Effective as of May 6, 2024

Listonic Privacy Policy

INTRODUCTION

We at Listonic Sp. z o.o, a Polish Ltd. company (“us”, “we”, or “our”), are committed to acting responsibly and prioritizing the confidentiality and security of your personal information. This Privacy Policy outlines the principles we adhere to when processing personal data across the various activities of Listonic, particularly in connection with the operation of our Apps and Services as defined and governed by the Terms of Services (https://listonic.com/terms-of-service/) that are supplemented by this document. This Privacy Policy covers all our digital service offerings, regardless of their functionality or the platform through which they are accessed, ensuring a consistent and compliant user experience across our products’ suite.

In our commitment to transparency and the responsible handling of your personal information, Listonic Sp. z o.o incorporates a Consent Management Platform (CMP) across our Apps and Services. A CMP is a system designed to manage users’ preferences regarding data processing, ensuring that you have full control over what information is used and for what purposes. This system clearly outlines the objectives of marketing consents, allowing us to tailor our communication and services to your interests without compromising your privacy. Through this approach, we aim to enhance your experience by utilizing non-sensitive information – including information that cannot be classified as ‘personal information’ under the GDPR and/or further legal requirements, to inform you about products or services that you may find interesting.

We are issuing this document to fulfill our information obligations under the regulations. Reading this Privacy Policy is a prerequisite for using our services, as your acknowledgement and acceptance of it is required before you use our Apps or Services We also refer to this Privacy Policy when collecting information or consent from you and during our correspondence.

Please read this document carefully to understand when, what, and why we process your personal data and kindly note that according to privacy laws, our legal basis for processing your data isn’t limited to your consent. This consent-based data processing is largely covered by our CMP mechanism mentioned above and respective privacy notices. Therefore this Privacy Policy focuses on further legal grounds often apply, in particular when data processing is necessary to supply App’s functionalities and render Services for you. In other words – when it involves the performance of a contract concluded with you or when we may be otherwise obliged to process your personal data to fulfill legal obligation.

DATA CONTROLLER AND DATA PROTECTION OFFICER

At Listonic Sp. z o.o., your privacy is our priority. As the data controller, we are responsible for managing how your personal information is processed when you use our Apps or Services. This means we determine the purposes and means of processing your personal data, always aiming to uphold the highest standards of privacy and data protection in accordance with this Privacy Policy.

To ensure your personal data is treated with the utmost care and in line with the General Data Protection Regulation (GDPR), we have appointed a dedicated Data Protection Officer (DPO). Our DPO oversees our data protection strategy and its implementation to secure compliance with GDPR requirements.

Should you have any inquiries or concerns about how your personal data is handled, or wish to exercise your data protection rights, our Data Protection Officer (Tomasz Wekwart) is readily accessible. You can reach out directly for assistance with any matter related to data processing or GDPR at:

E-mail: [email protected] 

We encourage you to contact our DPO with any questions or requests regarding your personal data. Our commitment is to ensure transparency, accountability, and your right to privacy throughout your experience with our Apps and Services.

CATEGORIES, PURPOSES AND LEGAL BASIS OF DATA PROCESSING

We typically collect information directly from you when you engage with the Listonic service, such as when you download and use our Apps or Services, register for an account, utilize certain App’s functionalities (e.g., such as lists, texts, notes, photos, and optionally uploaded documents like receipts for expense tracking) or contact us. We do not use any information you provide to us (including profiling) for the purpose of automated decision-making but we may use these information to provide you with content that may be of higher relevance to your needs or interests when you use or Apps or Services.

Your data may be collected and processed through direct interactions with our Apps and Services, such as when you sign up, use specific features of our Apps, or subscribe to our newsletter. While we primarily gather data directly from you, there are instances where we might receive information from third parties, especially when integrating our Apps with other services or platforms you may use.

The extent of our relationship determines which parts of this Privacy Policy apply to you, focusing on the functionalities and services you engage with or your communication towards us.

When you download and engage with our Apps or Services without creating an account  –  we will process only those of your personal information that you decide to provide, which – depending on certain App’s of Service’s features, includes, but is not limited to, your name, billing data (or information about your payment via a respective marketplace), email address and/or telephone number – your contact information and contact information from your address book (if you choose to do so) and further voluntary information on your age, gender and language, information of cash bonuses or other incentives that may be received. 

Additionally, for the purposes of proper functioning of our Apps’ features and for presenting third-parties marketing information that will be relevant to your interests, we may also process any content you may input or upload to our App (and information included in this content), such as lists, texts, information on interactions with Apps’ content, notes, photos, and scans of documents and receipts. As a result of processing these information, we may display suggestions about products of particular brands, present targeted promotions that match your interests and display banners, which are an indispensable part of provisioning our Apps and Services free of charge. Paid versions of our Apps and Services, without displaying such marketing information and processing them may be available.

Depending on your devices used to access our Apps or Services and it’s settings, we may process further information on App or Services usage – technical, analytical, and statistical information about your device and it’s configuration in order to ensure the correct operation of our Apps or Services such as device’s IP address and geolocation, information contained in cookies or other similar technologies, you activity within our Services and session data, data of the Internet browser, and the settings of the App or Services.

This data is processed to prepare and conclude a contract with you for the provision of electronic services (Article 6(1)(b) of the GDPR), comply with tax and legal obligations (Article 6(1)(c) of the GDPR), manage the quality of our services, and for analytical purposes (Article 6(1)(f) of the GDPR).

Providing this data is voluntary but necessary for us to provide you with our Services and Apps’ functionalities and their correct or enhanced performance. We will keep this data for the period of performance of the contract and maintenance of your account or until the statutory limitation periods for claims related to this contract are reached. 

