Patryk Press

Poland's business day in 3 minutes.

The English-language briefing for foreign investors and executives in Poland.

Written by a US expat who calls Poland home, invested in its future.

DRAFT — not an approved privacy notice

This notice is a draft awaiting review and approval by counsel. It is not a finished legal document.

Privacy notice — DRAFT

Status: DRAFT. This is not a finished legal document. It needs review and approval by counsel familiar with RODO/GDPR and with a US company offering a newsletter to readers in the EU before the sign-up form goes live or any subscriber data is collected. Placeholders in square brackets must be filled in.

A short, plain-English notice should be published at https://patrykpress.com/privacy and linked from the form, every email, and the site footer.

1. Who is the controller?

Quigley Capital LLC, a United States limited liability company, is the controller of personal data collected through patrykpress.com and the Patryk Press email list. Patrick provided the owner’s name and that the company is a US LLC. Registry details (state of formation, registration number, registered address) remain [TBC] and are not stated here. The domain patrykpress.com is the domain Patrick says he registered; the public registry record does not show the registrant, and those registry details remain [TBC].

[Registered address and a contact email for privacy requests — to be supplied.]

2. What we collect

  • Email address (required), in order to send the briefing.
  • Optional: role, company, and stated interests.
  • Technical data that the site or email platform needs to deliver the service (for example IP address on sign-up, and email delivery and open events) should be listed here once the exact tools and logs are confirmed.

3. Why we collect it, and on what legal basis

To send the daily briefing you asked for (consent, Article 6(1)(a) GDPR, and/or performance of a request to receive the newsletter, Article 6(1)(b) GDPR). Optional fields are used only to understand the audience and are also based on consent. Any later use for direct outreach as a lead source should be described here and consented to separately if it goes beyond sending the briefing.

4. Where data is processed — including processing in the United States by Kit

The site may be hosted in the EU or the United States (for example on Vercel).

The email platform is Kit. Newsletter-subscriber data is processed by Kit as a processor under Kit’s Data Processing Addendum (kit.com/dpa), not under Kit’s Privacy Policy. That policy says that when Kit processes the personal information of newsletter subscribers, it does so as a processor subject to the DPA and not the Privacy Policy. Kit’s DPA Attachment 3 (Subprocessor List, last updated 9 October 2026, checked on that page on 10 November 2026) lists the country where each sub-processor will process subscriber personal data as the United States. For transfers of EEA, UK and Swiss subscriber data, the DPA incorporates the EU Standard Contractual Clauses, Module 2 (Controller to Processor), with the customer as data exporter and Kit as data importer (DPA section 5.2). That means this personal data (at least the email address, and any optional role, company and interest fields, plus delivery events Kit records) leaves the European Economic Area.

Counsel should still review the current DPA, confirm it is in place for the account, and approve this section before the form goes live. Do not publish this section until that review is done.

5. How long we keep it

For as long as the person remains subscribed, and for a short period afterwards as needed to honour an unsubscribe and keep basic records of consent.

6. Who we share it with

Email and hosting providers acting as processors, under a data-processing agreement. The email processor is Kit. We do not sell the list.

7. Your rights

Access, rectification, erasure, restriction, objection, portability, and the right to withdraw consent at any time, without affecting the lawfulness of earlier processing. The right to lodge a complaint with a supervisory authority, including in the EU member state where the reader lives or works (in Poland, the President of the Personal Data Protection Office, UODO).

8. How to contact us and how to unsubscribe

[A postal or email address for requests — to be supplied.] A working unsubscribe link will be in every email.

9. Updates

[Date of the notice — to be supplied], and a short statement of how material changes will be communicated.

End of DRAFT. Do not treat this as an approved privacy notice.