Privacy Policy
DRAFT — English translation of the Polish draft; the Polish version is binding. To be reviewed by a lawyer before publication. Fields
[[…]]to be completed.
Version: 0.1 (draft) · Effective from: [[date]]
1. Controller
The controller of personal data is [[company name]], [[address]], [[tax / registration number]] ("we").
Data protection contact: [[e-mail address]]. [[Data Protection Officer: not appointed / DPO details.]]
2. In short
- An account needs only an email address. There are no passwords — you sign in with a code sent by email.
- We do not use advertising analytics, show ads, sell data or track you across other apps.
- We keep your progress and settings so the app works on all your devices.
- You can delete your account yourself, in the app, at any time.
- Data is stored on servers in the European Union (
[[Frankfurt]]).
3. What data, why, on what basis, for how long
| data | purpose | legal basis (GDPR) | retention |
|---|---|---|---|
| email address | account, sign-in, account messages (codes, terms changes, security) | contract (Art. 6(1)(b)) | until account deletion |
| sign-in codes (hashed), time and number of attempts | sign-in, protection against guessing | contract; legitimate interest — security (f) | minutes |
| session id, device id, platform, push token | keeping you signed in, notifications you enable | contract | until sign-out / account deletion |
| course progress, favourites, settings | app functionality, sync between devices | contract | until account deletion |
| referral code, referral link, commissions, payout details | referral programme and its settlement | contract; legal obligation — accounting (c) | until account deletion; accounting records [[5 years]] |
| subscription purchase details (store transaction id, plan, status) | access to paid content, "Restore purchases", complaints | contract | until account deletion; accounting records [[5 years]] |
| server logs: IP address, time, path, device id | security, abuse detection, diagnostics | legitimate interest (f) | [[30]] days |
| correspondence with us | replying, proof of handling | contract; legitimate interest | [[3 years]] |
We do not profile you or make automated decisions with legal effects. You can use the app as a guest without giving any data — settings then stay on your device only.
4. Recipients
Only processors acting on our behalf under a data processing agreement: [[Amazon Web Services EMEA SARL]]
(hosting, EU), [[email provider]] (sign-in codes and account messages), Google (Firebase Cloud Messaging) and
Apple (APNs) for push notifications you enable, Google Play and Apple App Store for subscriptions (we never see
card details). Public authorities where the law requires it. We do not sell data or share it with advertisers.
5. Transfers outside the EEA
Data is stored in the EEA. It leaves the EEA only for push notifications and store purchases, based on
[[an adequacy decision (EU-US Data Privacy Framework) / standard contractual clauses]].
6. Your rights
You have the right of access, rectification, erasure, restriction, portability, objection to processing based on legitimate interest, and to withdraw consent.
- Delete your account and data: in the app, Profile → Delete account — immediately. If you uninstalled the
app:
[[/legal/usun-konto]]. - Copy of your data: write to
[[e-mail address]]; we reply within[[30]]days. - Complaint: the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw,
Poland (
uodo.gov.pl), or the supervisory authority in your country.
7. Security
Connections are encrypted (TLS). Sign-in codes are stored hashed. Server access is limited to people who need
it, with [[two-factor]] authentication. Database backups are encrypted and kept in the same region.
8. Children
The app is intended for people aged [[16]]+. We do not knowingly collect data of younger people.
9. Cookies and local storage
The mobile app uses no cookies. The web version uses only storage strictly necessary to work (session,
settings, downloaded content), so no consent banner is shown. [[Update if analytics is ever added.]]
10. Changes
We will announce material changes in the app and by email [[14]] days in advance. The current version is
always at [[/legal/prywatnosc]].
regulamin · polecenia · usun-konto · zasady-tworcow · zasady-tresci