Privacy Policy

Last updated: March 26, 2026

General Provisions
General Provisions
Scope and Purpose of Data Collection
Social Networks
Processing Period
Voluntary Data Provision
Trafficwatchdog Rights and Obligations
Data Processors
Subject Rights
Data Security
Final Provisions
Contact
Downloads

I. General Provisions

  1. This Privacy Policy of the TrafficWatchdog.pl service (hereinafter: the "Service"), owned by Spark DigitUP Sp. z o.o. with its registered office in Kraków, Plac Wolnica 13 lok. 10, 31-060 Kraków (hereinafter: "Trafficwatchdog") is addressed to users of the Service (hereinafter: "User"), including clients and potential clients of Trafficwatchdog (hereinafter: "Customer"), and also, in the event the Customer concludes an agreement with Trafficwatchdog for the provision of electronic services – to their Users (hereinafter: "Customer's Users"), employees or other persons used by the customer, whose data was provided to Trafficwatchdog by the customer, and specifies the type, scope, ways of using personal data, rights and obligations of the User, and the security of personal data. Using the Service implies reading and accepting this Privacy Policy. Providing personal data is voluntary, but necessary to provide electronic services or ensure the proper functioning of the Service; failure to provide data may prevent the use of specific functionalities.
  2. The controller of Users' personal data (hereinafter: "Personal Data") is Spark DigitUP Sp. z o.o. with its registered office in Kraków, Plac Wolnica 13 lok. 10, 31-060 Kraków, NIP 6762496391, registered in the District Court for Kraków-Śródmieście, XI Commercial Division of the National Court Register under KRS number 0000587711, REGON 363042916, share capital PLN 205,000.00 fully paid up. Contact with the controller is possible via the e-mail address: kontakt@trafficwatchdog.pl, the contact form available on the website: Click here, or in writing to the controller's registered office address indicated above.
  3. In specific cases when Customers use the services offered by Trafficwatchdog, it acts as a processor of Customer's Users' personal data, meaning it processes personal data on behalf of and by the order of the personal data controller. This relationship is regulated in the Trafficwatchdog Service Terms of Service (Click here).
  4. Personal Data referred to in the Privacy Policy is information about an identified or identifiable natural person to whom the data relates, i.e., one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  5. Personal Data – is processed by Trafficwatchdog in accordance with applicable regulations, in particular Polish law and 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").
  6. Processing, within the meaning of the Privacy Policy, means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation.
  7. The User may browse the Service without having to enter their Personal Data into the Service or having to register, subject to the provisions of point II.1.a. below ["Automatically collected data"].

