This Privacy Policy of the TrafficWatchdog.pl service (hereinafter: "Service"), owned by Spark DigitUP Sp. z o.o. with its registered office in Krakow, Plac Wolnica 13 lok. 10, 31-060 Krakow (hereinafter: "TrafficWatchdog") is addressed to users of the Service, including clients and potential clients of TrafficWatchdog, and in the case of a client concluding a contract with TrafficWatchdog for the provision of electronic services – also to its employees or other persons used by the client, whose data were provided to TrafficWatchdog by the client (hereinafter: "User") and specifies the type, scope, methods of using personal data, the rights and obligations of the User, and the protection of personal data. The User's lack of acceptance of the provisions and principles resulting from this Privacy Policy is tantamount to the inability to use the Service and the need for the User to leave the Service.
The administrator of Users' personal data (hereinafter: "Personal Data") is Spark DigitUP Sp. z o.o. with its registered office in Krakow, Plac Wolnica 13 lok. 10, 31-060 Krakow, NIP 6762496391, registered in the District Court of Krakow-Śródmieście, 11th 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 administrator is possible via the email address: kontakt@trafficwatchdog.pl, the contact form available on the website: www.trafficwatchdog.pl or in writing at the administrator's registered office address indicated above.
In certain cases of Clients using services offered by TrafficWatchdog, it acts as a personal data processor for the Client's Users, which means that it processes personal data on behalf of and at the request of the personal data administrator. This relationship is regulated in the TrafficWatchdog Service Regulations.
Personal Data, as referred to in the Privacy Policy, is information about an identified or identifiable natural person to whom the data relates, i.e., someone who can be directly or indirectly identified, in particular on the basis of characteristics such as: name and surname, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of a natural person.
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").
Processing, as defined in the Privacy Policy, means an operation or set of operations performed on Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation.
The User can browse the Service without having to enter their Personal Data into the Service or without having to register, subject to the provisions of point II.A. A below ["Automatically collected data"].
Privacy policy
TrafficWatchdog Privacy Policy
(hereinafter: “Privacy Policy”)
Table of contents
# I. General provisions
# II. Scope, purpose and legal basis for the collection and processing of personal data
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Automatically Collected Data
When the User uses the Service, data about the User and their visits are automatically collected and processed. This data includes: IP address, cookies, basic information about the computer device used to access the Service, an identifier assigned to the device from which visits are generated, end device parameters, operating system parameters, browser parameters, general geographic location of the visit, method of interaction of the potential User with the Service and activity data in the Service, time spent in the Service, HTTP header parameters, marketing campaign parameters, data about visited websites, URLs of visited pages, date and time of the visit. This data is collected and processed to identify marketing fraud such as ad fraud, create reports and analyses, collect demographic data about Users, and personalize the content of the Service. The basis for this processing is Article 6(1)(f) of the GDPR.
When the User uses the Chat Widget, contact details provided by the User during the conversation may also be collected and processed: name, surname, email, phone number, social media account details. This data is collected and processed to handle User inquiries and provide them with appropriate support. The basis for this processing is Article 6(1)(b) of the GDPR.
Cookies, as referred to in point II.A.1 above, are files sent to the User's computer or other device while browsing the Service.
Cookies remember the User's preferences, which enables improving the quality of the Service and services provided electronically through the Service, creating viewership statistics, tracking User preferences, and maintaining the logged-in User's session.
Cookies do not cause configuration changes to the device or software installed on the User's device.
The User may refuse to allow the use of cookies (blocking cookies), which will prevent cookies from being stored on the User's device in the future.
A User who does not consent to the use of cookies (applies cookie blocking) should select the appropriate settings in their web browser. The process of consenting to the use of cookies varies depending on the browser used by the User.
A User who wants to delete existing cookies should select the appropriate settings in their web browser or delete cookies manually. The process of deleting cookies varies depending on the browser used by the User.
Blocking or deleting cookies may cause difficulties in using the Service, and in some cases, prevent the use of certain options.
Advertisements placed on the Service may use third-party cookies to enable the analysis of the effectiveness of these entities' advertising campaigns. This Privacy Policy does not regulate the use of cookies by third parties.
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Data collected during registration and after logging into the Service
Contact form - if the User fills out the contact form on the Service, the following Personal Data is collected and processed: name, email address, phone number, IP address. The data is collected and processed to facilitate contact with the User and provide assistance. The basis for this processing is Article 6(1)(b) of the GDPR. If the User consents in the contact form to the processing of their personal data for marketing purposes (by giving appropriate consent), the User's data will then be collected and used to present offers, conduct competitions, and other marketing activities. If the User consents in the contact form to the processing of their personal data for receiving commercial information (by giving 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) of the GDPR.
Account registration - according to the Service Regulations, the condition for creating a client account or a demo account by the User is registration and providing 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) of the GDPR.
