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Privacy Policy

This GG Privacy Policy is effective from 12 March 2022

PREAMBLE

The following provisions constitute a privacy policy (hereinafter referred to as the “Privacy Policy”) which provides information on the collection and processing of data, including personal data of Users of the Services provided by Fintecom Sp. z o. o. with its registered office in Koszalin, within the GG Communication Platform.
Acceptance of one of Fintecom’s Terms of Service listed below:

also means acceptance of this Privacy Policy.

I. DEFINITIONS:

  1. Fintecom – Fintecom Sp. z o. o. with its registered office in Koszalin, and the office address at ul. Marszalka Jozefa Pilsudskiego 45, 75-502 Koszalin, entered into the Register of Entrepreneurs of the National Court Register by the District Court in Koszalin, IX Commercial Division of the National Court Register under KRS number 0000362067, NIP: 6692501424, REGON: 320877907.
  2. GG Instant Messenger / GG Communication Platform – The instant messenger owned by Fintecom Sp. z o. o. with its registered office in Koszalin.
  3. Service – a service provided electronically as part of the GG online communication platform.
  4. GG User – a natural person or legal entity registered on the GG platform using the Internet registration form in order to use the GG Instant Messenger Service, and which has been assigned a unique GG number.
  5. Service User – a GG User or any other natural person or legal entity not registered in the GG instant messenger using the Service as part of the GG online communication platform, including payment services provided by Fintecom.
  6. GG Moneybox – a payment service provided electronically within the GG Internet communication platform, consisting in the operation a Payment Instrument called “GG Moneybox”.
  7. GG Moneybox User – a natural person with legal capacity who has completed the Registration process and the verification process.
  8. Supporter/Contributor – any adult natural person with full legal capacity, legal person or organisational entity without legal personality, providing a GG Moneybox User with voluntary contribution in any amount.
  9. GG Premium – a paid service, in the form of a benefits package, provided by Fintecom in the GG Instant Messenger.
  10. Verifying Transfer – a transfer from the GG User’s Bank account or a bank account of which the User is a co-owner and to which the User’s personal data is assigned, necessary to identify their identity.
  11. AML Act – the Act of 1 March 2018 on Counteracting Money Laundering and Terrorism Financing.
  12. Fintecom’s Partners – entities which offer services or marketing and commercial information to the GG Users, and which signed a cooperation agreement with Fintecom.

II. Personal Data Collector

The administrator of your personal data is: Fintecom Sp. z o.o., ul. Marszalka J. Pilsudskiego 45, 75-502 Koszalin, KRS: 0000362067, NIP: 6692501424, REGON: 320877907.

III. Contact Information:

In matters related to the Privacy Policy, the User may contact our Data Protection Officer, Hanna Majchrowska: iod@gadu-gadu.pl

IV. Scope and Purpose of Data Processing

  1. Fintecom ensures transparency in the scope of the collected personal data and their use. For this purpose, Fintecom informs about the type and purpose of using the collected personal data.
  2. In order to provide the Services defined in the Terms and Conditions (referred to in the Preamble), and to perform the necessary activities related to the provision of these services, Fintecom processes the entered data, including personal data with the User’s consent. The collected personal data may also be used to provide technical support and for communication with the User.
  3. Data entered by the User of the Services, including, with their consent, personal data means the data entered voluntarily by the User of the Services during: registration of their GG Account, verification of the GG Account or when making bank transfers to a GG Moneybox.
  4. Personal data of the GG User may be processed for marketing purposes only with the separate consent of the User.
  5. Personal data processed in order to provide the GG instant messaging service are collected directly from the data subject and are entered by the User voluntarily during registration. Personal data required to register in GG:
    • Name and surname or nickname,
    • e-mail address,
    • location data (city),
    • gender,
    • date of birth*
    • mobile phone number* *
    • NIP (tax identification number), company name, business profile* * *
    • address* * * *

    6. * The Service is provided only to persons who are 16 years of age or older. By accepting theTerms and Conditions and the Privacy Policy during registration of the GG Account, the Userconfirms that they are at least 16 years of age.
    ** The phone number provided at registration:
    – will be used by Fintecom to send you the SMS verification code required to complete your GG registration,
    – can be used to prompt friends who have your number saved in their phone’s contact list but don’t have you in GG yet,
    -can be used when logging in to GG and when recovering the password to your account.
    *** applies to business accounts only.
    **** visible on the transfer confirmation when verifying the account.

