Privacy Policy

Last updated: 21.08.2026

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 prospective clients of Trafficwatchdog (hereinafter: "Client"), as well as – in the event the Client enters into an agreement for the provision of electronic services with Trafficwatchdog – also its Users (hereinafter "Client Users"), employees or other persons engaged by the Client whose data has been provided to Trafficwatchdog by the Client, and it sets out the type, scope, and manner of use of personal data, the rights and obligations of the User, and the safeguarding of personal data. Using the Service means having read this Privacy Policy. The provision of personal data is voluntary; however, to the extent necessary for the provision of electronic services or to ensure the proper functioning of the Service, failure to provide the data may prevent the use of certain features.
  2. This Privacy Policy also applies accordingly to the MediaAgentAI Studio (by TrafficWatchdog) service available at mediaagent.studio, operated by Trafficwatchdog, together with the service provided through it. Whenever the further part of this Privacy Policy refers to the "Service," this is understood to mean both trafficwatchdog.pl and mediaagent.studio, respectively, unless the content of a given provision indicates that it applies solely to one of these services.
  3. The controller of the 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 (Tax ID) 6762496391, registered with the District Court for the City of Kraków-Śródmieście, XI Commercial Division of the National Court Register under KRS number 0000587711, REGON 363042916, share capital of PLN 205,000.00, fully paid up. The controller can be contacted via e-mail at: kontakt@trafficwatchdog.pl, through the contact form available on the website: www.trafficwatchdog.pl, or in writing at the controller's registered office address indicated above.
  4. In certain cases where Clients use the services offered by Trafficwatchdog, Trafficwatchdog acts as a processor of the personal data of Client Users, meaning that it processes personal data on behalf of and under the instruction of the personal data controller. This relationship is governed by the Terms of Service of the Trafficwatchdog Service.
  5. The Personal Data referred to in this Privacy Policy means information about an identified or identifiable natural person, i.e. a person 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  6. Personal Data is processed by Trafficwatchdog in accordance with applicable law, 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").
  7. Processing, within the meaning of this 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, or consultation.
  8. The User may browse the Service without having to enter their Personal Data into the Service or register, subject to the provisions of point II.1.A below ["Data collected automatically"].

II. Scope, purpose, and basis for collecting and processing personal data

  1. Trafficwatchdog collects and processes the data of Users and Client Users while they use:
    1.1. the Trafficwatchdog Service and the services available within the Trafficwatchdog Service,
    1.2. the Client Service and the services available within the Client Service provided by Trafficwatchdog under a concluded Cooperation Agreement,
    1.3. services offered by Trafficwatchdog to Clients under a concluded Cooperation Agreement.

    1. When a User uses the Trafficwatchdog Service or a Client Service cooperating with Trafficwatchdog under a concluded Cooperation Agreement, data relating to 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, an identifier assigned to the device from which visits are generated, end-device parameters, operating system parameters, browser parameters, the general geographic location of the visit, the manner in which a prospective User interacts with the Service and activity data within the Service, time spent on the Service, HTTP header parameters, marketing campaign parameters, data on visited websites, URLs of visited pages, and the date and time of the visit. We process this data for the purposes of:
      1. ensuring the proper functioning of the Service (e.g. maintaining sessions, error diagnostics, handling requests),
      2. ensuring the security of the Service and counteracting abuse and attempts at unauthorized access,
      3. conducting statistics and analytics (provided the User consents to analytical cookies),
      4. marketing activities (provided the User consents within the privacy settings of the Service or the Client Service).
      The legal basis for processing is, respectively: Article 6(1)(f) GDPR (the Controller's legitimate interest – security and proper functioning of the Service) and Article 6(1)(a) GDPR (consent – analytics/marketing, where applied).

      We store personal data from Users' visits for a period of up to 3 months from the visit, unless further processing is justified by another legal basis (e.g. performance of a contract with the client, a complaint, or legal obligations). After this period, the data will be permanently deleted or anonymized. In connection with the use of solutions provided by external vendors, visit data may be transferred to our trusted subcontractors located outside the European Economic Area (e.g. Google LLC, USA). We ensure, however, that in such cases the transfer takes place in accordance with GDPR requirements – on the basis of standard contractual clauses approved by the European Commission entered into with these entities, and that the data is appropriately protected.
    2. Where the User uses the AI Chat or Chat Bot on the Trafficwatchdog Service or the Client Service, cookies and contact data provided by the User during the conversation may be collected and processed, such as, among others: first name, last name, e-mail, phone number, and social media account details. This data is collected and processed in order to handle Users' inquiries and provide them with appropriate support. In the course of a conversation conducted by the AI Chat, the content of the messages and the data provided may be automatically processed by external artificial intelligence systems (including OpenAI, USA; Google LLC, USA) in order to respond to the User's inquiry. We cooperate with AI service providers as processors – they process conversation data solely for the purpose of providing a response, based on our instructions and a data processing agreement.