Conclusion of contracts through or available on the Service - the following Personal Data is collected and processed: name and surname, address, tax identification number (NIP), email addresses, contact phone number. The basis for this processing is Article 6(1)(b) of the GDPR.
When the User uses the Chat Widget after logging in, contact details provided by the User during the conversation may also be collected and processed: name, surname, email, phone number, social media account details. This data is collected and processed to handle User inquiries and provide them with appropriate support. The basis for this processing is Article 6(1)(b) of the GDPR.
Fulfilling obligations related to contracts concluded on or through the Service and the operation of the Service - the following Personal Data is collected and processed: name and surname, address, tax identification number (NIP), email addresses, contact phone number. The basis for this processing is Article 6(1)(b) of the GDPR.
Google Ads and Facebook account data - some of the services provided require access to the User's Google Ads and Facebook accounts. This access is required for the Service robots to add and remove IP addresses or files to exclusion lists in Google Ads and Facebook campaigns and to add and remove a tracking template in the User's Google Ads account. The Service does not require the User's Google Ads or Facebook username or password - access is granted by approving the access request for the Service. The following Personal Data is collected and processed - the User's Google Ads and Facebook account identifier. The basis for this processing is Article 6(1)(b) of the GDPR.
Monitoring behavior and identifying marketing fraud on the Service, analyzing web traffic, ensuring the Service's IT security, conducting statistics, diagnoses, and analyses - the following Personal Data is collected and processed: IP address, cookies, basic information about the computer device used to access the Service, an identifier assigned to the device from which visits are generated, end device parameters, operating system parameters, browser parameters, general geographic location of the visit, method of interaction of the potential User with the Service and activity data in the Service, time spent in the Service, HTTP header parameters, marketing campaign parameters, data about visited websites, URLs of visited pages, date and time of the visit. The basis for this processing is Article 6(1)(f) of the GDPR.
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, tax identification number (NIP), email addresses, contact phone number. The basis for this processing is Article 6(1)(b) of the GDPR.
Fulfilling obligations related to the storage of data, documents, accounting evidence - the following Personal Data is collected and processed: name and surname, address, tax identification number (NIP), email address, contact phone number. The basis for this processing is Article 6(1)(b) of the GDPR.
If the User places in the Account or elsewhere on the Service personal data of the User's employees or other persons used by the User, the User is obliged to inform these data subjects of this fact, familiarize these data subjects with this Privacy Policy and obtain written statements from these persons confirming that they have read the content of the Privacy Policy, and to submit the signed statements of the data subjects at each request of TrafficWatchdog within no more than 3 days from the date of such request.
# III. Social networks
The Service contains links to external social networking sites ("Social Plugins") such as Facebook, belonging to Facebook Inc., 1601 Willow Road, Menlo Park, California 94025, USA (hereinafter: "Facebook").
The functions assigned to individual links, in particular the transfer of information and Personal Data, are activated only after clicking on a given link. Then, the so-called social plug-in of individual social networking sites is activated, and then the User's browser connects the User directly to that service.
If the User clicks on a selected link while visiting the Service, their Personal Data is transferred and processed by the given social networking site. If the User clicks on a selected link while visiting the Service, while being logged in to the given portal, information about visiting the Service may be transferred through the User's account and this fact may be saved on the User's account on the given social networking site. To avoid this, you should log out of your account on the given social networking site before clicking on the link. More information on data processing, e.g., by Facebook, can be found at https://www.facebook.com/about/privacy/.
The information transferred is most often the so-called public profile, as defined by the social networking site whose plug-in the User clicks on while visiting the Service. A comment published on the Service's pages using a social plug-in will be publicly available. For example, if the User publishes a comment using the Facebook comment plug-in, this event will be public and accessible to everyone.
The purpose and scope of Personal Data processing by social networking sites, as well as the related rights and obligations of the administrator of such a site serving to protect Users' privacy, can be found in the data protection tab of that site (e.g., for Facebook, information on personal data processing can be found at https://www.facebook.com/about/privacy/). The given social networking site is responsible for the processing of data that is initiated after clicking on a given link.
# IV. Personal data processing period
Personal Data collected in the Service, to the extent justified by the processing purposes, will be stored and processed as long as the legal basis for their processing exists. In the case of concluding a contract for the provision of electronic services, Personal Data will be processed for the duration of that contract, and then as long as it results from the provisions of law regarding the statute of limitations for claims arising from that contract, and until the expiry of the obligation to store data, documents, and accounting evidence resulting from applicable legal provisions. At the end of the storage period, Personal Data will be deleted or anonymized.
# V. Voluntariness of Providing Personal Data
Providing Personal Data on the Service is voluntary, but necessary for the implementation of one or more purposes of Personal Data processing defined in point II above.
