Who we are
RevolvX Andrii Poltavets
Andrii Poltavets, a sole trader established in Poland, trading as RevolvX.
Correspondence address: ul. Jabłoniowa 11/26, 83-330 Żukowo, Poland.
NIP: PL6783203939 · REGON: 524373095.
We are the controller responsible for the personal information described in this policy. For privacy questions, requests or marketing opt-outs, contact [email protected].
This policy covers revolvx.com and our dealings with prospective clients, clients and their business contacts, meeting participants and people who receive our communications. Our business is established in Poland and serves clients in the United Kingdom, United States and other markets.
Information we handle
- Contact and business details: name, email address, phone number, company, website and the business you represent.
- Inquiries and engagements: messages, appointment information, advertising spend, business goals, proposals, agreements and related correspondence.
- Advertising-account information: account identifiers, permissions, campaign information and reports available through access you authorise for a review or engagement.
- Meeting information: participants’ contributions, call recordings and transcripts, together with related meeting details.
- Communication preferences: subscription choices, available consent records and requests to stop marketing.
- Administration records: information needed to manage an engagement and its billing, accounting and legal records.
- Technical information: IP address, browser and device information, request details and information used to deliver and protect the website. See our Cookies Notice for browser storage and video features.
We receive information directly from you, through the booking and communication services you use to contact us, and through advertising accounts you authorise us to access. Our agreed service scope does not normally involve receiving your customers’ individual contact lists or order histories. Any work requiring additional personal data needs a separate assessment and appropriate arrangements.
Why we use information
We use information to respond to inquiries, arrange meetings, assess and deliver our services, administer engagements, send communications, advertise our business, protect our website and meet legal obligations.
Under European data-protection law, the legal ground depends on the purpose and your relationship with us:
- Requests and contracts: taking steps you request before a contract, or performing a contract, when you are the individual entering it.
- Business correspondence and service administration: our legitimate interests in responding to business contacts, delivering services to the organisations they represent and keeping relevant business records.
- Security and legal claims: our legitimate interests in preventing abuse, resolving technical issues and establishing, exercising or defending legal claims.
- Statutory records and privacy requests: compliance with our legal obligations.
- Marketing and consent-dependent processing: consent where the applicable law requires it; legitimate interests only where the law permits that basis for the particular activity. A legitimate interest does not remove a separate requirement for marketing, device-storage or recording consent.
Where legitimate interests apply, they must be balanced against your rights and interests. Information needed to answer an inquiry or deliver an engagement is voluntary to provide, but we may be unable to respond or provide the requested work without it. Reading this policy, visiting the website or submitting an inquiry is not, by itself, consent to marketing or recording.
Call recordings and transcripts
Our calls are recorded and transcribed. We tell participants that recording is taking place. If you do not want to take part in a recorded call, you can leave the call.
We use recordings and transcripts as a record of our business conversations and to support follow-up on the matters discussed. They can contain your voice, contributions, personal information you share and information about other people mentioned during the conversation. Avoid sharing personal information that is unnecessary for the discussion.
Recording and transcription remain subject to the applicable data-protection and recording laws. Where your consent is legally required, it must be established separately; this policy and the option to leave do not themselves establish that consent. Contact [email protected] to ask about a recording, object to its use or request access or deletion, subject to the rights and exceptions described below.
Email, SMS and advertising
We use contact details for RevolvX newsletters and marketing messages by email and SMS. We also use Google Ads and Meta Ads for advertising and remarketing. Advertising platforms process information about interactions with advertisements and their services under their own notices and the applicable campaign arrangements.
You can ask us to stop direct marketing to you at any time. Email [email protected] and tell us which email address or phone number the request concerns. You can also use an unsubscribe method provided in a message. You do not need to give a reason. Where processing relies on consent, withdrawing it does not affect the lawfulness of processing before withdrawal.
We may keep limited suppression information to respect an opt-out. Opting out of marketing does not prevent necessary, non-promotional messages about an inquiry, booking or existing engagement.
Advertising tracking is enabled by default unless disabled through Privacy choices or a browser opt-out signal. Our website sends PageView events to Meta through a server-side Conversions API integration for advertising measurement, personalized advertising and remarketing. Events include the public page path, event time, browser user agent, IP address, a browser identifier and an ad-click identifier when available. This integration does not send email addresses, phone numbers, URL query strings or fragments. You can turn advertising tracking off through Privacy choices in the footer; previously saved rejections are respected. We honor Global Privacy Control and Do Not Track signals. See our Cookies Notice for cookie names, durations and controls. These choices do not enrol you in a messaging program. Meta processes received data under its Privacy Policy.