II. Scope, Purpose, and Basis of Collecting and Processing Personal Data

  1. Trafficwatchdog collects and processes the data of Users and Customer's Users when they use:
    1.1. the Trafficwatchdog Service and services available on the Trafficwatchdog Service,
    1.2. the Client's Website and services available on the Client's Website provided by Trafficwatchdog based on a concluded Cooperation Agreement,
    1.3. services offered by Trafficwatchdog for Customers based on a concluded Cooperation Agreement:
    1. When the User uses the Trafficwatchdog Service or a Client's Website cooperating with Trafficwatchdog based on a concluded Cooperation Agreement, data concerning the User and their visits is automatically collected and processed. This data includes: IP address, cookies, basic information about the computer device used to access the Service, identifier assigned to the device from which visits are generated, end device parameters, operating system parameters, browser parameters, general geographical location of the visit, method of interaction of the potential User with the Service and activity data in the Service, time in the Service, HTTP header parameters, marketing campaign parameters, data regarding visited web pages, URLs of visited pages, date and time of the visit. We process this data in order to:
      1. ensure the proper functioning of the Service (e.g. session maintenance, error diagnostics, request handling),
      2. ensure Service security and prevent abuse and unauthorized access attempts,
      3. conduct statistics and analytics (provided the User consents to analytical cookies),
      4. perform marketing activities (provided the User consents in the privacy settings in the Service or Client's Website).
      The legal basis for processing is respectively: Article 6(1)(f) GDPR (legitimate interest of the Controller – security and proper functioning of the Service) and Article 6(1)(a) GDPR (consent – analytics/marketing, if applied).
      We store personal data from User visits for up to 3 months from the visit, unless their further processing is justified by another legal basis (e.g. performance of an agreement with a customer, complaint, or legal obligations). After this period, data will be permanently deleted or anonymized. In connection with the use of third-party solutions, visit data may be transferred to our trusted subcontractors located outside the European Economic Area (e.g. Google LLC, USA). However, we assure that in such cases the transfer is carried out in accordance with GDPR requirements – based on standard contractual clauses concluded with these entities and approved by the European Commission, and the data is adequately protected.
    2. When the User uses Chat AI or a Chat Bot on the Trafficwatchdog Service or Client's Website, cookies and contact data provided by the User during the conversation may be collected and processed, such as: name, surname, email, phone number, social media account data. This data is collected and processed in order to handle User inquiries and provide them with appropriate support. During a conversation conducted by Chat AI, the content of the message and provided data may be processed automatically by external artificial intelligence systems (e.g. Open AI, USA; Google LLC, USA) in order to answer the User's query. We cooperate with AI service providers as processors – they process conversation data exclusively to provide an answer, based on our instructions and data processing agreement.
      The legal basis for processing this data is Article 6(1)(b) GDPR (taking steps at the request of the User prior to entering into a contract or performance of a contract – inquiry handling) or Article 6(1)(f) GDPR (legitimate interest of the Controller – communication and handling of requests), depending on the nature of the contact.
      We store conversation data conducted by Chat AI or Chat Bot for the duration of handling the request and maximally up to 3 months from the end of the conversation, and then for the period necessary to defend or pursue any claims. After this period, data will be permanently deleted or anonymized.
      Saving the conversation history takes place with the User's consent expressed by using the Chat AI or Chat Bot service. The User has the right to request access to their saved conversation history, rectify it, delete it, or restrict processing.
      In connection with the use of AI-based chat solutions, conversation data (including provided personal information) may be transferred to our trusted subcontractors located outside the European Economic Area (e.g. Open AI, USA; Google LLC, USA). However, we assure that in such cases the transfer is carried out in accordance with GDPR requirements – based on standard contractual clauses concluded with these entities and approved by the European Commission, and the data is adequately protected.
    3. When the User uses the Voice Assistant AI on the Trafficwatchdog Service and Trafficwatchdog hotline or on the Client's Website and Client's hotline - User's voice conversations are recorded and processed. The scope of processed data includes the recording of the User's voice (audio) and a text transcription of the conversation. This data is used for two purposes: (a) providing the Assistant service – i.e. speech recognition and providing the User with answers to their questions, and (b) improving service quality and understanding customer needs – i.e. analyzing recordings to enhance the AI assistant's operation and elevate service quality standards. The User acknowledges that the conversation is conducted with an assistant utilizing artificial intelligence (synthetic voice), not with a live consultant.
