Last Updated: March 4, 2025
Welcome to […]. At Properly, we respect your privacy and are committed to protecting your personal data. This Privacy Notice is a part our Privacy Policy which explains how we collect, use, disclose, and safeguard your information when you visit our Website. Please read this Privacy Notice carefully. If you do not agree with the terms of this Privacy Notice, please do not access our Website.
- DEFINITIONS
All terms not defined in this Privacy Notice shall have the meaning as defined in the Terms of Service. The following terms used in this Privacy Notice shall have the meaning set forth below:
- GDPR – General Data Protection Regulation 2016/679 of 27 April 2016.
- EEA – European Economic Area.
- Personal Data – information about identified or identifiable natural person as defined in Article 4(1) of the GDPR.
- Privacy Notice – this Privacy Notice.
- Properly – Properly spółka z ograniczoną odpowiedzialnością (limited liability company) with its registered office in Warsaw, a company established under the laws of Poland, address: Augusta Cieszkowskiego 1/3, lok.8, (01-636) Warsaw, Poland, entered into the register of enterprises kept by the National Register Court, registered under no. KRS 0000940970, NIP (tax ID) 5272982244, capital PLN 5,000.00.
- Terms of Service – Terms of Service for the Properly Website and the Services available at […].
- Services – services provided on the Website indicated in the Terms of Service.
- User – the User as defined in the Terms of Service, i.e. any natural person visiting the Website or using one or more services or functionalities described in the Terms of Service.
- Website – a website operated by Properly on which the Services are provided, available at: […].
Terms relating to personal data not defined above have the meaning as defined in the GDPR.
- PRIVACY NOTICE
- CATEGORIES OF PERSONAL DATA
Properly uses the User’s data only when it is lawful under the applicable privacy law and only to the extent it is necessary to achieve its purposes. Properly collects and uses the following types of User’s personal data in connection with their use of the Website and the Services.
- Customer support data
The customer support data includes data collected and used in connection with customer support provided by Properly to the User. For example, this may include communication with us as regards the User’s rights as a Consumer or the User’s other requests, questions and queries.
- Social media data
The social media data includes data collected and used in connection with the User’s interactions or visits on Properly’s social media profiles. For example, this includes the User’s nickname when they send us a direct message on Telegram and the contents of such message. Please note that social media platforms are independent data controllers. The User’s use of such platforms is subject to the privacy policies and terms and conditions of such providers of such social media platforms. Properly encourages the User to consult such documents before using such services. Properly is not responsible for the privacy policies and practices of such social media platforms.
- Tracking data
The tracking data includes data collected and used in connection with use of cookies and similar technologies, such as pixels, beacons, tags, device IDs, Local Shared Objects or tracking pixels. For example, this includes personal data used when Properly uses cookies to remember the User’s settings such as preferred language. Please consult the Cookie Notice to learn more about cookies and similar technologies.
- Technical data
The technical data includes data collected and used in connection with the ICT Systems. For example, this includes the User’s device information, information about the User’s operating system or other software used by the User’s device, hardware details, browser used, location, statistics derived from this data and so on. Generally speaking, most of this information is anonymous data. However, in some cases it may be used to identify the User, for example in combination with other data.
- PURPOSES AND LEGAL GROUNDS OF PROCESSING
Properly collects and processes the User’s personal data in connection with their use of the Website and the Services. As a general rule, Properly collects the User’s personal data directly from the User and from their devices. Generally speaking, Properly processes the User’s personal data to the extent necessary to provide the Services, ensure smooth operation of the Website or for other legitimate purposes. Please find the description of such purposes and legal grounds for processing in greater detail below.
- Use of the Website
Properly processes the User’s personal data, such as IP address or other online identifiers, for the purpose of rendering electronic services within the scope of providing Users with access to the contents collected on the Website. The legal ground for such processing is the necessity of processing for performance of a contract with the User (Article 6(1)(b) GDPR).
- Security
Properly processes the User’s personal data to ensure the security of the Website and our ICT systems and to manage them. For example, Properly records some of the User’s personal information in a system logs (special computer program used for storing a chronological record containing information about events and actions related to the ICT Systems used). The legal ground of the processing is a legitimate interest (Article 6(1)(f) GDPR), which consists of the need to ensure security and safety of Properly’s ICT systems used in connection with the Website and the Services.