# VI. TrafficWatchdog Rights and Obligations
TrafficWatchDog reserves the right to disclose selected Personal Data to the appropriate authorities or third parties who request such information, based on an appropriate legal basis, in accordance with applicable law.
TrafficWatchdog may entrust the processing of Personal Data, based on a contract concluded in accordance with applicable regulations, to entities providing services to TrafficWatchdog.
# VII. Processing of Personal Data by Processors
A Processor, within the meaning of the Privacy Policy, is an entity that processes Personal Data on behalf of TrafficWatchdog.
The Processor is authorized and has the right to process Personal Data only for the purposes and to the extent specified in the Privacy Policy.
Personal Data may be processed in Poland, a Member State of the European Union (EU), or in a signatory to the European Economic Area (EEA) Agreement.
In connection with the provision, support, or improvement of service quality, or in cases provided by law, User data may be transferred to third countries outside the EEA. In such cases, data transfers will be secured by agreements with the service provider as the data recipient, containing standard data protection clauses adopted by the supervisory authority and approved by the European Commission.
The Processor processes the entrusted Personal Data in accordance with applicable legal provisions, in particular, the Processor: a) applies legally required technical and organizational measures, especially in the area of Personal Data processing security, b) applies measures ensuring: i) the ability to continuously ensure the confidentiality, integrity, availability, and resilience of processing systems and services; ii) the ability to quickly restore the availability of and access to personal data in the event of a physical or technical incident; iii) regular testing, measuring, and evaluating the effectiveness of technical and organizational measures to ensure processing security, c) applies Personal Data security measures at a level no lower than that applied by TrafficWatchdog.
List of external entities providing services to TrafficWatchdog: a) Anthropic, 548 Market St PMB 90375 San Francisco, California 94104, USA b) ARTIA INTERNATIONAL S.R.L, Bld. Decebal 28, Bucharest 030971, Romania c) Atlassian Pty Ltd, Level 6, 341 George St, Sydney NSW 2000, Australia d) Atman sp. z o.o., UL. Grochowska 21A, 04-186 Warszawa, Poland e) K&K Książki i Księgi Edyta Kuter, Żwirki i Wigury 6/14/301, 42-202 Częstochowa, Poland f) CloudIT Mariusz Sitarz, ul. Chopina 87, 42-202 Częstochowa, Poland g) Fakturownia Sp. z o.o., ul. Juliana Smulikowskiego 6/8, 00-389 Warszawa, Poland h) Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043, USA i) Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany j) Lite Speed Technologies Inc., 18 Campus Blvd. Suite 100, Newtown Square, PA 19073, USA k) Meta Platforms Inc. 1601 Willow Road, Menlo Park, CA 94025, USA l) MPROJECT SP. z o.o., Sielska 17a, 60-129, Poznań, Poland m) OpenAI, LLC, 548 Market Street, PMB 97273, San Francisco, California 94104, USA n) Optimal Balance Sp. z o.o., ul. Plac Solny 15, 50-062 Wrocław, Poland o) OVH sp. z o.o., ul. Powstańców Śląskich 9, 53-332 Wrocław, Poland p) Spółka Progreso.pl Sp. z o.o., ul. 1 Maja 7, 44-330 Jastrzębie-Zdrój, Poland q) ST LINE sp. z o.o. sp.k., ul. Sielska 17a, 60-129 Poznań, Poland r) Vercom S.A., ul. Wierzbięcice 1B, 61-569 Poznań, Poland s) Webfield Sp. z o.o., ul. Lęborska 3b, 80-386 Gdańsk, Poland t) Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
# IX. Personal Data Security
TrafficWatchdog declares that it makes every effort to ensure a high level of security for Users in the use of the Service and for this purpose: a) applies legally required technical and organizational measures, especially in the area of Personal Data processing security, b) applies measures ensuring: i) the ability to continuously ensure the confidentiality, integrity, availability, and resilience of processing systems and services; ii) the ability to quickly restore the availability of Personal Data and access to them in the event of a physical or technical incident; iii) regular testing, measuring, and evaluating the effectiveness of technical and organizational measures to ensure processing security.
# X. Final Provisions
In matters not regulated in the Privacy Policy, the provisions of law regarding the processing of Personal Data, including the GDPR, shall apply.
# XI. Contact
Any additional questions related to the Privacy Policy should be directed to: kontakt@trafficwatchdog.pl.
The principles set out in the Privacy Policy are subject to Polish law.
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TrafficWatchdog is entitled to unilaterally change the Privacy Policy in the event of:
changes in applicable legal provisions relating to the operation of the Service or the provision of electronic services.
changes in the Service's offer regarding services, provided that changes to the Privacy Policy are aimed at adapting the content of the Privacy Policy to the offer and its conditions.