  6. The User is responsible for the accuracy of the personal data provided.Note: If you provide false personal data, some features of the Service may remainunavailable to you until you correct your data.
  7. Personal data processed for marketing purposes shall be obtained directly from the datasubject from among the data provided voluntarily during registration of a GG User Account. The processing of data for this purpose requires the respective consent of the GG User, which may be granted or withdrawn at any time during the use of the services. Important: For marketing purposes, Fintecom processes, with the consent of the GG User, only the email address provided during registration.
  8. Automatic calling systems – systems used by Fintecom and Fintecom’s Partners, to provide the GG Users with messages (display advertisements) that are an integral part of the GG Instant Messenger. The display of advertisements in the application and on the GG websites is based on the legitimate interests of Fintecom and Fintecom’s partners (Article 6(1)(f) of GDPR). The GG User may object to such data processing at any time, which will result in cessation of the provision of the services.
  9. Login Details – personal data of the User in the form of e-mail address, GG number or phone number may be used to log into the Services.
  10. Sending contacts – if the GG User agrees to transfer the contact list from their device (e.g. phone, tablet) to the GG servers, Fintecom will notify the User if the persons on the contact list on their device already have a GG account. The consent to the transfer of the contact list may be withdrawn by the User at any time in the GG settings. Contacts from the device that are on the GG contacts list can be deleted by the User at any time, which will cause these contacts to be deleted from the GG servers as well. The contact list from the User’s device will be used only to suggest to the User that a person from their contact list has a GG account and will not be shared with anyone.
  11. Performance Data – Fintecom processes the GG Number assigned to the GG User upon registration of a GG Account, as well as other data characterising the use of the services, i.e. information about the connection of the GG User’s terminal device with Fintecom’s ICT system, including: computer and logging information, that is so-called system logs, containing the date, time of the visit, scope of each use of the services and IP number of the computer from which the connection was made, as well as data on viewing statistics and website traffic. In order to restrict the use of GG in a manner inconsistent with the Terms and Conditions, and to ensure the safety of other Users, Fintecom may process the anonymised identifier of the GG User’s device.
  12. Location Data – Fintecom, with the consent of the GG User, processes data regarding the approximate location of the User’s device when searching for people to talk to using the “Pair with Random User” feature.
  13. Contacting Fintecom – Communication with the User of the Services via telephone, email and other communication channels may require the User to provide personal data including, but not limited to, the User’s first name, last name, email address, phone number, and GG number. Personal data and the content of the message along with the date and time of correspondence, which are transferred in connection with communication with the User of the Services, are used only for the purpose of providing technical support, answering a question or providing other information.
  14. Fintecom may use the collected data for purposes other than those described in paragraphs 1-13 above, including but not limited to: a) developing new functionalities within the services provided, as well as improving them, b) creating new services, c) protecting Fintecom’s rights, d) if necessary, to fulfill legally justified purposes pursued by Fintecom or data recipients, with such processing not violating the rights and freedom of the data subject.
  15. The data processed by Fintecom is not subject to profiling, unless the GG User has consented to it.

V. Cookies

  1. Fintecom uses cookies to improve the quality of the services provided by Fintecom by storing the preferences of the Service User.
  2. Cookies do not identify the User’s personal data and they do not affect the functioning of the terminal device or its software. Cookies are a string of characters that is sent from the Fintecom ICT system to the User’s computer when the browser accesses the website.
  3. Fintecom uses two main types of cookies:
    a) Session cookies are temporary files that are stored on the User’s terminal device until the User logs out, leaves the website, or turns off the application.
    b) Permanent cookies are stored on the User’s terminal device for the time specified in the parameters of the cookies, or until they are deleted by the User.
  4. Fintecom uses:
    a) “essential” cookies, i.e. cookies that enable the use of services, e.g. authentication cookies used for services that require authentication,
    b) cookies used for security purposes, e.g. used to detect misuse of authentication as part of the services provided,
    c) “performance” cookies, i.e. cookies that allow us to collect information on how our services are used,
    d) “functional” cookies, i.e. cookies enabling the preservation (“remembering”) of the settings selected by the User and personalisation of the User’s interface,
    e) “advertising” cookies, i.e. cookies enabling the delivery of advertising content to the User that is more tailored to their preferences and interests.
  5. Fintecom collects data from cookies for its own purposes.
  6. Fintecom informs that cookies may also come from third parties e.g. entities implementing advertising campaigns on behalf of advertisers.
  7. Cookies will work only if accepted in the browser and not removed from the hard drive.
  8. In many cases, web browsing software (browsers) will allow cookies to be stored on your terminal device by default.
  9. In addition to cookies, Fintecom also uses other technologies to store data saved while using the services provided, such as the Local Storage technology, which is used to store data in a dedicated part of the browser’s memory or other additional modules that extend the functional capabilities of the browser (so-called plug-ins). In principle, the Local Storage technology is similar in its operation and function to cookies with the difference that, unlike cookies, the storage of data in Local Storage is permanent, i.e. it does not have a specific expiration date. Furthermore, the data stored in Local Storage is not sent from the terminal device to the server automatically, as is the case with cookies, but can only be retrieved via the website through which it was previously saved.
  10. Using the tools available in each of the browsers on the market, you can at any time, from the level of privacy settings, change the settings for cookies and other technologies used to store data (including the Local Storage technology), in particular in such a way as to block their automatic support in the settings of individual browsers and plug-ins, or – depending on the technology and tools used – to receive information on their placement in the User’s end device each time. Detailed information on the possibilities and ways of handling cookies is available in the software settings of individual browsers and plugins. Changing the settings may, however, cause some difficulties in using the services or its individual functionalities.