Providers and other recipients
We use the following providers and service categories in our business:
- Google / Gmail: email and meeting communications.
- Cal.com: our previous public booking provider.
- Calendly: the public booking page linked from this website, scheduling and meeting-related operations.
- Fireflies: call recording and transcription.
- GoHighLevel: customer relationship and communication management.
- Cloudflare and website hosting providers: website delivery, infrastructure and security.
- YouTube / Google: embedded video delivery when you activate a video.
- Google Ads and Meta Ads: advertising and remarketing services.
These services may use their own infrastructure and delivery providers. They may act on our instructions for some activities and have independent responsibilities for others. We may also disclose relevant records to professional advisers, authorities or other recipients where needed for legal obligations or legal claims.
Provider notices include Google, Cal.com, Calendly, Fireflies, GoHighLevel, Cloudflare and Meta. Their notices explain their own processing and do not replace this policy.
International processing
We operate from Poland. Our providers may process information in the United States and other countries, including countries outside the European Economic Area or United Kingdom. Processing locations depend on the provider, service and applicable account arrangements.
Transfers subject to European or UK restrictions require an applicable safeguard. Relevant provider arrangements may use an adequacy decision, including a data-privacy framework where the recipient and transfer qualify, or standard contractual clauses with the relevant UK provisions where needed. Calendly and Fireflies describe their transfer arrangements in their published Calendly data-processing addendum and Fireflies data-processing agreement.
Contact [email protected] for information about a particular transfer and the safeguards or copies relevant to it. A provider’s availability in Europe does not mean all of its processing takes place in Europe.
How long we keep information
Our retention policy for ordinary engagement-related personal information is the duration of the engagement and 180 days after it ends. This includes ordinary correspondence and meeting records associated with the engagement, subject to the exceptions below.
- Inquiries that do not become engagements: for the time needed to deal with the inquiry and complete its related follow-up. An ongoing marketing subscription is treated separately.
- Marketing subscriptions: while the subscription or other lawful marketing relationship remains active. After an opt-out, we retain limited information needed to respect the request and demonstrate relevant consent or withdrawal.
- Tax and accounting records: for the statutory retention period. Polish tax documentation is generally kept until the related liability is time-barred, ordinarily five years from the end of the year in which payment was due; suspension or interruption can extend that period.
- Legal claims: relevant records for the applicable limitation period and any related proceedings or preservation requirement.
- Advertising page views: event payloads are processed transiently by our relay. Random event identifiers are retained in memory for up to 24 hours to prevent duplicate delivery; we do not keep a local database of advertising page-view payloads. Explicit advertising preferences last 180 days and advertising identifiers up to 90 days in your browser. Meta’s retention is governed by its own policy.
- Security and technical records: for the period needed to identify, investigate and resolve the relevant security or operational issue, subject to provider retention arrangements and legal requirements.
These exceptions apply to the records needed for the particular purpose, rather than extending the retention of every record. Deletion from an active system may not immediately remove a copy from a provider’s backups; backup handling and expiry depend on that system’s retention arrangements.
Your rights and choices
Depending on the applicable law and circumstances, you may have rights to access your information, correct it, request deletion, restrict processing, receive information in a portable form, object to processing and withdraw consent. In particular, you can object to direct marketing at any time. Legal obligations and other lawful exceptions may limit a request.
Send requests to [email protected]. We may ask for information reasonably necessary to confirm your identity or a representative’s authority. We will respond within the applicable legal deadline and explain any permitted extension or limitation.
Where applicable US state law provides them, your rights may also include opting out of targeted advertising, sale or sharing as legally defined, and appealing a decision about a privacy request. Send an opt-out or an appeal to the same address, identifying the request concerned. We assess those requests under the law that applies; exercising an applicable privacy right should not result in unlawful discrimination.
You may complain to Poland’s President of the Personal Data Protection Office (Prezes UODO) or another competent supervisory authority, including where you live, work or believe an infringement occurred. UK individuals may also contact the Information Commissioner’s Office.
Changes and contact
We may update this policy when our practices or applicable requirements change. The date at the top identifies this version. We will provide additional notice where required for a material change.
For questions about this policy, contact [email protected] or write to our correspondence address above.