Privacy Policy

1. Introduction

This Privacy Policy outlines how the System Manager application (available at app.smanager.eu and via mobile App Stores) collects, processes, and protects your personal data. This policy applies to Users acquiring access to the Application for consumer purposes (B2C).

2. Data Controller

The Controller of your personal data is:

3. Purpose of Data Processing

We process your personal data for the following specific purposes:

• Service Provision: Implementing the subscription and ensuring the correct operation of the Application.
• Account Management: Managing the User’s account within the Application.
• Billing: Issuing invoices upon request for sales made via the Web Application.
• Communication: Contacting the User regarding service updates or support.

4. Legal Basis for Processing

We process your data based on the following legal grounds under the GDPR:

• Contractual Necessity: Processing is necessary for the performance of the contract (Art. 6(1)(b) GDPR).
• Legal Obligation: Processing is necessary for compliance with legal obligations, such as tax regulations (Art. 6(1)(c) GDPR).
• Legitimate Interest: Processing is necessary for the legitimate interests of the controller (Art. 6(1)(f) GDPR).

5. Data Sharing and Recipients

Your data may be transferred to the following third parties solely for the purposes of service delivery:

• Payment Operators: Data is transferred to PayU S.A. for processing payments made via the Web Application.
• App Store Operators: Data is shared with Google LLC (Google Play) or Apple Inc. (Apple App Store) to the extent necessary for license authorization.
• Service Providers: Entities providing IT services to the Seller to maintain the Application.

6. Data Retention

• Active Data: Personal data will be stored for the duration of your subscription and for the time required by applicable legal obligations (e.g., tax regulations).
• Expired Subscriptions: User data and configurations are stored for one month following subscription expiration to allow for renewal. After this period, the Seller reserves the right to permanently delete data from active systems.
• Backups: Data may be stored in backups for a limited time after deletion from active systems, in accordance with our backup retention policy to ensure security.

7. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

• The right to access your data.
• The right to rectify (correct) your data.
• The right to delete your data.
• The right to restrict processing.
• The right to data portability (transfer data).
• The right to object to processing.

You also have the right to lodge a complaint with the President of the Personal Data Protection Office if you believe your rights have been violated.

8. Changes to This Policy

The Seller reserves the right to amend this Privacy Policy. Users will be informed of any changes electronically via the email address provided during registration or purchase, with appropriate advance notice. Continued use of the Application after changes signifies acceptance.

9. Contact Us

If you have questions regarding this policy or wish to exercise your rights, please contact our support department:

• Email: support@smanager.eu
• Mailing Address: AQ Krystian Bączek, St. Powstańców 103/23, 05-800 Pruszków, PL.