Privacy Policy
This privacy policy describes how we process information about you, including personal data and cookies.
1. General Information
This policy applies to the website at: www.semperavanti.org
Data Controller: SEMPER AVANTI, plac Świętego Macieja 5/23, 50-244 Wrocław, Poland
Contact email: info@semperavanti.org
The Operator is the Controller of your personal data with respect to data voluntarily provided on the Website.
The Website uses personal data for the following purposes:
- handling enquiries through the contact form,
- website traffic analysis (after obtaining consent),
- displaying personalized advertisements (after obtaining consent).
The Website collects information about users and their behavior in the following ways:
- through data voluntarily entered in forms, which is then entered into the Operator’s systems,
- by storing cookies on end devices — only after the user has given consent via the consent banner.
2. Data Protection Methods
Login and personal data entry areas are protected at the transmission layer (SSL certificate). This means that personal data entered on the website is encrypted on the user’s computer and can only be read on the target server.
The Operator periodically changes administrative passwords. To protect data, the Operator regularly performs backups. An important element of data protection is the regular update of all software used for processing personal data.
3. Hosting and Security
The Website is hosted on Docker-based infrastructure with an Nginx server, served securely via a Cloudflare Zero Trust tunnel.
The hosting provider maintains server-level logs for technical reliability. The following may be recorded: requested resource URLs, time of queries, browser information, and IP addresses.
Cloudflare, as a CDN and security infrastructure provider, processes data to protect against attacks (e.g., DDoS) and ensure optimal website performance. To achieve this, Cloudflare sets essential technical cookies, such as __cf_bm (for bot identification) and, when logging in via the tunnel, access tokens (e.g., CF_Authorization). These cookies are strictly necessary for the operation of the website and do not require consent.
Additionally, to monitor site performance and visits in a privacy-respecting manner, we use Cloudflare Web Analytics (the beacon.min.js script). This is a cookieless analytics method that does not use client-side state to track individual users and does not profile visitors; it only provides us with aggregated statistics on traffic and page load speed.
4. Consent Management — Google Consent Mode v2 and Klaro
The Website uses Google Consent Mode v2 together with the Klaro consent management tool to manage user consent for cookies.
How it works:
- On first visit, all tracking and advertising consents are disabled by default (status:
denied). - A consent banner (Klaro) is displayed where the user can:
- accept all cookies,
- decline all optional cookies,
- choose individually which categories to consent to.
- Only after consent is given do the relevant tracking scripts begin collecting data.
- The user can change their settings at any time via the “Cookie Settings” link in the website footer.
Google Consent Mode v2 consent categories:
| Parameter | Description | Default |
|---|---|---|
analytics_storage | Storage of analytics data | Denied |
ad_storage | Storage of advertising data | Denied |
ad_user_data | Sending user data to Google Ads | Denied |
ad_personalization | Ad personalization | Denied |
User consents are stored in the klaro cookie and remembered for 365 days.
5. Cookies
5.1. What are cookies?
Cookies are computer data, specifically text files, stored on the user’s end device. Cookies typically contain the name of the website they originate from, their storage duration on the end device, and a unique number.
5.2. Types of cookies
The Website uses two main types of cookies:
- Session cookies — temporary, stored until the user leaves the website or closes the browser.
- Persistent cookies — stored for the period specified in their parameters or until deleted by the user.
5.3. List of cookies
Essential cookies (consent not required):
| Cookie | Provider | Purpose | Duration |
|---|---|---|---|
klaro | Klaro (local) | Storing user consent preferences | 365 days |
__cf_bm | Cloudflare | Bot identification, site protection | 30 minutes |
Analytics cookies (consent required — “Analytics” category):
| Cookie | Provider | Purpose | Duration |
|---|---|---|---|
_ga | Google Analytics | Distinguishing users | 2 years |
_ga_<ID> | Google Analytics | Maintaining session state | 2 years |
_gid | Google Analytics | Distinguishing users | 24 hours |
_gat | Google Analytics | Throttling request rate | 1 minute |
Advertising cookies (consent required — “Advertising” category):
| Cookie | Provider | Purpose | Duration |
|---|---|---|---|
_gcl_au | Google Ads | Conversion linker | 90 days |
_gcl_aw | Google Ads | Campaign conversion tracking | 90 days |
_gac_<ID> | Google Ads | Advertising campaign information | 90 days |
5.4. Managing cookies
You can manage your consents at any time:
- Klaro consent banner — click “Cookie Settings” in the website footer to change your preferences.
- Browser settings — you can change cookie settings in your browser:
Restricting the use of cookies may affect some functionalities available on the Website.
6. Marketing Techniques
The Operator uses the following marketing tools (only after obtaining user consent):
Google Analytics (Google LLC, USA) — statistical analysis of website traffic. The Operator does not transmit personal data to this service, only anonymized information (IP anonymization enabled). The service is based on the use of cookies. You can review and edit information about your preferences collected by the Google advertising network using the tool at: https://www.google.com/ads/preferences/
Google Ads (Google LLC, USA) — an advertising platform enabling personalized ad display and conversion tracking. Data collected through Google Ads includes information about interactions with advertisements.
Remarketing — a technique allowing ads to reach people who have previously visited our website. This only works after consent to advertising cookies has been given.
Google Tag Manager (Google LLC, USA) — a tool for managing tracking scripts. GTM itself does not collect personal data but manages scripts that do (e.g., Google Analytics, Google Ads).
7. Your Rights
Under the GDPR, you have the right to:
- Access your personal data.
- Rectification of inaccurate data.
- Erasure of data (“right to be forgotten”).
- Restriction of data processing.
- Data portability to another controller.
- Object to processing based on the controller’s legitimate interest.
- Withdraw consent at any time — withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal. Cookie consent can be withdrawn using the Klaro banner (“Cookie Settings” link in the footer).
You have the right to lodge a complaint with the President of the Office for Personal Data Protection (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warsaw, Poland.
8. Data Recipients
In certain situations, the Controller may share your personal data with other recipients:
- Google LLC (USA) — as part of Google Analytics and Google Ads services. Data transfers to the USA are based on Standard Contractual Clauses approved by the European Commission.
- Cloudflare Inc. (USA) — as a CDN and security infrastructure provider.
- Authorized employees and associates — who use data to carry out website operations.
9. Data Retention Period
- Contact form data: for the time necessary to handle the enquiry, no longer than 3 years.
- Marketing data (cookies): according to the lifetime of individual cookies (see the list in section 5.3).
- Klaro consents: 365 days from the last consent given.
10. Data Transfers to Third Countries
Personal data may be transferred to third countries (USA) as part of services provided by Google LLC and Cloudflare Inc. Data transfers are based on:
- Standard Contractual Clauses (SCCs) approved by the European Commission,
- EU-U.S. Data Privacy Framework (where applicable to the relevant entity).
11. Information in Forms
- The Website collects information voluntarily provided by the user, including personal data, if provided.
- The Website may record information about connection parameters (timestamp, IP address).
- Data provided in forms is processed for the purpose arising from the function of the specific form (e.g., handling a contact enquiry).
- Providing personal data is voluntary but necessary to handle the enquiry.
12. Automated Decision-Making
No automated decision-making, including profiling, that produces legal effects or similarly significantly affects users is carried out with respect to Website users.
Google advertising systems may apply profiling for ad selection — this only occurs after the user has consented to advertising cookies and is carried out by Google LLC under the terms described in Google’s Privacy Policy.
Last updated: April 2026