Privacy Policy

PERSONAL DATA PROCESSING POLICY ON THE WEBSITE

This policy is here to tell you about our rules. It’s mostly about how the website manager uses your personal data. We explain why we need your data, what we do with it, and how much of it we use. We also talk about your rights when it comes to your data. Plus, we tell you about how we use cookies and tools to analyze data on our website. 

§1 DEFINITIONS
  1. Administrator – SafeApps Sp. z o.o., ul. Mickiewicza 10/2, 60-836 Poznań, Poland NIP: PL781204421 referred to as either “SafeApps Sp. z.o.o”, “We”, “Us” or “Our” in this Agreement)
  2. Personal data – all information about an individual who is identified or identifiable by one or more specific factors defining physical, physiological, genetic, mental, economic, cultural, or social identity, including image, voice recording, contact information, location data, information contained in correspondence, information collected through recording equipment or other similar technology. rding equipment or other similar technology.
  3. Policy – this Personal Data Processing Policy.
  4. GDPR – Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC. 
  5. Data subject – any individual whose personal data is processed by the Administrator.
§2 HANDLING YOUR DATA 
  1. In running our business, we gather and handle personal data. We do this following the proper rules, especially those set out in the GDPR, and the data processing guidelines it provides. 
  2. We make sure to be open about how we handle data. This means we always let you know when we’re gathering your data, and why, and on what legal grounds. For example, if we’re making a sales deal for goods or services. We make sure to only gather as much data as we need for the purpose we told you about, and only keep it as long as we need to. 
  3. As we handle your data, we ensure its safety and privacy, and provide information about the processing to those whose data it concerns. If something goes wrong despite our safety measures, like a data leak or data loss, we’ll let those whose data is affected know about it following the rules. 
§3 GETTING IN TOUCH WITH US
  1. If you need to contact us, you can email us at hello@sequrify.io or send us a letter to: SafeApps Sp. z o.o., ul. Mickiewicza 10/2, 60-836 Poznań, Poland NIP: PL7812044215. 
  2. We haven’t assigned a Data Protection Officer. 
§4 PERSONAL DATA SECURITY
  1. We work hard to keep your personal data safe and private. We’ve put in place procedures that make sure only authorized people can access your data, and only as much as they need to for their tasks. We use both organization and technical solutions to make sure all actions on personal data are recorded and done only by authorized people. 
  2. We also do everything necessary to make sure that our subcontractors and other cooperating entities guarantee the use of proper security measures whenever they handle personal data on our behalf. 
  3. We’re always checking on the risks and making sure our data security is up to scratch. If we need to, we’ll put in extra measures to make your data even safer. 
§5 WHY AND ON WHAT GROUNDS WE PROCESS YOUR DATA
  1. We process the personal data of everyone who uses our online services. This includes IP addresses or other identifiers and information collected through cookies or other similar technologies. Here’s why we do this: 
    a). To provide electronic services, like making available the content gathered on the site. The legal basis for this processing is the necessity of processing for the performance of the contract (Article 6 (1) (b) GDPR). 
    b). For analytical and statistical purposes. The legal basis for this processing is our legitimate interest (Article 6 (1) (f) GDPR) in analyzing user activity and preferences to improve the functionalities and services we offer. 
    c). If needed, to establish, pursue, or defend against claims. The legal basis for this processing is our legitimate interest (Article 6 (1) (f) GDPR) in protecting our rights. 
    d). For marketing purposes, both by us and by others. The rules for processing personal data for marketing purposes are described in the “Marketing” section below. 
  2. We record user activity on our website, including personal data, in system logs. System logs are a special computer program that keeps a chronological record of events and actions related to the IT system we use to provide our services. We mainly process the information collected in the logs in connection with providing services. We also use it for technical and administrative purposes, to ensure the security of the IT system, to manage this system, and for analytical and statistical purposes. In this respect, the legal basis for processing is our legitimate interest (Article 6 (1) (f) GDPR). 
§6 MARKETING
  1. We use user personal data to carry out marketing activities. These can include: 
    a) Showing users marketing content that isn’t tailored to their preferences (contextual advertising). 
    b) Showing users marketing content that matches their interests (behavioral advertising). 