      The legal basis for processing this data is Article 6(1)(b) GDPR (taking steps at the User's request prior to entering into a contract, or performance of a contract – handling the inquiry) or Article 6(1)(f) GDPR (the Controller's legitimate interest – communication and handling of requests), depending on the nature of the contact.

      We store data from conversations conducted via the AI Chat or Chat Bot for the duration of handling the request and for a maximum period of up to 3 months from the end of the conversation, and thereafter for the period necessary to defend against or pursue any potential claims. After this period, the data will be permanently deleted or anonymized.

      The recording of conversation history takes place with the User's consent, expressed by using the AI Chat or Chat Bot service. The User has the right to request access to the saved history of their conversation, its rectification, deletion, or restriction of processing.

      In connection with the use of AI-based chat solutions, conversation data (including any personal information provided) may be transferred to our trusted subcontractors located outside the European Economic Area (e.g. OpenAI, USA; Google LLC, USA). We ensure, however, that in such cases the transfer takes place in accordance with GDPR requirements – on the basis of standard contractual clauses approved by the European Commission entered into with these entities, and that the data is appropriately protected.
    3. Where the User uses the AI Voice Assistant on the Trafficwatchdog Service and the Trafficwatchdog helpline, or on the Client Service and the Client's helpline – the User's voice calls are recorded and processed. The scope of data processed includes a recording of the User's voice (audio) and a text transcript of the conversation. This data is used for two purposes: (a) providing the Assistant's service – i.e. speech recognition and providing the User with answers to their questions, and (b) improving service quality and understanding client needs – i.e. analyzing recordings in order to improve the operation of the AI assistant and raise the quality of service. The User acknowledges that the conversation is conducted with an assistant using artificial intelligence (a synthetic voice), and not with a live consultant.

      The legal basis for processing data within the AI Voice Assistant is Article 6(1)(b) GDPR – necessity for the performance of a service at the User's request (speech recognition and the assistant's response), while to the extent that call recordings are analyzed after the call has ended in order to improve the quality and operation of our services, the legal basis is the Controller's legitimate interest (Article 6(1)(f) GDPR), consisting of improving the services offered and ensuring the highest standards of service.

      We store recordings of conversations with the AI Voice Assistant and their text transcripts for a period of no longer than 3 months from the date of recording, unless further processing is justified by another legal basis (e.g. performance of a contract with the client, a complaint, or legal obligations). After this period, the 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.

      The recording of conversations takes place with the User's consent, expressed by using the service after hearing the notice. The User has the right to request access to their recording, its rectification, deletion, or restriction of processing. The User also has the right to withdraw consent to recording at any time by ending the call, and to object to the processing of their data for quality-improvement purposes – which will result in the cessation of further processing for those purposes.

      As part of the operation of the AI Voice Assistant, personal data in the form of a voice recording and a conversation transcript may be transferred to our processors, in particular: Google (speech recognition and synthesis services) and OpenAI (the language model service generating the response). These entities may process data on our behalf solely for the above purposes. Due to the location of these providers (USA), the data may be transferred outside the European Economic Area – always, however, on the basis of standard data protection clauses and with the application of appropriate safeguards required by the GDPR.
    4. When providing selected services to Clients (such as, for example, Click Scanner, Affiliate Scanner, AI Sales Rep, Sales Bot, Ads Bot AI, Lead Bot AI, IT Agent AI, Blog Agent AI, MediaAgentAI Studio), we need to obtain access to a Google Ads account, Google Merchant Center, Facebook, or other Client systems, including the Client's sales system or e-commerce platform. This access is required in order to provide the services defined for Clients within the scope of a given product. The scope of data processed may include the Client's account identifier, contact data, and system data on the Client's side. The legal basis for processing this data is Article 6(1)(b) GDPR – necessity for the performance of a service at the Client's request.

