GDPR Information Obligation

The following information is a concise, clear, and transparent summary of the information provided in the Privacy Policy regarding the Data Controller, purposes, and methods of personal data processing, and your rights related to this processing, presented as required to fulfill the GDPR information obligations. Detailed information on data processing methods and entities involved is available in the mentioned policy.

§1. Who is the Data Controller?

The Personal Data Controller (hereinafter: Controller) is the company "Twojapka", conducting business at the address: (online), with Tax Identification Number (NIP): PL6443581559, providing electronic services through the Website.

§2. How can you contact the Data Controller?

You can contact the Controller in one of the following ways:

• Postal address - kontakt@twojapka.pl
• Email address - kontakt@daqcreator.pl | kontakt@twojapka.pl
• Phone number - +48 507 677 767
• Contact form - available at: /en/contact

§3. Has the Controller appointed a Data Protection Officer?

In accordance with Art. 37 GDPR, the Controller has not appointed a Data Protection Officer.

In matters regarding data processing, including personal data, please contact the Controller directly.

§4. Where do we obtain personal data and what are their sources?

Data is collected from the following sources:

• directly from data subjects.

§5. What is the scope of personal data we process?

The Website processes ordinary personal data, voluntarily provided by data subjects.

A detailed scope of processed data is available in the Privacy Policy.

§6. What are the purposes of our data processing?

Personal data voluntarily provided by Users is processed for the following purposes:

• Execution of electronic services.
• Communication between the Controller and Users regarding the Website and data protection.
• Ensuring the legitimate interest of the Controller.

§7. What are the legal bases for data processing?

The Website collects and processes Users' data based on:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding personal data processing and the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation - GDPR):
  • Art. 6(1)(a)

    the data subject has given consent to the processing of his or her personal data for one or more specific purposes

  • Art. 6(1)(b)

    processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract

  • Art. 6(1)(f)

    processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party

• Personal Data Protection Act of May 10, 2018 (Journal of Laws 2018, item 1000)
• Telecommunications Act of July 16, 2004 (Journal of Laws 2004, No. 171, item 1800)
• Act on Copyright and Related Rights of February 4, 1994 (Journal of Laws 1994, No. 24, item 83)

§8. What is the legitimate interest pursued by the Controller?

• For the purpose of establishing, asserting, or defending against claims – the legal basis for processing is our legitimate interest (Art. 6(1)(f) GDPR) in protecting our rights;
• Assessing the risk associated with potential clients;
• Evaluating planned marketing campaigns;
• Conducting direct marketing.

§9. How long do we process personal data?

Generally, the indicated personal data is stored only for the period of service provision through the Website by the Controller. They are deleted or anonymized within 60 days after the end of the service provision (e.g., user account deletion, newsletter unsubscription, etc.).

In exceptional situations, to protect the Controller's legitimate interests, this period may be extended. In such cases, the Controller will store the indicated data from the time of the User's request for deletion, but no longer than 3 years in case of violation or suspicion of violation of the Website's terms by the data subject.

§10. Who are the recipients of the data, including personal data?

In principle, the only recipient of the data is the Controller.

Data processing may, however, be entrusted to other entities providing services for the Controller in maintaining the Website's activities.

Such entities include, but are not limited to:

• Hosting companies providing hosting or related services for the Controller.

§11. Will your personal data be transferred outside the European Union?

Personal data is transferred outside the European Union.

Transfer outside the EU occurs due to the use of services provided by entities located outside the EU or as a result of publication by individual User actions (e.g., posting a comment or entry), making data available to every visitor to the Website.

In the event of transferring or entrusting data processing outside the EU, data is processed based on an agreement between the Controller and the Service Provider.

§12. Will personal data be used for automated decision-making?

Personal data will not be used for automated decision-making (profiling).

§13. What rights do you have concerning personal data processing?

• Right of access to personal data
  Users have the right to access their personal data upon request made to the Controller.

• Right to rectification of personal data
  Users have the right to request the Controller to promptly rectify inaccurate personal data or complete incomplete personal data upon request.

• Right to erasure of personal data
  Users have the right to request the Controller to promptly delete personal data.

  For user accounts, data deletion involves anonymization of data identifying the User.

  For the Newsletter service, Users can independently delete their personal data via the link provided in each email.

• Right to restrict personal data processing
  Users have the right to restrict personal data processing in cases indicated in Art. 18 GDPR, including data accuracy disputes, upon request to the Controller.

• Right to data portability
  Users have the right to receive their personal data in a structured, commonly used, machine-readable format upon request to the Controller.

• Right to object to personal data processing
  Users have the right to object to the processing of their personal data in cases specified in Art. 21 GDPR upon request.

• Right to lodge a complaint
  Users have the right to lodge a complaint with the supervisory authority responsible for data protection.