    c) Conducting other types of activities related to direct marketing of goods and services (sending commercial information electronically and telemarketing activities). 
  2. In some cases, we use profiling for our marketing activities. This means that through automatic data processing, we evaluate certain factors about individuals to analyze their behavior or make future predictions. The legal basis for this data processing is our legitimate interest (Article 6 (1) (f) GDPR). 
§7 COOKIES AND SIMILAR TECHNOLOGIES
  1. Cookies are small text files installed on the device of the user visiting the website. Cookies collect information that makes it easier to use the website, for instance, by remembering the user’s visits to the site and the actions they take. The legal basis for processing such data is the Administrator’s legitimate interest (Article 6 (1) (f) GDPR). 
  2. We mainly use cookies to provide users with services offered electronically and to improve the quality of these services. Thus, we and other entities providing analytical and statistical services on our behalf use cookies, storing information or gaining access to information already stored in the user’s end telecommunication device (computer, phone, tablet, etc.). The cookies used for this purpose include: 
    a). Cookies with data entered by the user (session identifier) for the duration of the session (user-input cookies); 
    b). Authentication cookies used for services requiring authentication for the duration of the session (authentication cookies); 
    c). Security cookies, for instance, those used to detect authentication abuses (user-centric security cookies); 
    d). Session cookies of multimedia players (for example, flash player cookies), for the duration of the session (multimedia player session cookies); 
    e). Persistent cookies for personalizing the user interface for the duration of the session or slightly longer (user interface customization cookies); 
    f). Cookies used to monitor traffic on the website, i.e., data analytics, including Google Analytics cookies. These are files used by Google to analyze how a user uses the service, to create statistics and reports on the operation of the service. The Google Analytics tool also serves to direct behavioral advertising to users. Google does not use the collected data to identify the user or link this information to enable identification. Detailed information about the scope and rules of data collection in connection with this service can be found by typing into any internet search engine: Google- Privacy and Terms. 
§8 ONLINE CONTACT FORMS
  1. We’ve got contact forms on our website, which make it super easy for you to reach out to us. If you want to use these forms, you’ll need to tell us a few personal details. This way, we can get back to you and answer your questions. Some details are really important and without them, we won’t be able to deal with your inquiry. But sharing other information is totally up to you. 
  2. What do we do with the information you give us? 
    We first use it to figure out who is reaching out and handle your request or respond to your questions sent through the contact form. We’re allowed to do this because of something called “legitimate interest” (Article 6(1)(f) of the General Data Protection Regulation (GDPR)). It just means that it’s important for us to respond to requests and answer questions, especially from those who are interested in what we do. 
    We also use this information to keep track of our service quality and to look for ways to make it even better. This is also under the same “legitimate interest” (Article 6(1)(f) of the GDPR). It helps us ensure we’re always improving the services we provide to you. 
§9 EMAIL AND TRADITIONAL MAIL
  1. If you send us an email or a letter, we will only use your personal details included in that correspondence to communicate with you and handle the issue your message is about. 
  2. This processing is based on our legitimate interest (Article 6(1)(f) of the General Data Protection Regulation (GDPR)), which is to manage correspondence sent to us due to our business activities. 
  3. We only process personal data relevant to the issue your correspondence is about. All correspondence is stored in a way that ensures the safety of the personal data (and other information) contained in it, and it is only disclosed to authorized individuals. 
§10 PHONE CONTACT
  1. If you contact us by phone, we may ask you to provide personal data only if it’s necessary to handle the issue you’re calling about. The legal basis for this is our legitimate interest (Article 6(1)(f) of the General Data Protection Regulation (GDPR)), which is to manage requests and answer questions asked by people interested in our services. 
  2. We may also record phone calls. If we do, we’ll tell you at the start of the call. We record calls to monitor the quality of our service and to check how our consultants are doing. These recordings are only accessible to our staff and the people managing our helpline. The legal basis for this processing is our legitimate interest (Article 6(1)(f) of the GDPR) in being able to improve the quality of the services we provide. 
§11 SOCIAL MEDIA