      Data retention period – the data will be processed by us for the period necessary to achieve the above purpose, but no longer than until an objection to processing is raised or consent, if given, is withdrawn.
    5. We may also process data obtained from public sources, e.g. from publicly available websites or other public registers containing information about a company's business activity. The scope of data processed includes basic contact data. Purpose of processing – the data is processed for the purposes of establishing B2B business relationships and direct marketing carried out on the basis of the controller's legitimate interest (within the limits permitted by law), as well as for the purposes of maintaining and updating a database of business contacts used in carrying out information and marketing campaigns, including those conducted on behalf of our clients or business partners. Legal basis for processing – the legitimate interest of the data controller (Article 6(1)(f) GDPR), consisting of establishing and maintaining business contacts and carrying out marketing activities within the scope permitted by law.

      Data retention period – the data will be processed by us for the period necessary to achieve the above purpose, but no longer than until an objection to processing is raised or consent, if given, is withdrawn.

      Persons whose data has been obtained in this manner have the right to access their data, to rectify it, to erase it, to restrict its processing, to data portability, and the right to object to processing.

      Contact data obtained in this manner may be transferred to our processors, in particular: Google and OpenAI. These entities may process data on our behalf solely for the above purposes. Due to the location of these providers (USA), the data may be transferred outside the European Economic Area – always, however, on the basis of standard data protection clauses and with the application of appropriate safeguards required by the GDPR. This data may also be transferred to entities providing us with technical or organizational services (e.g. hosting, mailing systems, legal advice), solely to the extent necessary to achieve the purposes of processing.
    6. We use cookies and similar technologies on the Service. We use them in particular in order to: (i) ensure the operation of the Service and its features, (ii) ensure security, (iii) analytics/statistics, (iv) marketing – depending on the User's settings.

      Essential cookies are used on the basis of Article 6(1)(f) GDPR (legitimate interest – the proper functioning and security of the Service) and are required for the Service to operate. Analytical and marketing cookies are used only if the User gives their consent (Article 6(1)(a) GDPR).

      The User may at any time change or withdraw their consent through the settings of the consent management tool and through their browser settings. Blocking essential cookies may cause the Service to malfunction.

      Third-party cookies (e.g. from analytics or advertising providers) may be used within the Service – in such cases, the rules for their operation and data processing follow from the privacy policies of those entities.

      The full list of cookies collected and processed by us — covering both the trafficwatchdog.pl service and the mediaagent.studio service — is available in the Cookie Policy (https://trafficwatchdog.pl/pl/docs/cookie-policy)
    7. In connection with providing services that require integration with the Client's sales system or e-commerce platform (including within MediaAgentAI Studio and other Services using such integration), Trafficwatchdog retrieves the Client's catalog data via API, including: product names and descriptions, prices, categories, brands, promotions, product photos, and basic identification and contact data relating to the Client's business. This data is used to provide the Service (in particular, generating and publishing marketing content). To the extent that this data includes personal data (e.g. where the Client operates a sole proprietorship, or where product/photo data contains data of natural persons), the legal basis for processing is Article 6(1)(b) GDPR (necessity for the performance of the Agreement), and Trafficwatchdog acts in this respect as a processor on the Client's instructions, on the terms set out in the Terms of Service.
    8. For Services that do not involve integration with a product catalog (e.g. for entities providing services without a product offering), Trafficwatchdog may retrieve and process content publicly available on the Client's Website in order to prepare a knowledge base used to generate content – on the same terms and legal basis as above.
    9. In connection with the provision of the MediaAgentAI Studio Service, data and content processed in the course of generating materials (articles, graphics, video materials) may be transferred to our subcontractors providing artificial intelligence technology, in particular: Google LLC (USA) — for the purposes of generating text, graphics, video materials, and speech synthesis, and Anthropic, PBC (USA) — as a reserved AI technology provider, currently not used within this Service. Due to the location of these providers outside the European Economic Area, the data transfer takes place on the basis of standard contractual clauses approved by the European Commission, with the application of appropriate safeguards required by the GDPR.
    10. In connection with the automatic publication of materials on social media, data and content may also be transferred to providers of tools enabling publication via the API of the Client's social media accounts, in particular Zernio (zernio.com), as well as directly to the platforms: Meta Platforms, Inc. (Facebook, Instagram), TikTok, and Google LLC (YouTube), in accordance with the rules of those platforms and to the extent resulting from the access authorization granted by the Client to their accounts.
    11. Use of the Content Studio within MediaAgentAI Studio takes place via a unique Private Link, without the need to register an account or provide a password. This access is secured by an encrypted authorization token stored in the review_auth cookie, described in the Cookie Policy. The Private Link provides access to as-yet unpublished draft content (article drafts, graphics, and video materials) prepared for a given Client. A person in possession of the Private Link gains access to this content without additional identity verification, and accordingly the Client is required to keep the Private Link confidential, in accordance with the Terms of Service.
    12. Content prepared within MediaAgentAI Studio that has not been published by the Client (including during the free trial period) is automatically deleted from Trafficwatchdog's systems after 30 days from its generation. Materials published by the Client remain on the Client's Website or on their social media accounts in accordance with the Client's decision and independently of Trafficwatchdog.
  2. Data collected during registration and after logging in to the Trafficwatchdog Service:
    1. Contact form - if the User fills in the contact form on the Service, the following Personal Data is collected and processed: first name, last name, e-mail address, phone number, IP address. The data is collected and processed in order to make contact with the User and provide the User with assistance. The basis for this processing is Article 6(1)(f) GDPR (the Controller's legitimate interest consisting of handling correspondence and responding to Users' inquiries) or Article 6(1)(b) GDPR (where the contact is directly aimed at, or related to, entering into a contract). If the User gives consent on the contact form to the processing of their personal data for marketing purposes (by giving the relevant consent), the User's data will then be collected and used for the purposes of presenting offers, conducting contests, and other marketing activities. If the User gives consent on the contact form to the processing of their personal data in order to receive commercial information (by giving the relevant consent), the User's data will then be collected and used for the purposes of receiving commercial information. The basis for this processing is Article 6(1)(a) GDPR.