VI. Third Party Applications

Fintecom enables the GG Users to access applications provided by third parties (other than Fintecom). Information collected by Fintecom when the User turns on the application is processed in accordance with this Privacy Policy. Information collected by the provider of such application is covered by that provider’s (third party) privacy policy.

VII. Payments

Fintecom provides the Service User with the ability to use certain paid services in the GG instant messenger through third party (not Fintecom’s) Payment Controllers. The User is obliged to read the terms and conditions of data processing provided by the Payment Controller, which is also the personal data controller of the data provided by the User in order to make the payment. Fintecom does not process personal data necessary to make payments through third party (not Fintecom’s) Payment Controllers. Fintecom does not have access to the User’s payment card data. The Payment card data is stored by the Payment Controller through which the Service User makes the payment.
The following entities may be the payment controller:

VIII. Verifying Transfer

Fintecom processes the GG User’s data necessary for the verifying transfer (in the amount of PLN 0.01) to verify their GG account, made from the User’s bank account only at the User’s request. In connection with the GG User making a verifying transfer, Fintecom processes the following personal data visible on the transfer confirmation:

By making a verifying transfer, the user agrees to the processing of data necessary for the verification of their GG account.

IX. Processing Time

  1. The GG User’s data necessary for using the free GG Instant Messenger Services, including personal data, shall be processed for the period of providing the Services, until the withdrawal of consent or until an objection is raised, but not longer than 2 years from the date on which:
    a) the User’s last login to their GG Account is recorded,
    b) the User’s account is deleted by the User,
    c) the User’s account is deleted by Fintecom due to the User’s violation of the Terms of Service.
  2. For GG numbers purchased by the GG User from the GG store, the period referred to in the paragraph above is respectively 2 years.
  3. Data of the GG User, provided to Fintecom when making the verifying transfer, and data provided during the purchase of GG Premium, is processed for the period of the Services provision, and for 5 years from the end of the provision of the Services in accordance with the AML Act.
  4. The GG User’s data necessary to verify the GG Moneybox User account, such as:
    a) name and surname,
    b) address,
    c) bank account number,
    d) data contained on the ID document,
    e) data on the beneficial owner,
    and other data provided by the User in accordance with the Terms of Service for GG Moneybox Owners, are processed for the period of the Services provision, and for 5 years after termination of the Services in accordance with the Act of 1 March 2018 on Counteracting Money Laundering and Terrorism Financing.
  5. All data regarding payments made by the User of the Services (transfer confirmations, payment confirmations) for the Services provided by Fintecom are processed for the period of the Services provision, and for 5 years after the termination of the Services in accordance with the AML Act.
  6. Personal data of Contributors/Supporters making payments to the GG Users’ Moneyboxes and data related to those payments, such as
    a) name and surname,
    b) address,
    c) bank account number,
    are processed in accordance with the AML Act, for 5 years from the date of the deposit. Deletion of the GG Account by its User is tantamount to withdrawal of consent to the processing of personal data for the provision of services as well as to withdrawal of consent to the processing of personal data for marketing purposes.
  7. After the period indicated in par. 1 – 6 above, the personal data of the Service User will be deleted or anonymised.
  8. By deleting your GG Account, you are not withdrawing your consent to the processing of your personal data given to third party application providers. Withdrawal of consent for the processing of the GG User’s personal data provided to a third party application provider is done in accordance with the terms of the privacy policy of that third party.
  9. Personal data of the GG User used for marketing purposes are processed for the period of service provision, or until consent is withdrawn or objection raised, but not longer than for the period indicated in par. 1 – 5 above.
  10. The GG User’s data, including personal data, may be processed after the termination of the provision of services for the purpose and to the extent necessary to clarify the circumstances of the unauthorised use of the Service, on the basis of the legitimate interest of the controller (Article 6(1)(f) GDPR), however, no longer than for the period indicated in par. 1 – 5 above.

