Privacy Policy — FaktuPro

Effective date: March 22, 2026
Last updated: March 22, 2026

1. Data Controller

The controller of your personal data is:

(hereinafter: "Controller", "we")

2. What Data We Process

We process data necessary for the operation of the Application and the provision of services.

2.1 Account Data

email address
first and last name
account settings (e.g., language, timezone)

2.2 Login and Authentication Data

login credentials (stored in encrypted form)
Apple Sign In data
device tokens (push notifications)

2.3 Business and Client Data

business activity data
client data entered by the user

2.4 Document and Financial Data

invoices, corrections, and other documents
bank account data
data necessary for issuing documents

2.5 Subscription Data

Apple transaction identifiers
subscription status

2.6 AI Feature Data (Smart Invoice)

query content
result generated by the system

2.7 Technical Data

data necessary for system operation and security

3. Purposes and Legal Bases for Processing

We process your data for the following purposes:

providing services and managing your account — Art. 6(1)(b) GDPR
fulfilling legal obligations — Art. 6(1)(c) GDPR
ensuring security and system operation — Art. 6(1)(f) GDPR

4. Who We Share Data With

Your data may be shared with:

infrastructure providers (hosting in the EU)
Apple (subscription and notification management)
AI technology providers (e.g., OpenAI)
public systems (KSeF, GUS, VAT White List)
technical service providers (e.g., email)

5. Data Transfers Outside Europe

Some data may be transferred outside Europe.

This applies in particular to:

AI technology providers
Apple

Data may be transferred outside the European Economic Area (EEA), i.e., outside the countries of the European Union and associated states.

In such cases, we apply appropriate safeguards, such as standard contractual clauses.

6. How Long We Retain Data

We retain data:

for the period of using the Application
for the period required by law
for the period necessary to pursue or defend claims

After account deletion, data is deleted or anonymized, except for data that must be retained in accordance with the law.

7. Data Security

We apply appropriate technical and organizational measures to protect data, including:

data transmission security
access control
protection of stored data
system operation monitoring

Detailed information can be found in the Security Policy.

8. Data on the User's Device

The Application may store data locally on the user's device to ensure its operation.

This data is protected by the device's system mechanisms.

9. What We Do Not Do

we do not conduct user analytics
we do not use tracking
we do not sell personal data
we do not use data for advertising purposes

10. Your Rights

You have the right to:

access your data
rectify your data
delete your data
restrict processing
data portability
object to processing

You may also file a complaint with the supervisory authority — the President of the Personal Data Protection Office (PUODO).

11. Changes to This Policy

We may update this policy.

We will notify you of material changes within the Application.

12. Contact

For matters related to personal data:

13. Effective Date

This Policy is effective as of: March 25, 2026