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TESSERA PROXY

Privacy Policy

Version 1.1 · Effective from 5 November 2026

Last updated

1. Who is the controller

The controller of your personal data is Antoni Kowalcze, a natural person developing the Tessera project (working name), ul. Zdrojowa 74, 32-400 Myślenice, Poland.

Contact for all data protection matters: [email protected]. We have not appointed a Data Protection Officer.

We plan to register a company. When we do, the company will become the controller. We will tell you by e-mail before the change, and you will be able to leave the waitlist.

2. What data we process

  • From the waitlist form: e-mail address (required); first name, last name and company name (optional).
  • Consent record: the version of this Privacy Policy you accepted, the date and time you accepted it, and your IP address at sign-up.
  • Correspondence: if you write to us, your e-mail address and the content of your message.
  • Technical data: IP address, date and time, requested URL and browser type, processed by Cloudflare to deliver and protect the website.

We do not process special categories of data (Article 9 GDPR).

3. Purposes, legal bases and retention

  • Waitlist: inviting you to a pilot or to alpha/beta testing, asking for a short conversation about your needs, announcing the launch. Legal basis: your consent – Art. 6(1)(a) GDPR and Art. 398 of the Polish Electronic Communications Law (Prawo komunikacji elektronicznej). Retention: until you withdraw consent, but no longer than 24 months from sign-up or 6 months after the release of version 1.0, whichever comes first.
  • Proving that we had your consent. Legal basis: our legitimate interest – Art. 6(1)(f) GDPR. Retention: as long as your waitlist entry exists; the consent record is deleted together with it.
  • Answering your messages and requests concerning your data. Legal basis: legal obligation – Art. 6(1)(c) GDPR (data subject requests); otherwise our legitimate interest – Art. 6(1)(f) GDPR. Retention: 3 years after the matter is closed.
  • Website delivery, security and abuse prevention (via Cloudflare). Legal basis: our legitimate interest – Art. 6(1)(f) GDPR. Retention: Cloudflare processes it only as long as needed to provide the service.
  • Establishing, exercising or defending legal claims. Legal basis: our legitimate interest – Art. 6(1)(f) GDPR. Retention: until claims are time-barred.

Our legitimate interests are: being able to prove that we act lawfully, keeping the website secure, and protecting our rights in case of a dispute.

Waitlist entries older than 24 months are deleted automatically. We do not keep backups of waitlist data, so deleted data is gone for good.

4. Do you have to give us your data

Providing data is voluntary. It is not a statutory or contractual requirement. Without an e-mail address you cannot join the waitlist. First name, last name and company are optional.

5. Who receives your data

  • Hetzner Online GmbH, Germany. Role: server hosting, including our database, which runs on that server. Location: data centre in Falkenstein, Germany.
  • Amazon Web Services EMEA SARL, Luxembourg (Amazon SES). Role: sending e-mails. Location: EU (Frankfurt) region, Germany; parent company in the USA.
  • Cloudflare, Inc., USA. Role: website delivery and protection (CDN, DDoS protection). Location: global network, including the USA.
  • Purelymail (Add Rabbit LLC), USA. Role: hosting our e-mail inboxes, including [email protected]. Location: USA.

These providers process data on our behalf and on our instructions (Art. 28 GDPR). Members of our five-person founding team also have access, as persons authorised by the controller and bound by confidentiality.

6. Transfers outside the EEA

Cloudflare, Amazon Web Services and Purelymail are based in the USA or may access data from there.

  • Cloudflare and Amazon Web Services: we rely on the EU-U.S. Data Privacy Framework and, as a fallback, the European Commission's Standard Contractual Clauses included in their data processing agreements.
  • Purelymail: we are concluding a data processing agreement based on the European Commission's Standard Contractual Clauses.

You can ask us for a copy of the safeguards at [email protected].

7. Your rights

You have the right to:

  • access your data,
  • have it rectified,
  • have it erased,
  • restrict processing,
  • data portability,
  • object to processing based on our legitimate interest,
  • lodge a complaint with the Polish supervisory authority: Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, Poland, uodo.gov.pl.

9. Automated decisions

We do not make automated decisions about you and we do not profile you.

10. Cookies

Our website does not use any cookies, analytics or tracking tools.

11. Security

We use encrypted connections, restricted and authenticated access to servers, and regular updates.

12. Changes

We will tell you by e-mail about significant changes, such as a change of controller, product name or providers. Previous versions are available on request.