      The legal basis for data processing within the Voice Assistant AI is Article 6(1)(b) GDPR – necessity to perform the service at the User's request (speech recognition and assistant's reply), whereas to the extent that call recordings are analyzed after they end to improve the quality and functioning of our services – the legal basis is the legitimate interest of the controller (Article 6(1)(f) GDPR) consisting in improving offered services and ensuring the highest service standards.
      We store recordings of conversations with the Voice Assistant AI and their text transcriptions for no longer than 3 months from the day of the recording, unless their further processing is justified by another legal basis (e.g. execution of an agreement with a client, complaint, or legal obligations). After this period, data will be permanently deleted or anonymized. Call duration and the phone number itself are stored for a period of 12 months, unless further processing is justified by another legal basis (e.g., performance of a contract, a complaint, or legal obligations). After this period, the data will be permanently deleted or anonymized.
      Recording of conversations takes place with the User's consent expressed by using the service after hearing the announcement. The User has the right to request access to their recording, its rectification, deletion, or restriction of processing. They also have the right to withdraw their consent to recording at any time by ending the conversation and to object to the processing of their data for quality improvement purposes – which will result in the cessation of further processing for these purposes.
      As part of the Voice Assistant AI operation, personal data in the form of voice recordings and conversation transcriptions may be transferred to our data processors, in particular: Google (speech recognition and synthesis services) and Open AI (language model service generating the response). These entities may process data on our behalf exclusively for the above purposes. Due to the location of these providers (USA), data may be transferred outside the European Economic Area – always, however, on the basis of standard data protection clauses and applying appropriate safeguards required by GDPR.
    4. In the case of realizing selected services for Customers (such as Click Scanner, Affiliate Scanner, eSeller AI, Sales Bot, Ads Bot AI, Lead Bot AI, IT Agent AI, Blog Agent AI), we need to obtain access to the Customer's Google Ads, Google Merchant Center, Facebook account, or other Customer systems. This access is required to execute services for Customers defined in the product's scope. The scope of processed data may include the Customer's account identifier, contact details, and system data on the Customer's side. The legal basis for processing data is Article 6(1)(b) GDPR – necessity to perform the service at the Customer's request.
      Data retention period – data will be processed by us for the period necessary to achieve the above purpose, no longer than until an objection to processing is raised or consent is withdrawn, if such was granted.
    5. We may also process data obtained from public sources, e.g. from publicly available websites or other public registers containing information about business activities. The scope of processed data includes basic contact details. Purpose of processing – data is processed for the purpose of establishing B2B business relations and direct marketing carried out based on the legitimate interest of the controller (within limits permitted by law), as well as for the needs of maintaining and updating a database of commercial contacts, used when executing information and marketing campaigns, including those conducted on behalf of our clients or business partners. Legal basis for processing – legitimate interest of the data controller (Article 6(1)(f) GDPR), consisting in establishing and maintaining business contacts and conducting marketing activities to the extent compliant with the law.
      Data retention period – data will be processed by us for the period necessary to achieve the above purpose, no longer than until an objection to processing is raised or consent is withdrawn, if such was granted.
      Persons whose data obtained in this way relates to – have the right to access data, rectify it, delete it, restrict processing, transfer data, and the right to object to processing.
      Contact details obtained in this way may be transferred to our data processors, in particular: Google and Open AI. These entities may process data on our behalf exclusively for the above purposes. Due to the location of these providers (USA), data may be transferred outside the European Economic Area – always, however, on the basis of standard data protection clauses and applying appropriate safeguards required by GDPR. This data may also be transferred to entities providing technical or organizational services for us (e.g. hosting, mailing systems, legal consulting), strictly to the extent necessary to fulfill the purposes of processing.