We process the personal data of users who visit our profiles on social media platforms (Facebook, YouTube, Instagram, Twitter). We only process this data in connection with running our profiles, including to let users know about our activities and to promote various events, services, and products. The legal basis for this processing is our legitimate interest (Article 6(1)(f) of the GDPR), which is to promote our own brand. 

§12 COLLECTION OF DATA IN OTHER CASES
  1. In relation to our business activities, we also collect personal data for the purposes of initiating and maintaining business contacts. The legal basis for this processing is our legitimate interest (Article 6(1)(f) of the GDPR), which is to build a network of contacts in connection with our activities.  
  2. We only process personal data collected in these cases for the purpose for which they were collected and we ensure their adequate protection. 
§13 DATA RECIPIENTS
  1. As part of our operations that require processing personal data, this data is disclosed to external entities, in particular to providers responsible for the operation of our IT systems and equipment, entities providing legal or accounting services, couriers, marketing agencies, and recruitment agencies. The data may also be disclosed to selected partners, for example in the case of promotional campaigns joined by the individual concerned. 
  2. We reserve the right to disclose selected information about the individual concerned to competent authorities, services, or third parties who request such information, based on an appropriate legal basis and in accordance with applicable law. 
§14 TRANSFER OF DATA OUTSIDE THE EEA
  1. The level of personal data protection outside the European Economic Area (EEA) differs from that provided by European law. Therefore, we only transfer personal data outside the EEA when necessary and with the assurance of an adequate level of protection, primarily through: 
    a). cooperating with entities processing personal data in countries for which a relevant decision of the European Commission has been issued; 
    b). using standard contractual clauses issued by the European Commission; 
    c). using binding corporate rules approved by the competent supervisory authority; 
    d). in the case of data transfers to the USA – cooperating with entities participating in the Privacy Shield program approved by a decision of the European Commission. 
    e). We always inform about the intention to transfer personal data outside the EEA at the stage of collecting these data. 
§15 TIME WE KEEP YOUR DATA
  1. How long we keep your data depends on what we’re using it for and why we need it. Sometimes, legal rules tell us how long we have to keep information. For example, if we’re using your data because we have a good reason to (like keeping things secure), we keep it for as long as we need to achieve that goal or until you tell us you don’t want us to. If you gave us permission to use your data, we’ll keep it until you change your mind and tell us not to. If we’re using your data because we need it to make a contract work, we keep it until that contract ends. 
  2. Sometimes, we might keep your data longer if we need it to sort out a problem or defend ourselves. After this, we’ll only keep it if the law says we have to. When we no longer need your data, we’ll either erase it completely or make sure it can’t be linked back to you. 
§16 YOUR RIGHTS ABOUT YOUR DATA
  1. If we’re using your data, you have the following rights: 
    a). Right to know – You can ask us for information about what we’re doing with your data. We’ll tell you why and how we’re using it, what kind of data we have, who we’re sharing it with, and when we plan to delete it. 
    b). Right to get a copy – You can ask us for an electronic copy of your data that we’re using. 
    c). Right to correct – If we have any wrong or incomplete data about you, you can ask us to correct or complete it. 
    d). Right to erase – If we don’t need your data for any of the reasons we collected it, you can ask us to delete it. 
    e). Right to limit – If you ask us to, we’ll stop doing things with your data. But we’ll keep it stored according to our rules or until we’re allowed to start using it again (for example, if a supervisory authority says it’s okay). 
    f). Right to transfer – You can ask us to give you your data in a computer-readable format if we’re using it because of a contract or your consent. You can also ask us to send it to someone else, as long as it’s technically possible for us and them to do this. 
    g). Right to object (marketing) – You can tell us to stop using your data for marketing at any time. You don’t need to give a reason. 
    h). Right to object (other) – You can tell us to stop using your data for other reasons, like analyzing or protecting our property. You need to give us a reason for this. 
    i). Right to withdraw consent – If we’re using your data because you’ve given us your permission, you can take that permission back at any time. This doesn’t affect the legality of our use of your data before you withdrew your consent. 
    j). Right to complain – If you think we’re not handling your data properly, you can complain to the President of the Office for Personal Data Protection. 
§17 SUBMITTING REQUESTS RELATED TO THE EXERCISION OF RIGHTS
  1. If you want to exercise any of your rights concerning your data, you can submit a request: 
    a) In writing to the following address: SafeApps Sp. z o.o., ul. Mickiewicza 10/2, 60-836 Poznań, Poland NIP: PL7812044215 
    b) Via email to: hello@sequrify.io 
  2. If we can’t figure out who’s making the request based on the information provided, we’ll ask for additional details. 
  3. You can make the request yourself, or through a representative (like a family member). For the safety of your data, we suggest using a power of attorney, preferably certified by a notary or authorized lawyer. This significantly speeds up the verification process. 
  4. We’ll respond to your request within a month from when we receive it. If for some reason we need more time, we’ll let you know why. 
  5. We usually respond through traditional mail, unless the request was submitted by email or you ask for an electronic response. 
§18 CHARGING PRINCIPLES
  1. Processing your requests is generally free. However, charges may apply in the following cases: 
    a) If you request a second or any subsequent copies of your data (the first copy is free). In this case, we might charge a fee of 50 PLN. This fee covers the administrative costs of fulfilling your request. 
    b) If the same person makes excessive (e.g., unusually frequent) or evidently unfounded requests. In this case, we may charge a fee of 150 PLN.  
  2. This fee covers the costs of communication and action related to your request. 
  3. If you disagree with the decision to charge a fee, you can lodge a complaint with the President of the Personal Data Protection Office. 
§19 CHANGES TO THE PERSONAL DATA PROCESSING POLICY

We regularly update and review this policy. 

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