Communications and marketing

Two consents, not one

Marketing messages require two independent conditions to be met at the same time, and neither replaces the other.

First, the GDPR: there must be a basis for processing your data. For marketing that basis is consent (Article 6(1)(a) GDPR).

Second, electronic communications law: separate consent is required for USING THE CHANNEL itself to send commercial information. In Poland this is governed by the Electronic Communications Law of 12 July 2024, which from 10 November 2024 replaced Articles 172-173 of the Telecommunications Law and Article 10 of the Act on Providing Services by Electronic Means in this respect.

That is why consent is always collected explicitly and separately. We never infer it from the fact that you created an account, made a purchase or registered for an event.

Types of messages you may receive

• Service (transactional) messages - registration confirmation, password reset, payment confirmation, invoice, event reminder, change of terms. They are necessary to perform the contract, so they are not covered by marketing consent and CANNOT be switched off without deleting the account.
• Editorial newsletter - ordered separately, with its own consent and its own unsubscribe link in every message.
• Marketing communications - invitations to commercial events, subscription offers, partner information. Always based on marketing consent.
• Activity notifications - a reply to your comment, a message, a network invitation. You control these per category in notification settings.
• Browser push notifications - only after permission granted in the browser AND marketing consent, where the content is commercial.
• Product information about platform changes - on by default as relevant to using the service, but switchable off in settings.

How newsletter sign-up works

We use double opt-in. After you submit an address we send a message with a confirmation link, and only clicking it starts delivery. An unconfirmed address never reaches the sending list.

This protects against signing somebody up against their will - and at the same time proves that the consent came from the owner of the mailbox.

• With every consent we store its text in the version you saw, a timestamp, the language and the source of the decision. Changing the text bumps the consent version and requires a fresh decision - we never stretch an old consent onto a new scope.
• Required fields are limited to the email address. A first name is optional and is used only to personalise the greeting.
• We use no pre-ticked boxes and no bundled consents - every consent has its own field and its own text.
• Consent to measuring opens and clicks has its own unticked box and its own text. You receive the newsletter without it as well, and you can withdraw consent to measurement separately, at any time and without unsubscribing (see Measuring delivery performance).
• The confirmation link is single-use and expires. Clicking a confirmed link again shows an already confirmed state rather than an error.

How to opt out

Opting out must be as easy as opting in - that is the requirement of Article 7(3) GDPR and that is how it works here.

• The unsubscribe link sits in the footer of every marketing message and newsletter. It works without signing in and without giving a reason.
• Unsubscribing takes effect immediately. We run no grace period and send no extra messages asking you to reconsider.
• Signed-in users switch individual categories off in consent settings (/profile/privacy) - with a visible decision history.
• You can also write to office@neweuropeanstrategies.com; we action an objection to direct marketing immediately and without asking why (Article 21(2)-(3) GDPR).
• After an opt-out the address goes onto a suppression list. That is the only way an unsubscribe survives a list re-import - which is why the address itself stays even though the rest of the newsletter data is removed.
• We honour the Global Privacy Control signal sent by your browser and treat it as an objection to processing for marketing purposes.

Personalisation and segmentation

We tailor newsletter content to what you read and which topics you follow. This is low-risk profiling - we take no decisions on that basis that produce legal or similarly significant effects within the meaning of Article 22 GDPR.

You can switch personalisation off by withdrawing the personalisation consent. We then send the newsletter in a non-profiled version rather than stopping it.

• Segmentation is based on content categories, open history (only with consent to measurement) and preferences declared in your profile.
• We do not buy address lists and we do not enrich our lists with data from data brokers.
• We do not hand email addresses to partners for their own mailings. If a partner is to reach you, it happens through us or on the basis of a separate consent given to them.

Measuring delivery performance

We measure opens and clicks only for active subscribers who have confirmed separate consent to measurement themselves. Measurement requires access to information on your device, so its legal basis is consent (Article 6(1)(a) GDPR and Article 399 of the Polish Electronic Communications Law; EDPB Guidelines 2/2023).

• We record deliveries, bounces and unsubscribes for every mailing - without them we cannot deliver messages, honour opt-outs or maintain sender reputation.
• We measure opens (a tracking pixel in the message) and clicks (a link passing through a counting redirect) only with your separate consent to measurement. Ticking the box in a form does not switch measurement on: the consent takes effect only once you confirm it with the button on the page opened from a link in an email sent to your address, and only while you are an active subscriber. Purpose: tailoring the content and sending frequency, and statistics.
• How you confirm the consent: when you sign up with address confirmation (double opt-in), we ask you about it on the sign-up confirmation page, where you can confirm or decline it with a button; when you sign up without address confirmation, we send a separate email asking you to confirm. Without your click measurement stays off, and you can decide within 60 days. We record the consent text and version, how it was confirmed, the time, the IP address and the browser.
• Without such consent the message carries no tracking pixel and links lead straight to their destination, with no recipient identifier.
• You can switch measurement off separately, without unsubscribing: the “Don't measure my opens and clicks” link is in the footer of every marketing message and on the unsubscribe page. It takes effect immediately and is recorded in the consent log, and the newsletter keeps coming.
• With every consent we store the text and version you saw, and for consent to measurement also how it was confirmed. The mention of measurement in the newsletter consent text of 21 October 2026 is not treated as consent to measurement. We may ask you once for separate consent to measurement - not answering changes nothing.
• The end of a newsletter subscription - unsubscribing, a permanent bounce, a spam complaint or an administrator's decision - also ends consent to measurement. After you sign up again, measurement needs a new confirmation by the mailbox owner.
• A mail client that blocks images switches the tracking pixel off effectively, and this has no effect on content delivery. The link destination is always our own address or an address stated explicitly in the message.
• We analyse statistics in aggregate. We do not build assessments of individuals from them and do not share them with advertisers in a form that identifies a recipient.

Advertising, sponsored content and political advertising

• Paid material is unambiguously labelled as advertising, sponsored or partner content - both in the service and in the newsletter.
• Advertising does not influence editorial content. Publishing decisions are taken independently of commercial relationships.
• We run political advertising in line with Regulation (EU) 2024/900 on the transparency and targeting of political advertising, applicable since 10 October 2025. Every such item carries a political advertising label, the sponsor's identity and information on targeting criteria, and we retain the documentation the Regulation requires.
• The Regulation prohibits targeting political advertising using special categories of data and targeting people we know have not reached voting age - we observe both prohibitions absolutely.
• Detailed rules for advertising cooperation are set out in our advertising guidelines.

Sender authentication and security

• Our messages are authenticated with SPF, DKIM and DMARC - so spoofing of our domain is detectable at the recipient's end.
• We never ask in a message for a password, a one-time code or full card details. A message containing such a request did not come from us.
• Payment links lead only to our own service or to the payment provider's page.
• Report a suspicious message impersonating New European Strategies to office@neweuropeanstrategies.com - ideally with the message headers.

Contact

Matters concerning mailings, consents and opt-outs: office@neweuropeanstrategies.com. If you receive messages from us despite opting out, treat it as an incident report - we will check how the address got back onto the list.