    6. We use cookies and similar technologies on the Service. We use them primarily to: (i) ensure the operation of the Service and its functions, (ii) security, (iii) analytics/statistics, (iv) marketing – depending on the User's settings.
      Necessary cookies are used based on Article 6(1)(f) GDPR (legitimate interest – proper operation and security of the Service) and are required for the Service to function. Analytical and marketing cookies are used only if the User consents to it (Article 6(1)(a) GDPR).
      The User may change or withdraw their consent at any time via the consent management tool settings and via browser settings. Blocking necessary cookies may cause the Service to malfunction.
      Third-party cookies (e.g. analytics or advertising providers) may be used within the Service – in which case the rules of their operation and data processing arise from the privacy policies of these entities.
      A complete list of cookies collected and processed by us is available in the Cookie Policy (Click here)
  2. Data collected during registration and after logging into the Trafficwatchdog Service:
    1. Contact form - in the event the User completes the contact form on the Service, the following Personal Data is collected and processed: name, surname, email address, phone number, IP address. The data is collected and processed to contact the User and provide assistance to the User. The basis for this processing is Article 6(1)(f) GDPR (the Controller's legitimate interest consisting in handling correspondence and answering Users' inquiries) or Article 6(1)(b) GDPR (if the contact directly aims at concluding a contract or is related to it). If the User grants consent on the contact form to process their personal data for marketing purposes (by expressing appropriate consent), the User's data will then be collected and used for the purpose of presenting an offer, conducting competitions, and other marketing activities. If the User grants consent on the contact form to process their personal data in order to receive commercial information (by expressing appropriate consent), the User's data will then be collected and used to receive commercial information. The basis for this processing is Article 6(1)(a) GDPR.
      Data retention period – data will be processed by us for the period necessary to achieve the above purpose, no longer than until an objection to processing is raised or consent is withdrawn, if such was granted.
    2. Account registration in the service - according to the Service Terms of Service, a condition for the User to set up a Customer Account or Demo Account is registration and provision of User data – the following Personal Data is collected and processed: email address, password, IP address. The basis for this processing is Article 6(1)(b) GDPR.
      Data retention period – data will be processed by us for the period necessary to achieve the above purpose, no longer than until an objection to processing is raised or consent is withdrawn, if such was granted.
    3. Concluding contracts via or available in the Service – the following Personal Data is collected and processed: name and surname, address, NIP (Tax ID), email addresses, contact phone number. The basis for this processing is Article 6(1)(b) GDPR.
      Data retention period – data will be processed by us for the period necessary to achieve the above purpose, no longer than until an objection to processing is raised or consent is withdrawn, if such was granted.
    4. Fulfilling obligations regarding contracts concluded in the Service or via the Service and the functioning of the Service – the following Personal Data is collected and processed: name and surname, address, NIP (Tax ID), email addresses, contact phone number. The basis for this processing is Article 6(1)(b) GDPR.
      Data retention period – data will be processed by us for the period necessary to achieve the above purpose, no longer than until an objection to processing is raised or consent is withdrawn, if such was granted.
    5. Pursuing claims or defending against such claims related to the operation of the Service or services provided electronically – the following Personal Data is collected and processed: name and surname, address, NIP (Tax ID), email addresses, contact phone number. The basis for this processing is Article 6(1)(f) GDPR (the Controller's legitimate interest consisting in pursuing claims or defending against claims).
    6. Fulfilling the obligation regarding the storage of data, documents, accounting evidence – the following Personal Data is collected and processed: name and surname, address, NIP (Tax ID), email address, contact phone number. The basis for this processing is Article 6(1)(c) GDPR (legal obligation incumbent on the Controller). Data is stored for the period required by tax and accounting law.
    7. If the User transfers the personal data of third parties via the Service, they declare that they have a legal basis for sharing it with the Controller and that, to the extent required by law, they have fulfilled the information obligation towards these individuals.
  3. Users' Personal Data is not subject to automated decision-making, including profiling, which could produce legal effects concerning the User or similarly significantly affect them.

