§1
General provisions
- This Privacy Policy governs the processing and protection of personal data provided by Users in connection with their use of services through the Wiphly mobile application (the “Application”).
- The administrator of the Users’ personal data provided in connection with their use of the services through the Application (hereinafter: “Personal Data”) is CodeAgency.pl Sp. z o.o. with its registered office in Bydgoszcz, 18 Królowej Jadwigi Street, entered in the Register of Entrepreneurs under the KRS number: 0000725181, REGON number: 369798302, NIP number: 9671412160 hereinafter: the Administrator.
- The administrator has not appointed a Data Protection Officer
§2
Principles of collecting Users’ Personal Data
- Registration of the User, and thus access to the functionalities of the Application, involves the need for the User to provide Personal Data.
- Failure by the User to provide Personal Data will not allow Registration.
- Users’ personal data are processed as follows:
- Provision of the service of maintaining the User’s account and any related Services in the Application – the legal basis for data processing is the performance of the contract (Article 6(1)(b) of the RODO);
- marketing – the legal basis for data processing is the Company’s legitimate interest – marketing of its own products and services (Article 6(1)(f) RODO),
- to consider complaints, to investigate and defend in the event of mutual claims – the legal basis for data processing is the Company’s legitimate interest – (Article 6(1)(f) RODO),
- Sending commercial information by electronic means – only in case of the User’s consent – the legal basis for data processing is consent (Article 6(1)(b) RODO);
- realization of legitimate interests. Our legitimate interests include: providing payment services, conducting a survey of the level of satisfaction of Users, possibly establishing, asserting and enforcing claims or defending against claims, preventing abuse and fraud, detecting cases of unauthorized use of services, ensuring IT security of the Wiphly platform, financial analysis of the Administrator, responding to inquiries and messages from Users, conducting statistics and performing analytical studies and tests in order to better select services to the User’s needs or optimize processes, performing profiling aimed at best matching the information sent to the User’s needs and interests, storing data for archiving purposes and ensuring accountability, processing data for statistical purposes.
§3
Scope of processing of Personal Data and the period of its processing
- The Administrator may process User Personal Data of the following categories:
- Identification data (e.g., name, ID on social networks),
- contact information (e.g., email address),
- location data (e.g., the location of the device, the place where the audiovisual material was created),
- technical data (e.g. data on the device on which you use the Application, Advertisment ID).
- Users’ personal data will be kept for the period of providing the Services, unless a longer processing period is stipulated by law.
- Personal data is obtained directly from the User, among other things, placed in forms or by entering proofs of purchase or loyalty cards into the Application. Some data is of an exploitative nature and is recorded in the system when the User uses the Application. Some of the data may be obtained from portals that the User uses to integrate the account in the Application with the account on other portals.
- Data processing may involve certain algorithms, but we do not make fully automated decisions that may have a significant or legal impact on you without your explicit consent or as otherwise permitted by law.
§4
User Privileges
- Each User has the right of access to the content of their data and the right to rectify, delete, limit processing, the right to data portability, the right to object, the right to withdraw consent at any time without affecting the lawfulness of the processing carried out on the basis of consent before its withdrawal.
- Each User has the right to lodge a complaint with the President of the DPA if he/she considers that the processing of personal data concerning him/her violates the provisions of the General Data Protection Regulation of April 27, 2016.
§5
Transfer and Sharing of Personal Data
- The Administrator may transfer or share Personal Data with third parties in the event that:
- the user agrees to it or
- it will be justified by law or
- it will be necessary in order to provide and perform the contract.
- In the above cases, Personal Data will be transferred on the basis of an entrustment agreement for the processing of Personal Data, unless such obligation is excluded by law. The entrustment of the processing of Personal Data in the situation described in the first sentence will ensure the protection of Personal Data in accordance with the Personal Data Protection Act at a level at least equal to the safeguards applied by the Administrator.
- Data may be entrusted to, among others, the following categories of recipients of personal data:
- entities providing services to the Administrator, including accounting, legal services;
- Software providers, including analytics software,
- Application content providers, including with the use of their software.
§6
Users’ rights
- The Administrator shall provide the User with the possibility of deleting his/her Personal Data from the Dataset at his/her request, as well as in other cases, based on the provisions of applicable law.
- The Administrator may refuse to delete Personal Data if the User has not paid all amounts due to the Administrator or has violated the Regulations or applicable laws, and the preservation of Personal Data is necessary to establish the User’s responsibility.
- Each User has the ability to view and edit his/her Personal Data, at any time, within the functionality of the Application, after logging in with an email address and password.
Contact:
CodeAgency.pl Ltd.
Królowej Jadwigi 18
85-231 Bydgoszcz
e-mail: support@codeagency.pl