      Data retention period – the data will be processed by us for the period necessary to achieve the above purpose, but no longer than until an objection to processing is raised or consent, if given, is withdrawn.
    2. Account registration on the service - under the Terms of Service of the Service, opening a Client Account or a Demo Account by the User is conditional upon registration and the provision of the User's data – the following Personal Data is collected and processed: e-mail address, password, IP address. The basis for this processing is Article 6(1)(b) GDPR.

      Data retention period – the data will be processed by us for the period necessary to achieve the above purpose, but no longer than until an objection to processing is raised or consent, if given, is withdrawn.
    3. Entering into agreements via or available on the Service – the following Personal Data is collected and processed: first name and last name, address, NIP (Tax ID), e-mail addresses, contact phone number. The basis for this processing is Article 6(1)(b) GDPR.

      Data retention period – the data will be processed by us for the period necessary to achieve the above purpose, but no longer than until an objection to processing is raised or consent, if given, is withdrawn.
    4. Fulfilling obligations relating to agreements entered into on or via the Service and the functioning of the Service – the following Personal Data is collected and processed: first name and last name, address, NIP (Tax ID), e-mail addresses, contact phone number. The basis for this processing is Article 6(1)(b) GDPR.

      Data retention period – the data will be processed by us for the period necessary to achieve the above purpose, but no longer than until an objection to processing is raised or consent, if given, is withdrawn.
    5. Pursuing claims or defending against such claims relating to the operation of the Service or the services provided electronically – the following Personal Data is collected and processed: first name and last name, address, NIP (Tax ID), e-mail addresses, contact phone number. The basis for this processing is Article 6(1)(f) GDPR (the Controller's legitimate interest consisting of pursuing claims or defending against claims).
    6. Fulfilling the obligation to retain data, documents, and accounting evidence – the following Personal Data is collected and processed: first name and last name, address, NIP (Tax ID), e-mail address, contact phone number. The basis for this processing is Article 6(1)(c) GDPR (a legal obligation incumbent on the Controller). The data is stored for the period required by tax and accounting law.
    7. If the User provides personal data of third parties via the Service, they represent that they have a legal basis for disclosing it to the Controller and that, to the extent required by law, they have fulfilled the information obligation towards those persons.
  3. Users' Personal Data is not subject to automated decision-making, including profiling, that 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 services (e.g. Facebook). Clicking a link results in a connection to the external service, and further processing of data takes place in accordance with the rules of that provider. To the extent that data is processed by the social networking service, its provider acts as a separate data controller.
  2. For Services requiring authorization to access the Client's social media accounts in order to automatically publish content (e.g. within MediaAgentAI Studio), Trafficwatchdog gains access to those accounts solely to the extent and for the purpose necessary to provide the given Service, on the basis of authorization granted by the Client via the interfaces (API) of the given platform. In this respect, Meta Platforms, Inc. (Facebook, Instagram), TikTok, and Google LLC (YouTube), as well as the provider of the integration tool Zernio (zernio.com), process data in accordance with their own privacy policies as separate controllers or processors, depending on the scope of their activity.