- Social media interaction
Properly processes the User’s personal data for the communication and marketing purposes. For example, to inform the User about Properly’s activity and promote various events, services and products. Properly also processes the User’s personal data to communicate with the User, to promote its brand and for direct marketing purposes. The legal basis of the processing is a legitimate interest (Article 6(1)(f) GDPR), which consists of improving the services, communication with the Users, promotion and marketing. Where required under statutory law, Properly will be conducting direct marketing activities only with the User’s consent.
- Analytics
Properly processes the User’s personal data for analytical and statistical purposes. The legal ground for such processing is a legitimate interest (Article 6(1)(f) GDPR), which consists of conducting analyses of the User’s activity, as well as of the User’s preferences in order to improve functionalities and services provided by Properly, like visit duration or pages visited. Where required under statutory law, Properly will be conducting analytical activities only with the User’s consent.
- Compliance
Properly uses the User’s personal data to ensure compliance with the applicable law. For example, this includes processing of the User’s personal data to comply with consumer protection law. Properly also processes the User’s personal data to comply with the GDPR, for example when the User submits the User’s request as regards the User’s privacy rights and for accountability purposes. The legal ground for processing is the necessity of processing for compliance with appropriate legal obligation under applicable statutory law to which Properly is subject (Article6(1)(c) GDPR).
- Legal rights
Properly may process the User’s personal data, if necessary, to establish and assert claims or to defend against claims. The legal ground for such processing is a legitimate interest (Article 6(1)(f) GDPR), which consist of the protection of Properly’s legal rights.
- Cookies
Properly may use the User’s personal data in connection with the use of cookies or similar technologies for purposes described in sections above. The legal grounds for processing the User’s personal data are (depending on the type of cookies) the User’s consent (Article6(1)(a) GDPR) or necessity of processing for performance of a contract with the User (Article 6(1)(b) GDPR). Please consult the Cookie Notice to learn more about cookies and similar technologies.
- DATA STORAGE
Properly stores the User’s personal data only as long as necessary for the purposes Properly collected it. This means that the duration of storage depends on the purpose of processing. For example, Properly stores the User’s personal data for the period of time when Properly provides the User the Services in accordance with the agreement Properly has entered with the User subject to the Terms of Service. Properly stores personal data processed on the basis of legitimate interest(s), our or those of a third party, until the User lodge an effective objection to such processing. Similarly, when Properly processes the User’s personal data on the basis of the User’s consent, Properly stores it until the User withdraw the User’s consent.
The duration of storage or use of the User’s data may be extended in certain situations. For example, Properly may store the User’s personal data after the User terminated the agreement with Properly when required by law. Properly may also continue to store and use the same dataset if Properly uses it for a different purpose and on a different legal basis, for example to assert possible claims or to defend against claims (if Properly has a legitimate interest to do so).
After the end of the period of data storage, Properly permanently deletes or anonymizes the User’s personal data.
- DATA RECIPIENTS
As a general rule, Properly does not share the User’s personal data unless it is necessary. For example, Properly may share the User’s personal data for example in connection with the provision of the Services under the Terms. Properly may disclose the User’s personal data to the following categories of recipients:
- external developers or software solution providers;
- marketing and advertising services providers;
- analytical tools providers;
- data storage providers;
- professional advisors, such as lawyers, accountants and tax advisors.
Properly requires its partners to keep the User’s data secure and confidential under the terms that ensure level of protection essentially equivalent to that described in this Privacy Notice. Please note that some of them and some act as independent controllers of the User’s personal data. If they are controllers of the User’s data, relevant privacy policies and terms and conditions of such controllers may apply. Properly encourages the User to consult such documents before using such services. Properly is not responsible for the privacy policies and practices of the third parties.
As a general rule, Properly’s partners are located in the European Economic Area. However, some of them may be located outside of the EEA, for example in the United States. Please consult Section 6 for more details on transfers of the User’s personal data outside of the EEA.
