1. Data Controller
The controller is BCM CAPITAL sp. z o.o., operating the EWADC brand, with contact address at Juliana Smulikowskiego 4/16, 00-389 Warsaw, Poland.
Privacy enquiries may be sent to office@ewadc.com.
2. Scope
This Notice applies to website visitors, prospective customers, customers, customer representatives, authorised users, suppliers, business partners, support contacts and other persons communicating with EWADC.
Where EWADC processes personal data solely on behalf of a Customer as a processor, the Customer is generally responsible for providing privacy information to relevant data subjects and the processing may be governed by a Data Processing Agreement.
3. Personal Data We May Collect
Account and identity data
Name, business role, company, login/account identifiers, authorised-user information and information needed to verify a customer or representative.
Contact data
Email address, telephone number, business address and communication preferences.
Contract and billing data
Orders, quotations, agreements, invoices, payment status, VAT information, transaction references and related accounting records.
Technical and security data
IP addresses, timestamps, authentication and access logs, browser/device information, service identifiers, network metadata, security alerts, anti-abuse records and diagnostics.
Support and communications
Support tickets, emails, meeting information, service requests and troubleshooting information.
Website and preference data
Cookie identifiers, consent choices, analytics data and website interaction data where such technologies are enabled and permitted.
4. Purposes and Legal Bases
| Purpose | Typical data | GDPR legal basis |
|---|---|---|
| Provide and administer Services | Account, contact, contract, technical data | Performance of a contract or pre-contract steps |
| Billing, accounting and taxation | Billing, invoice and transaction data | Contract and legal obligations |
| Security, fraud prevention and abuse handling | Access logs, IP data, security and support records | Legitimate interests and, where applicable, legal obligations |
| Customer support and service communications | Contact, ticket and technical data | Contract and legitimate interests |
| Sales and business communications | Business contact and communication data | Legitimate interests or consent where required |
| Analytics or non-essential cookies | Cookie, device and interaction data | Consent where required |
| Legal claims | Relevant account, contract and communications | Legitimate interests |
Where legitimate interests are relied upon, EWADC considers necessity, proportionality and the rights and expectations of affected individuals.
5. Sources of Personal Data
Data may be provided directly by you, by your employer or organisation, generated through use of the Services, obtained from providers acting on our behalf, or obtained from lawful public or business sources where necessary for verification, compliance or business communications.
6. Recipients and Service Providers
EWADC may disclose personal data where necessary to hosting and infrastructure providers, telecommunications carriers, data-center partners, payment and banking providers, accounting and professional advisers, software and support providers, security and anti-abuse providers, and public authorities where required by law.
Providers processing personal data on EWADC's behalf are expected to operate under appropriate contractual and confidentiality obligations.
7. International Data Transfers
EWADC primarily operates from Poland and the European Union. Where personal data is transferred outside the European Economic Area, EWADC uses an available lawful mechanism where required, such as an adequacy decision, Standard Contractual Clauses or another GDPR-permitted mechanism.
8. Data Retention
Personal data is retained only as long as reasonably necessary for the purposes for which it was collected and to satisfy contractual, accounting, tax, security, dispute-resolution and legal requirements.
Retention varies by data type. Account and contract records may be kept for the customer relationship and an appropriate period afterwards. Security and support records may be retained for periods proportionate to operational, security and legal needs.
9. Security
EWADC applies technical and organisational measures designed to protect personal data against unauthorised or unlawful processing and accidental loss, destruction, alteration or disclosure. Measures may include access controls, authentication, logging, network security, physical data-center controls and confidentiality obligations.
No system can provide absolute security, and Customers remain responsible for security measures applicable to systems and data under their control.
10. Your GDPR Rights
Subject to GDPR conditions and limitations, you may have the right to:
- receive information about processing;
- access personal data and obtain a copy;
- request rectification;
- request erasure in applicable circumstances;
- request restriction of processing;
- object to processing based on legitimate interests;
- receive certain data in a portable format where applicable;
- withdraw consent at any time where consent is the legal basis, without affecting prior lawful processing;
- not be subject to certain solely automated decisions where Article 22 GDPR applies.
Requests may be sent to office@ewadc.com. EWADC may need to verify identity before responding.
11. Right to Lodge a Complaint
You have the right to lodge a complaint with the competent supervisory authority. In Poland, this is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych — UODO).
Urząd Ochrony Danych Osobowych (UODO), Warsaw, Poland. Current contact details are available at uodo.gov.pl.
12. Cookies and Similar Technologies
The EWADC website may use cookies and similar technologies for essential site operation and, where enabled and consented to as required, analytics, preferences or marketing functionality.
13. Changes to This Notice
EWADC may update this Notice to reflect changes in Services, processing activities, technology or law. The effective date at the top identifies the current version.
14. Contact
Juliana Smulikowskiego 4/16
00-389 Warsaw, Poland
VAT EU: PL5252716887
Email: office@ewadc.com