IV. Personal data processing period

  1. Personal Data collected on the Service will be stored for as long as the legal basis for its processing exists, subject to the shorter retention periods specified in detail in Chapter II (e.g. for call recordings, chat histories, or content prepared within MediaAgentAI Studio).
  2. Where an agreement for the provision of electronic services has been entered into, Personal Data will be processed for the duration of that agreement, and thereafter for as long as follows from the statutory limitation periods applicable to claims arising from that agreement, and until the obligation to retain data, documents, and accounting evidence arising from applicable law expires.
  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 on the Service is voluntary, but necessary in order to achieve one or more of the processing purposes defined in point II above.

VI. Rights and obligations of Trafficwatchdog

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

VII. Processing of personal data by Processors

  1. Processors, within the meaning of this Privacy Policy, are entities that process Personal Data on the instructions of Trafficwatchdog.
  2. Personal Data may be processed within the territory of Poland, a Member State of the European Union (EU), or the territory of a signatory to the European Economic Area (EEA) Agreement.
  3. Where data is transferred to third countries, the transfer takes place on the basis of: (i) a European Commission adequacy decision, or (ii) standard contractual clauses adopted by the European Commission, and, where necessary, additional security measures. The User may obtain a copy of the safeguards applied 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 data protection and security, in accordance with Article 28 GDPR.
  5. Recipients of Personal Data may include 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, providers of tools for publishing content on social media, as well as entities providing us with accounting, legal, and IT support services. Where there is a justified need, at the User's request, the Controller will make available a current list of processing entities.

VIII. Rights and obligations of the data subject

  1. Every User has the right:
    1. to access their Personal Data, and the right to have it rectified, erased, and to request restriction of its processing,
    2. to object to the processing of Personal Data, to withdraw consent to the processing of Personal Data for one or more of the purposes for which it was given, at any time without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal, and also the right to the portability of their Personal Data.
  2. In order to exercise the rights referred to above – please send an e-mail to: kontakt@trafficwatchdog.pl, use the features made available in the Client Account, click the link causing withdrawal of consent included in the content of a commercial communication, or send written notice to: Spark DigitUP Sp. z o.o., Plac Wolnica 13 lok. 10, 31-060 Kraków.
  3. If the User posts on the Service any personal data of other persons (including their first and last name, address, phone number, or e-mail), they may do so only on condition that they do not violate applicable law or the personal rights of those persons.
  4. Every User has the right to lodge a complaint with the supervisory authority responsible for the protection of personal data, 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 infringes the GDPR.

IX. Personal data security

  1. Trafficwatchdog represents that it makes every effort to ensure Users a high level of security in using the Service, and to this end:
    1. it applies the technical and organizational measures required by law, in particular with regard to the security of the processing of Personal Data,
    2. it 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) a regular process for testing, measuring, and assessing the effectiveness of technical and organizational measures for ensuring the security of processing.

X. Final provisions

  1. In matters not regulated by this Privacy Policy, the provisions of law relating to the processing of Personal Data, including the GDPR, shall apply.

XI. Contact

  1. Any additional questions relating to the Privacy Policy should be directed to: kontakt@trafficwatchdog.pl.
  2. The rules set out in this Privacy Policy are governed by Polish law.
  3. Trafficwatchdog is entitled to unilaterally amend the Privacy Policy in the event of:
    1. a change in applicable law relating to the operation of the Service or the provision of electronic services.
    2. a change in the Service's offering of services, provided that changes to the Privacy Policy are intended to align the content of the Privacy Policy with the offering and its terms.
    3. Users with a registered Account on the Service will be informed electronically (by e-mail) of any material changes to the Privacy Policy. The amended Privacy Policy will also be published on the Service's website.

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