Last updated: 26 September 2026
1. The controller
The Polibeli service was designed and developed, and is operated, by DarwinAI (the “Provider”).
2. What data we process and why
| Processing | Data | Purpose and legal basis | Retention |
|---|---|---|---|
| Pilot demo request | name, position, institution, faculty/department, email address, phone number (optional), message, time and source of the request | getting in touch and arranging the demo; steps prior to entering into a contract (GDPR Art. 6(1)(b)) and legitimate interest (Art. 6(1)(f)) | 2 years after the business relationship ends, or until objection |
| Newsletter (optional) | email address, name, time of subscription and confirmation | news about Polibeli; consent (Art. 6(1)(a)) with double opt-in | until unsubscribing |
| Business contacts | public institutional data (name, website), the contact’s name, position and business contact details, contact history | initiating and maintaining institutional partnerships; legitimate interest (Art. 6(1)(f)) | 2 years after the relationship ends, or until objection |
| Visitor analytics | aggregate statistics of page views and events (page, referrer, campaign parameters, device type, country). No cookies; IP address and browser identifier are processed only to tell visits apart | improving the website; legitimate interest (Art. 6(1)(f)); can be switched off, and the browser’s “Do Not Track” setting is respected | in aggregate form |
| Security logs | IP address, time, requested page, browser identifier | secure operation and investigating abuse; legitimate interest | at most 30 days |
3. Who can access the data?
Authorised staff of the Provider, with role-based permissions. The hosting provider acts as processor (see the legal notice), as do – when the feature is enabled – the email delivery provider and the analytics provider. We do not sell data or share it with third parties for advertising.
Switching off visitor analytics
You can switch off visitor analytics in this browser. Your choice is kept in the browser’s local storage.
Visitor analytics is allowed in this browser.
4. Your rights
You can request access to your data, its rectification, erasure or restriction, object to processing based on legitimate interest, request data portability and withdraw your consent at any time. Send your request to the contact details in section 1; we reply within one month.
You can lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH, 1055 Budapest, Falk Miksa utca 9–11, www.naih.hu) or go to court.
5. Data in the examination system
Processing related to exams (exam ID, name, drawn topic, question-and-answer transcript, audio recording, analysis and event log) is part of the educational institution’s exam organisation. Roles, purposes, storage location and retention are set out in the agreement with the institution and in the institution’s own notice. Students receive a recording notice on site and confirm it during the device check.
6. Data security
Encrypted (HTTPS) connections, role-based access, one-way (scrypt) password storage, logged administrative actions and regular backups. Session cookies of internal areas are HttpOnly and SameSite-protected.
7. Changes to this notice
We update this notice when the service changes; the current version is always available on this page.