III. Social Networks

  1. The Service may contain links to external social networking sites (e.g., Facebook). Clicking a link creates a connection to the external service, and further data processing takes place according to the rules of that provider. Regarding the data processed by the social network, its provider acts as a separate data controller.

IV. Data Processing Period

  1. Personal Data collected in the Service will be stored as long as there is a legal basis for processing it, subject to shorter retention periods specified in detail in Chapter II (e.g. for call recordings or chat histories).
  2. If an Agreement for the provision of electronic services is concluded, Personal Data will be processed for the duration of that agreement, and subsequently as long as it arises from the legal provisions concerning the statute of limitations for claims arising from that agreement and until the expiration of the obligation to store data, documents, and accounting evidence resulting from applicable legal provisions.
  3. At the end of the retention period, Personal Data will be deleted or anonymized.

V. Voluntary Provision of Personal Data

  1. Providing Personal Data in the Service is voluntary, but necessary to fulfill one or more purposes of processing Personal Data defined in point II above.

VI. Trafficwatchdog Rights and Obligations

  1. Trafficwatchdog reserves the right to disclose selected Personal Data to competent authorities or third parties who submit a request for such information, based on an appropriate legal basis, in accordance with the provisions of applicable law.
  2. Trafficwatchdog may entrust the processing of Personal Data to entities providing services to Trafficwatchdog based on an agreement concluded in accordance with applicable regulations.

VII. Processing of Personal Data by Processors

  1. Processors within the meaning of the Privacy Policy are entities that process Personal Data on behalf of Trafficwatchdog.
  2. Personal Data may be processed in Poland, a Member State of the European Union (EU), or within a signatory to the European Economic Area (EEA) Agreement.
  3. When transferring data to third countries, the transfer takes place based on:
    1. an adequacy decision of the European Commission, or
    2. standard contractual clauses adopted by the European Commission, and if necessary, also additional security measures.
    The User may obtain a copy of the applied safeguards by contacting the Controller.
  4. Trafficwatchdog entrusts the processing of personal data to third parties solely on the basis of appropriate data processing agreements, strictly requiring them to ensure a high level of protection and data security, in accordance with Article 28 GDPR.
  5. The recipients of Personal Data may be trusted external entities providing services to Trafficwatchdog, in particular: hosting and cloud service providers, providers of analytical, communication, and marketing tools, artificial intelligence (AI) technology providers, as well as entities providing accounting, legal, and IT support services to us. In case of justified need, upon the User's request, the Controller will provide the current list of data processors.

VIII. Rights and Obligations of the Data Subject

  1. Every User has the right to:
    1. access their Personal Data, the right to rectify it, delete it, and the right to request restriction of processing,
    2. object to the processing of Personal Data, withdraw consent to process Personal Data for one or more purposes for which it was granted, at any time without affecting the lawfulness of processing based on consent before its withdrawal, and the right to data portability.
  2. In order to exercise the rights referred to above - one must send an email to: kontakt@trafficwatchdog.pl, use the functionality provided in the Customer Account, click on the consent withdrawal link placed in the commercial information message, or send a written notice to the address: Spark DigitUP Sp. z o.o., Plac Wolnica 13 lok. 10, 31-060 Kraków.
  3. If the User places any personal data of other persons in the Service (including their name, surname, address, phone number, or email), they may do so only on condition that they do not violate the provisions of applicable law and the personal rights of those persons.
  4. Every User has the right to lodge a complaint with the supervisory authority dealing with personal data protection, i.e. the President of the Personal Data Protection Office (PUODO), ul. Stawki 2, 00-193 Warsaw, if they consider that the processing of their data violates GDPR provisions.

IX. Data Security

  1. Trafficwatchdog declares that it strives to provide Users with a high level of security when using the Service and to this end:
    1. applies technical and organizational measures required by law, particularly regarding the security of Personal Data processing,
    2. applies measures to ensure:
      1. the ability to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;
      2. the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident;
      3. a process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

X. Final Provisions

  1. In matters not covered by the Privacy Policy, the legal provisions concerning the processing of Personal Data, including GDPR, apply.

XI. Contact

  1. Please send any additional questions related to the Privacy Policy to the address: kontakt@trafficwatchdog.pl.
  2. The rules set out in the Privacy Policy are governed by Polish law.
  3. Trafficwatchdog is entitled to unilaterally change the Privacy Policy in the event of:
    1. changes in applicable legal regulations applying to the operation of the Service or the provision of electronic services.
    2. changes in the Service's offer regarding services, provided that the amendments to the Privacy Policy are aimed at adapting the content of the Privacy Policy to the offer and its conditions.
    3. Users holding a registered Account in the Service will be informed of any significant changes to the Privacy Policy electronically (via email). The amended Privacy Policy will also be published on the Service's website.

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