Privacy Policy — SafeMe App

General provisions

1. This Privacy Policy sets out how personal data necessary for the provision of services by electronic means via the mobile app operating under the name SafeMe (hereinafter: SafeMe) is collected, processed and stored.

2. The controller of Users’ personal data is SFM SOFT SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, KRS 0001024285, NIP: 5273046788, UL. JANA KAZIMIERZA 64/128, 01-248 WARSZAWA, Poland, e-mail: biuro@safeme.pl (hereinafter: the Controller).

3. Personal data is processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of 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 (General Data Protection Regulation) (hereinafter: GDPR).

4. Data collected by the Controller will be:

• a) processed lawfully,
• b) processed for specified, explicit purposes and not further processed in a manner incompatible with those purposes,
• c) accurate and relevant in relation to the purposes for which it is processed,
• d) kept for no longer than is necessary to achieve the purpose of processing.

5. Accepting this Privacy Policy is a necessary condition for using its functionality, which means that if the user does not accept it, they will not be able to use the app.

6. The Controller will process personal data to the extent set out in this Privacy Policy. This data is necessary for the app to function properly and for access to the services. The categories of data include, in particular:

• a) first and last name,
• b) profile photo,
• c) height,
• d) hair colour,
• e) body type,
• f) phone number,
• g) e-mail address,
• h) the User’s location, determined from the phone’s GPS data.

7. Depending on the mobile platform, the apps may request access to the following permissions on the mobile device:

• a) running in the background,
• b) device location information,
• c) access to the microphone and camera.

8. The information listed in point 6 will be collected and used as follows:

• a) the personal data in point 6(a)–(g) is used to ensure quick contact with the user and to make it easier to identify them, in order to provide fast support in the event of a call for help,
• b) the user’s location data is sent only at the moment when the user orders SafeMe to observe them or calls for help. It is used for the safety supervision of the User and to direct the appropriate services to the User’s location, where necessary.

9. The app running in the background allows the service ordered by the user via the mobile app to be performed.

10. Communication between the mobile app and the SafeMe service uses encryption mechanisms.

11. Depending on the mobile app, app permissions can be revoked by changing the device’s system settings or by uninstalling the app.

1. Purpose and legal basis for data processing

1. The Controller processes personal data necessary to provide and develop the services available via the SafeMe app and its individual functionalities.

2. Personal data will be processed for the following purposes:

• a) account registration, verification of the User’s identity, and performance of the agreement for the provision of services by electronic means in accordance with the Polish Act of 18 July 2002 on the Provision of Services by Electronic Means, including in particular by enabling the use of an individual User account — on the basis of acceptance of the Terms (Article 6(1)(b) GDPR);
• b) communicating with the User in order to provide them with necessary information and to build a positive and reliable relationship with them, which constitutes the Controller’s legitimate interest (Article 6(1)(f) GDPR);
• c) the Controller promoting its own products and/or services and those of its Partners by sending marketing information (newsletter) by electronic means, provided the User has consented to receiving such communications by e-mail or via the app (Article 6(1)(a) GDPR);
• d) providing access to information about news from the industry directly related to the Controller’s business, provided the User has consented to receiving such communications by e-mail or via the app (Article 6(1)(a) GDPR);
• e) for analytical and statistical purposes, on the basis of the Controller’s legitimate interest in verifying Users’ activity and preferences in order to optimise the SafeMe app’s services, products and functionality (Article 6(1)(f) GDPR);
• f) the potential establishment, pursuit or defence of claims, on the basis of the Controller’s legitimate interest in protecting its rights (Article 6(1)(f) GDPR).

3. In each of the cases listed above (point 2), providing the data is voluntary, but necessary to conclude the agreement or to use other functionality of the Service.

2. Personal data retention period

1. Personal data will be processed for the period during which a person remains an active User of the SafeMe app (has a User account), and after that time for the period necessary to maintain compliance with the law, and to pursue or defend against potential claims, but no longer than 3 years from the date the agreement for the provision of services by electronic means is terminated.

2. Data processed on the basis of consent will be processed until the consent given is withdrawn, provided that withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

3. We store users’ data only for the period necessary to achieve the purposes for which it was collected, in accordance with applicable law. After the provision of services ends, or at the user’s request, data is deleted securely or anonymised, so that it can no longer be identified. Where data needs to be kept for a longer period for legal or regulatory reasons, it is archived in a manner compliant with security requirements. We regularly review the data we store to ensure it remains up to date and compliant with the Privacy Policy.

3. Information about processing

1. Depending on the purpose of processing, personal data may be disclosed to:

• a) entities affiliated with the Controller,
• b) entities cooperating with the Controller,
• c) subcontractors, in particular entities supplying and operating selected IT systems and solutions,
• d) entities handling online payments,
• e) entities providing courier and postal services,
• f) law firms.

2. Personal data processed by the Controller will not be transferred outside the European Economic Area or to international organisations.

3. We take care of the security of our users’ personal and sensitive data, applying appropriate technical and organisational measures that protect it against unauthorised access, loss, alteration or disclosure. Our procedures include data encryption, access control, regular security audits and staff training. All data is processed in accordance with applicable law, and its use is limited solely to purposes necessary for the provision of our services.

4. Rights of data subjects

1. App users have the right:

• a) to access the content of their personal data,
• b) to rectify their data,
• c) to erase their data,
• d) to restrict the processing of their data,
• e) to data portability,
• f) to object to processing carried out on the basis of the Controller’s legitimate interest,
• g) to withdraw consent at any time, without affecting the lawfulness of processing carried out on the basis of that consent before it was withdrawn.

2. Users have the right to lodge a complaint with the President of the Personal Data Protection Office (UODO) if they believe that the processing infringes their rights and freedoms.

3. The data processing does not involve automated decision-making, including profiling.

5. Privacy contact point

1. If you have any questions regarding the processing of personal data, privacy protection, or wish to exercise your rights, please contact our privacy contact point at: biuro@safeme.pl. We will respond to your enquiry as soon as possible, no later than within the period provided for by applicable law.

6. Final provisions

1. The Controller reserves the right to make changes to this Privacy Policy, while ensuring that Users’ rights under this document will not be restricted.

2. Users will be informed of any changes to the Privacy Policy via a notice available in the Service.