- DATA TRANSFERS OUTSIDE THE EEA
The level of protection for the Personal Data outside the European Economic Area (EEA) differs from that provided by the EU law. For this reason, Properly transfers the User’s personal outside the EEA only when necessary and with an adequate level of protection, primarily by cooperating with processors of the personal data in countries for which there has been a relevant European Commission decision finding an adequate level of protection for the Personal Data. Alternatively, Properly may use the standard contractual clauses issued by the European Commission. If the User wants to learn more about these safeguards or learn where they have been made available, they should contact Properly.
- REQUIREMENT TO PROVIDE PERSONAL DATA
In some cases provision of the User’s personal data is mandatory by law or necessary in order to carry out the User’s request or to perform a contract by Properly with the User. If the User fails to provide Properly with the User’s personal data in such situations, Properly may not be able to carry out the User’s request, perform a contract with the User (or enter into it) or comply with the law. In some cases, this may mean that Properly will terminate the contract or stop its engagement with the User. For example, if the User do not provide the User’s personal data necessary for the consumer complaint procedure, Properly may not be able to handle the User’s complaint.
In other cases, provision of the User’s personal data is voluntary. If the User fails to provide Properly with the User’s personal data in such situations, Properly may not be able to carry out the User’s request or achieve its goal. For example, if the User do not share the User’s contact details with Properly, Properly may not be able to contact the User.
- THE USER’S RIGHTS
To exercise the User’s right(s) contact Properly
The User can contact Properly using one of the following channels:
- e-mail: hello@properly.studio;
- Telegram: [______] - to use this channel, the User must have an active Telegram account;
- postal mail: Augusta Cieszkowskiego 1/3, lok.8, (01-636) Warsaw, Poland.
Properly may contact the User using the same contact channels as set out above.
Depending on where the User lives, the User may have different privacy rights. If the EU law applies to the User, the User have the following rights under the GDPR:
- Right to access information
The User can request from us information about the processing of the User’s personal data. The User can also request a copy of the User’s personal data that Properly processes from it free of charge.
- Right to correct the User’s data
The User can request that Properly rectifies the User’s personal data that Properly uses, for example, when it is inaccurate. The User can also complete the User’s data if it is incomplete.
- Right to be forgotten
The User can request that Properly erases the User’s personal data under certain conditions prescribed by law. However, this is not an absolute right and it does not apply in certain conditions, for example, when use of the User’s data is necessary for the establishment, exercise of legal claims by Properly.
- Right to restrict
The User can request that Properly stops processing the User’s personal data, with the exception of storage, under certain conditions prescribed by law. However, this is not an absolute right, and it does not apply in certain conditions, for example when use of the User’s data is necessary for the protection of the rights of another natural or legal person.
- Right to data portability
The User can request that some of the User’s personal data is provided to the User, or to another controller, in a commonly used and machine-readable format. This right applies where Properly uses the User’s data based on the User’s consent or a contract and if the processing of the User’s data is carried out by automated means.
- Right to withdraw consent
The User have the right to withdraw the User’s consent to the processing of the User’s personal data. The User can do this at any time. If the User withdraw consent, Properly will stop using the User’s personal data where the basis for processing is consent. Withdrawal of consent does not affect the lawfulness of processing the User’s data on the basis of consent before withdrawal. The right to withdraw consent applies only to the extent that the User’s personal data is processed on the basis of consent.
- Right to object
The User have the right to object to the processing of the User’s personal data on the basis of legitimate interest(s), our or those of a third party. The User can do this at any time. If the User raises an objection, Properly will stop using the User’s personal data where the basis for processing is our legitimate interest. In exceptional circumstances, Properly may continue to use the User’s data despite the User’s objection. This exception does not apply when the User object to the processing of data for direct marketing purposes, i.e. if the User objects to it, Properly will stop processing the User’s personal data on this basis.
- Right to lodge a complaint
The User can lodge a complaint with the supervisory authority dealing with the protection of personal data. The User can lodge such complaint with the User’s local data protection authority or with Data Protection Inspectorate, a data protection authority based in Warsaw.
- AMENDMENTS
The Privacy Notice shall be reviewed on an ongoing basis and updated as necessary, for example for legal reasons or to reflect changes in the Terms of Service.
The current version of the Privacy Notice has been adopted and is effective as of […].
