Privacy Policy
Version 2026-08-24. In force from 24 August 2026.
This document describes what data we collect, why, how long we keep it and what you can do about it. It is written to be read — without cross-references you have to assemble yourself.
1. Who is the data controller
The controller is PRZEDSIĘBIORSTWO ACTION Jan Gołąb, ul. gen. Władysława Andersa 6D/13, 66-400 Gorzów Wielkopolski, Poland, VAT ID (NIP) PL5992602962, REGON 080085712.
Contact for data protection matters: aaccttiioo@gmail.com.
We have not appointed a Data Protection Officer — we are not required to. All matters are handled by the controller personally, at the address above.
2. The principle we follow
We do not collect data we do not need. Therefore:
- browsing the Service requires no account, and we collect nothing about you beyond technical connection data,
- creating an account needs only an e-mail address and a password — we do not ask for your name, age or school,
- invoicing data is collected only at your first top-up, not before,
- we do not profile, do not build advertising profiles and do not sell data.
3. What we collect and on what basis
| Data | Purpose | Legal basis (GDPR) | | :---- | :---- | :---- | | E-mail address, password (as an irreversible hash) | Running the account, sign-in, access recovery | Art. 6(1)(b) — performance of a contract | | Address confirmation date, Terms acceptance date and version | Showing that a contract was concluded and on what terms | Art. 6(1)(c) and (f) | | Last activity date | Deleting unused accounts (Art. 5(1)(e) — storage limitation) | Art. 6(1)(c) | | Token history: purchases, spending, refunds | Settling the service, handling complaints | Art. 6(1)(b) and (c) | | Invoicing data: name, address, country, VAT ID (businesses) | Issuing the sales document | Art. 6(1)(c) — tax obligation | | Generated worksheets and their parameters | Access to the worksheet and repeat downloads | Art. 6(1)(b) | | IP address, server logs, request timestamps | Security, abuse prevention, diagnostics | Art. 6(1)(f) — our legitimate interest | | Marketing consent (if given) | Messages about new materials | Art. 6(1)(a) — consent, withdrawable at any time |
Providing data is voluntary, but without an e-mail address an account cannot be run, and without invoicing data a sales document cannot be issued.
4. Password and codes
We do not store your password. The database holds the output of Argon2id — an irreversible operation. Nobody, including the controller, can read your password; a reset sets a new one rather than recovering the old one.
Confirmation codes sent by e-mail are likewise not stored in plain form. They are valid for 15 minutes, single-use and attempt-limited.
5. How long we keep data
| Data | Period | | :---- | :---- | | Account with an unconfirmed address | 7 days from creation, then deleted | | Active account | Until you delete it | | Unused account | 5 years from last activity; two warnings by e-mail (30 and 7 days ahead), then personal data removed | | Confirmation codes | 15 minutes of validity; records purged after 7 days | | Sales documents and the data on them | 5 years from the end of the tax year — a legal requirement, not our choice | | Token ledger entries after account deletion | Kept without any link to your identity | | Server logs | Up to 90 days |
6. What "deleting the account" means exactly
We delete the identity and keep the record of financial events — because tax law requires it, and tax law outweighs our preference.
After deletion:
- gone: e-mail address, password, invoicing data, generated worksheets, active sessions, confirmation codes, marketing consent,
- kept: token operations linked only to a random identifier, with no data that could point to a person, and issued sales documents, which we delete on their own schedule (5 years from the end of the tax year).
Signing in to a deleted account is impossible, and the e-mail address cannot be recovered from it.
7. Who we share data with
We use services without which the Service could not run. Each of them processes data on our instructions and only to the extent its role requires:
| Who | Purpose | Where | | :---- | :---- | :---- | | Server provider (hosting) | Running the Service and the database | European Union | | Transactional e-mail provider | Sending confirmation codes and notices | See note below | | Payment provider | Handling payments — we never see card details | See note below | | Accounting office / accounting system | Issuing and recording sales documents | Poland |
Note on transfers outside the EEA. Some providers may process data outside the European Economic Area. Such transfers rely on Standard Contractual Clauses approved by the European Commission or on an adequacy decision. We will provide the current list of providers on request sent to the contact address.
We do not sell data and do not share it for third-party marketing. We may disclose it to authorised bodies where required by law.
8. Your rights
You have the right to:
- access your data and receive a copy,
- rectify inaccurate data,
- erasure ("right to be forgotten") — subject to documents we must keep for tax purposes,
- restrict processing,
- data portability — the account panel has a button that downloads your data as JSON, with no need to write to us,
- object to processing based on legitimate interest,
- withdraw marketing consent at any time, without affecting the lawfulness of processing before withdrawal,
- lodge a complaint with the President of the Polish Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw) or with the supervisory authority in your country of residence.
Most of these you can exercise yourself, from the account panel: change address, change password, sign out everywhere, download your data, delete the account. The rest we handle by e-mail, within 30 days.
9. Cookies and browser storage
The Service uses only mechanisms strictly necessary for it to work:
| What | Purpose | Consent required |
| :---- | :---- | :---- |
| Browser local storage (localStorage) — session token | Keeping you signed in; without it you would sign in on every click | No — strictly necessary for the service you requested |
| Local storage — selected interface language | Remembering your language between visits | No — a convenience you set yourself |
We use no analytics, marketing or tracking cookies. We embed no third-party analytics, no social media buttons and no advertising pixels. That is why there is no consent banner — there is nothing to consent to.
This data is stored in your browser, not on our server. You can delete it at any time in your browser settings; the effect is being signed out and returning to the default language.
If we ever add a tool that requires consent, a separate request will appear before it runs, and this document will be updated.
10. Security
- All communication with the Service uses encrypted HTTPS.
- Passwords are stored only as an irreversible Argon2id hash.
- Sessions expire, and changing the password invalidates them on all devices.
- Only the controller has access to the production database.
No system is fully secure. If a personal data breach occurs that is likely to result in a high risk to your rights, we will notify you without undue delay, and the supervisory authority within 72 hours.
11. Children
The Service is intended for adults — parents, teachers, tutors. Accounts are not created by children and we do not knowingly collect data of persons under 16. Worksheets are used to work with children, but children's data never enters the Service: we do not ask for pupils' names, class or school.
12. Changes to this policy
We will announce material changes to the account e-mail 14 days in advance. Every version carries a date shown at the top of the document.