X. Data Sharing by Fintecom

  1. The personal data processed by Fintecom may be transferred to the following categories of recipients:
    a) persons authorised by Fintecom – employees and associates,
    b) entities to which Fintecom commissioned activities related to the provision of services to the Services Users, on the basis of agreements for entrusting the processing of personal data,
    c) Fintecom’s Partners for marketing purposes, with consent of the Services User only.
  2. The personal data processed by Fintecom will not be shared with third parties unless:
    a) the obligation to share personal data results from applicable laws,
    b) the transfer of data serves the purposes of protecting the rights of Fintecom or settling disputes;
    c) The User has consented to the transfer of personal data to third parties.
  3. However, Fintecom informs that:
    a) personal data will be made available to third parties with the help of which Fintecom performs certain functions appropriate to the conduct of day-to-day business, e.g. billing or dispatch of prizes in competitions. Fintecom shall exercise due diligence to ensure that third parties to which personal data is shared, for the purposes indicated above, treat the personal data provided in accordance with the Privacy Policy and in a manner consistent with applicable law,
    b) data, other than personal data, may be shared with third parties in aggregate form, characterising the population of GG Users, with current and potential business partners of Fintecom,
    c) personal data and data other than personal data may be shared with third parties if the GG User uses applications provided by third parties, of which the User is informed before starting using the application. The transfer of data from Fintecom’s ICT system shall in such case take place at the request and risk of the GG User.
  4. The Users’ personal data will not be transferred to third countries.

XI. Service Users’ Personal Data Rights

The Service User has the right to:

  1. Request access to their personal data, their completion, update, rectification, restriction of their processing, transfer to another data controller and deletion at any time, without providing reasons, unless it is contrary to the provisions of generally applicable law. Requests can be submitted to the following email address: iod@gadu-gadu.pl
  2. Object to the processing of their personal data on the basis of the legitimate interest of Fintecom or Fintecom’s partners (Article 6(1)(f) GDPR). Objections can be submitted to the e-mail address: iod@gadu-gadu.pl Filing an objection to the use of automated calling systems (displaying advertisements) will entail the cessation of services.
  3. Withdraw any consent at any time by submitting a request to the following email address: iod@gadu-gadu.pl. Withdrawal of consent does not affect the compliance of the processing of personal data carried out on the basis of consent before its withdrawal.
    a) Withdrawal of consent to the processing of data for the provision of services will entail the cessation of those services. Upon withdrawal of your consent to the processing of data for the provision of services, your personal data will be deleted or anonymised. In order to withdraw this consent, you may contact our Data Protection Officer or delete your GG Account yourself using the appropriate function in the Account settings.
    b) Withdrawal of consent to process the data for marketing purposes will result in discontinuation of contact with the User for the purpose of providing marketing information.
  4. File a complaint to the President of the Personal Data Protection Office in matters related to the processing of their personal data by Fintecom.

XII.Personal Data Security

Fintecom employs technical and organisational measures ensuring the best possible protection of personal data collected by Fintecom against unauthorised access or misuse by unauthorised persons. The technical measures applied are modernised along with the development of new technologies, needs, as well as available security methods. The organisational measures in place ensure that only persons authorised by Fintecom have access to the User’s personal data within the Fintecom structure. Fintecom regularly reviews its compliance with applicable laws and this Privacy Policy. Fintecom cooperates with state
institutions responsible for controlling the collection and processing of personal data and implements their recommendations, if any.

XIII. Changes to the Privacy Policy

  1. Development of technology mean that this Privacy Policy is subject to change, and Fintecom will inform of any such changes with 15 days’ notice.
  2. Any change to the Privacy Policy will become effective:
    a) in 15 (fifteen) days from the date of notification of the change or at any other time indicated by Fintecom, but not less than 15 (fifteen) days; in the event that the GG User does not consent to the change, the User shall provide Fintecom with an appropriate statement, including through Fintecom’s ICT system, before the change takes effect and shall cease using the Service from that date.
    b) immediately upon notice of the change, or within such other time as Fintecom may indicate, if the changes concern the provisions of the Privacy Policy that do not affect the Service Users