When you register for an account  – for the provision of Services requiring a user login (registering for an account), we additionally process information necessary for account registration: email address and password or information about your account at platform used for registration and login purposes (such as Facebook, Google or other similar ones).

Providing this data is voluntary but necessary for us to provide you with our Services and Apps’ functionalities requiring login information. We will keep this data for the period of performance of the contract and maintenance of your account or until the statutory limitation periods for claims related to this contract are reached. 

When you order a newsletter – we process your name and email address.

We will do so in our so-called legitimate interests, i.e. promoting our brand and direct marketing of our services (Article 6(1)(f) GDPR).

Your provision of data is then voluntary, but necessary for us to deliver the newsletter to you.

We will process this data for the duration of our business, but no longer than until we revoke your consent to send you the newsletter.

When you contact us – we process your: name, email address, phone number or other content or information you provide to us during this contact.

We will do so at your request, which we understand to be your explicit consent to process this data, or on the basis of our so-called legitimate interest, which is to provide you with answers to the questions you ask us (Article 6(1)(a) and (f) GDPR).

Providing your personal data is voluntary, but necessary to provide you with an answer.

We will keep this data for the duration of the case or until the statute of limitations for claims related to the subject of your contact.

ENTRUSTMENT OF PROCESSING, SHARING OR TRANSFER OF DATA

The fulfillment of the purposes of processing your data (in particular – proper functioning of Apps’ features and Services) may require entrusting the processing of this information to entities that work with us so that we can provide our services to you, such as Amazon, Google or Microsoft. Such service providers will only process your personal information in accordance with our instructions under the data processing agreements we have entered into.

We may also share your personal data with other entities as separate controllers of your data, e.g. courts or government authorities for purposes related to fulfillment of legal obligations or safeguarding our interests.

Depending on the purpose of processing, these may be other entities, and so:

1. when you use our Apps and when we render Services for you – IT system providers, technology services providers and email operators, hosting companies, entities covered by your marketing consent – depending on information presented in relevant CMP consent applicable for certain App or Service you may be using;
2. when you purchase subscriptions and when we set up a Listonic account for you, and when we provide services to you – payment operators or marketplaces where you access our Apps or Services, our subcontractors and others involved in operating our systems, companies providing IT and technology services;
3. when we send you a newsletter – IT system providers and email operators;
4. when you contact us – email or postal operators or couriers, IT service providers and IT systems we use to operate the service, and our consultants and advisors (including legal advisors) – to the extent necessary.

We will also be able to anonymize your personal data (it will then cease to be ‘personal data), in order to present aggregated business or statistics information about processes and/or issues related to our Apps functionalities.

When providing services through our Apps or Services, especially with regard to the technological functionalities available via our Apps, we might proceed with the so-called data transfer outside the European Economic Area (Article 46(2)(c) of the GDPR), which we will do primarily on the basis of standard contractual clauses approved by the European Commission. This is a pre-approved set of obligations that ensure a level of personal data protection adequate to the ones required by the EU.

These entities are reputable service providers such as, most notably, Google Inc. for providing cloud solutions or Amazon.

SECURITY

We protect the confidentiality, integrity, and availability of your personal information. Therefore, we have implemented security measures (known as organizational and technical measures) to confirm that we operate in accordance with the best standards and applicable legal requirements. We have also developed information security policies, which include instructions and measures to protect your personal data from destruction, loss, alteration, or unauthorized access, including encryption of data in transit and at rest, regular security audits, and access control measures.

Your payment data is processed by relevant marketplaces where you purchase our subscriptions in. Those are entities independent from us, so we also do not have direct access to your payment data.

Our Apps and Services may contain links to and references to other websites or applications. We are not responsible for the content of third-party websites and applications or their personal data processing practices. We recommend that you familiarize yourself with them before submitting data there.

YOUR RIGHTS

You have the right to access the personal data that we process in Listonic about you, as well as a copy of it, subject to certain exceptions provided by law.

You also have the right to have personal data that is outdated or inaccurate corrected, and to have the processing of your personal data erased or restricted, unless we are authorized or required to continue processing it in accordance with respective legislation, including tax and accounting laws, or we may process it in connection with defending against possible claims or proceedings.

In certain cases, you also have the right to obtain personal data in a structured, commonly used machine-readable format and to request Listonic to transfer such personal data to another data controller (data portability).

You also have the right to withdraw any consent you have given, but without prejudice to the lawfulness of processing based on consent prior to withdrawal.

To exercise these rights or withdraw your consent, contact us at: [email protected]

If you believe that we are improperly implementing data protection laws, please contact us. However, you also have the right to file a complaint with the supervisory authority, which in Poland is the President of the Office for Personal Data Protection (Prezes Urzędu Ochrony Danych Osobowych).

COOKIES

Our website uses so-called cookies (cookies and similar solutions) for the proper operation of all its functions (our cookies). Cookies are small packets of information stored on your device depending on your browser settings, but they do not allow us to identify users of the site. These cookies may record, for example, your identification number, IP address, device location or digital footprints, pages visited or technical information.

We may also use cookies from other service providers that provide analytical and statistical information (e.g. Google Analytics, Microsoft Clarity, Equativ), or marketing and social media providers that may have access to them.

You can make changes to cookies in your browser, and we treat failure to do so as consent to the use of cookies.

VALIDITY AND CHANGES TO THIS POLICY

We may amend this Privacy Policy at any time by posting a revised version on our website, within marketplaces where our Apps are available and, if applicable or necessary, by emailing you the email address associated with your account or by providing an in-product notification.

CONTACTS

Listonic Sp. z o.o.
ul. Piotrkowska 99
90-425 Lodz
POLAND
[email protected]