work email address, company name, and role.
• Qualification data you choose to share: the processes you would encode first, what you have tried so far, and an estimated annual revenue range.
• The content of any message you send us.

Data collected automatically when you visit the Site:

• Technical data: IP address, browser type and version, device and operating system, and approximate location derived from the IP address.
• Usage data: pages visited, referring URLs, timestamps, and interactions, collected through cookies and similar technologies.
• Business-visitor identification data: Snitcher uses your IP address to identify the company or organization associated with your visit. It identifies the business, not you as an individual.

We do not intentionally collect special categories of data, for example health, political, or biometric data. Please do not include such data in free-text fields.

Purpose	Legal basis
Respond to your enquiry, schedule and run a fit call, and send a written recap	Steps taken at your request prior to entering a contract (GDPR Art. 6(1)(b)); our legitimate interest in responding to business enquiries (Art. 6(1)(f))
Assess whether an engagement is a fit and prepare a proposal	Pre-contract steps (Art. 6(1)(b)); legitimate interest (Art. 6(1)(f))
Operate, secure, and improve the Site	Legitimate interest in running a safe, functional website (Art. 6(1)(f))
Non-essential analytics and any marketing communication	Your consent (Art. 6(1)(a)), where required
Comply with legal obligations, for example accounting and tax	Legal obligation (Art. 6(1)(c))

We do not run an automated nurture or marketing sequence, and we do not subscribe you to anything without your consent.

The Site uses cookies and similar technologies. Strictly necessary cookies keep the Site working and do not require consent.

Only where you have given consent through the cookie banner, we use PostHog for product and usage analytics, including pages visited, interactions, and similar signals, to understand how the Site is used and improve it. You can grant, decline, or withdraw consent at any time through the cookie banner and your browser settings; withdrawal does not affect processing carried out before you withdrew.

We also use Snitcher, a business-visitor identification service that uses your IP address to identify the company or organization behind a visit; it identifies the business, not you as an individual, and sets one cookie (SNID) to distinguish visitors. Snitcher processes data within the EU (AWS, Frankfurt). We rely on our legitimate interest in understanding which organizations engage with us (Art. 6(1)(f)); you can object at any time by contacting us.

The trackers in use are PostHog's analytics cookies and Snitcher's SNID cookie. The cookie banner lists them and lets you manage your choices.

We share personal data only with:

• Service providers (processors) who act on our instructions, namely PostHog (product and usage analytics) and Snitcher (business-visitor identification), together with our hosting, email, and calendar/scheduling providers.
• Professional advisers, for example legal and accounting, where necessary.
• Authorities, where required by law.

We do not sell your personal data.

Some of our providers may process data outside the European Economic Area, for example PostHog depending on the hosting region configured. Snitcher processes data within the EU (AWS, Frankfurt). Where data is processed outside the European Economic Area, we rely on an adequacy decision or appropriate safeguards such as the European Commission's Standard Contractual Clauses. You can request information about the safeguards in place by contacting us.

• Enquiry and fit-call data: kept for the duration of the conversation and for up to 24 months afterwards to follow up or to evidence the basis of contact, unless you ask us to delete it sooner.
• Data tied to a signed engagement: kept for the life of the engagement and for the period required by accounting and limitation-period rules.
• Technical, analytics, and visitor-identification data: kept for up to 14 months.

Under the GDPR you have the right to: access your data; rectify it; erase it; restrict or object to processing; data portability; and, where processing is based on consent, to withdraw consent at any time without affecting prior processing.

To exercise any right, contact privacy@empowered.house. You also have the right to lodge a complaint with the Polish supervisory authority, the President of the Personal Data Protection Office (Prezes Urzedu Ochrony Danych Osobowych, UODO), ul. Stawki 2, 00-193 Warszawa, or with the authority in your country of residence.

We apply technical and organizational measures appropriate to the risk, including access controls, encryption in transit, and limiting who can see enquiry data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

The Site is intended for businesses and is not directed at children. We do not knowingly collect data from children under 16.

We may update this policy. The current version and its effective date are posted on this page. Material changes will be made clear on the Site.

Questions about this policy or your data: privacy@empowered.house.