Privacy policy - Earlybell
Version of 9 October 2026.
1. Controller
The controller of your personal data is The Masters sp. z o.o., registered office ul. Polna 1, 43-512 Bestwina, Poland, KRS 0000546003, NIP 8943060072, VAT ID PL8943060072 ("we"). Data protection contact: contact@earlybell.eu. We have not appointed a data protection officer.
2. About this website
earlybell.eu tests whether businesses are interested in the Earlybell service. The service has not started yet. On this website you can join the list of interested businesses and take the free "Does the CRA apply to me" check. The rules are set out in our terms.
3. What data, why, and on what legal basis
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Sign-up to the early access list and notice when the service starts | e-mail, form answers (what you sell), sign-up date | Art. 6(1)(b) - contract for an electronic service (terms, section 2) |
| Free CRA check and sending the result by e-mail | e-mail, check answers, result code | Art. 6(1)(b) |
| Evaluating the test: how many sign-ups came from which ad | ad click ID (gclid) and utm parameters from the page address, whether you consented to advertising cookies | Art. 6(1)(f) - our legitimate interest in deciding whether to launch the service |
| Measuring Google Ads performance (advertising cookies) | cookie identifiers, visit and conversion data | your consent: Art. 6(1)(a) GDPR and Article 399 of the Polish Electronic Communications Law |
| Website usage statistics (analytics cookies, if any) | visit data | your consent: Art. 6(1)(a) GDPR and Article 399 of the Polish Electronic Communications Law |
| Website security and spam protection | IP address, date and time, page address, browser (server logs) | Art. 6(1)(f) - legitimate interest in security |
| Correspondence, complaints, establishing and defending claims | message content, e-mail | Art. 6(1)(f) - legitimate interest in replying and protecting against claims |
Providing data is voluntary. Without an e-mail address we cannot add you to the list or send the check result. We do not make decisions about you based solely on automated processing and we do not profile you.
4. Cookies and browser storage
| Name | Category | Purpose | Duration |
|---|---|---|---|
zgoda_v1 (browser storage) |
necessary | remembers your cookie choice | 6 months |
_gcl_au, _gcl_aw, _gcl_gs, _gcl_dc (Google Ads) |
advertising, only with consent | link a visit from an ad to a sign-up | up to 90 days |
If you do not consent, the website does not connect to Google and does not set advertising cookies. The ad click ID stays only in the page address and reaches us together with the form. You can withdraw your consent at any time using the "Cookie settings" link in the footer. Withdrawal does not affect the lawfulness of processing before it.
5. Who receives the data
- Hetzner Online GmbH (Germany): hosts the website server and the sign-up database. Processes data on our behalf.
- OVH: sends and stores our e-mail. Processes data on our behalf.
- Google Ireland Limited (Ireland): only if you consent to advertising cookies. For ad measurement it is a separate controller. Google's policy: https://policies.google.com/privacy
- Public authorities: only where the law requires it.
Google may transfer data to the USA. The basis is the European Commission adequacy decision (EU-US Data Privacy Framework) or standard contractual clauses.
6. How long we keep data
- Sign-up and check result: until the service starts or until we decide not to launch it, no later than 30 June 2027. Earlier if you unsubscribe.
- gclid, utm and consent flag: as long as the sign-up they belong to.
- Cookies and browser storage: see the table in section 4.
- Server logs: [to be completed: number of days] days.
- Correspondence: until the matter is closed or, if claims are possible, until they are time-barred.
7. Your rights
You have the right to:
- access your data and get a copy (Art. 15 GDPR);
- rectification (Art. 16 GDPR);
- erasure (Art. 17 GDPR);
- restriction of processing (Art. 18 GDPR);
- data portability for data processed under a contract or consent (Art. 20 GDPR);
- object to processing based on our legitimate interest (Art. 21 GDPR);
- withdraw your consent at any time (Art. 7(3) GDPR);
- lodge a complaint with a supervisory authority (Art. 77 GDPR), in particular in the EU country where you live or work. Our lead authority is the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, Poland.
To exercise your rights, write to contact@earlybell.eu. We reply within one month.
8. Changes
We announce changes on this page, and signed-up users also by e-mail. The version date is always at the top.