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Privacy Policy

The rules for processing personal data in the Roadence service, in accordance with the GDPR Regulation (EU) 2016/679 and the Personal Data Protection Act.

Effective from: 12 lipca 2026 r.

§ 1. Data controller

  1. The controller of personal data is Gracjan Szymczak conducting sole proprietorship business under the name PXL MEDIA Gracjan Szymczak, ul. Turoszowska 9/15, 91-025 Łódź, VAT ID 9472018058, REGON 542668215, entered in CEIDG, operating under the Roadence brand (the "Controller").
  2. Contact for data protection matters: e-mail kontakt@roadence.com. No data protection officer (DPO) has been appointed - there is no such obligation.

§ 2. Definitions

  1. Personal data - information about an identified or identifiable natural person (Article 4(1) GDPR).
  2. Processing - any operation performed on data (collection, storage, sharing, deletion, etc.).
  3. Processor - an entity processing data on behalf of the Controller under a data processing agreement (Article 28 GDPR).

§ 3. Purposes, legal bases and retention periods

  1. Order and contract fulfillment (e-mail, first and last name, vehicle registration number, route and date data, order scope). Basis: Article 6(1)(b) GDPR. Period: for the duration of fulfillment and then until claims become time-barred.
  2. Legal obligations (tax settlements, accounting, complaints). Basis: Article 6(1)(c) GDPR. Period: for the period required by law (as a rule 5 years counting from the end of the tax year).
  3. Handling inquiries, pursuing and defending claims, security and development of the Service. Basis: Article 6(1)(f) GDPR (legitimate interest). Period: until an effective objection or until the purpose ceases.
  4. Marketing and reminders (about vignette/insurance expiry, offers). Basis: Article 6(1)(a) GDPR (consent), double opt-in model. Period: until consent is withdrawn.
  5. Statistics and analytics (with cookie consent). Basis: Article 6(1)(a) GDPR. Period: until consent is withdrawn or cookies expire.
  6. AI assistant and route planning (the content of queries and route data is transmitted to the language-model provider in order to select charges and prepare recommendations; the scope of personal data sent to the assistant is limited to the necessary minimum). Basis: Article 6(1)(b) and Article 6(1)(f) GDPR. Period: for the duration of handling the query.
  7. The vehicle registration number constitutes personal data to the extent that it enables the identification of a natural person.

§ 4. Voluntary provision of data

  1. Providing data is voluntary but necessary to conclude and perform the contract; failure to provide it makes order fulfillment impossible. Providing data for marketing purposes is entirely voluntary.

§ 5. Data recipients and processors

  1. Data is entrusted to the entities necessary to provide the service, under data processing agreements (Article 28 GDPR), in the following categories:
    1. payment operator - mBank S.A. (Paynow);
    2. infrastructure, hosting and database - Vercel Inc., Supabase, server provider (Hostinger);
    3. e-mail delivery - Resend;
    4. AI assistant provider - OpenRouter (an intermediary providing access to language models);
    5. order-fulfilling suppliers - including tolltickets (vignettes and road charges), Direct Ferries (ferries), Airalo (eSIM), Booking.com (accommodation), as well as insurance companies and their authorized intermediaries;
    6. analytics and marketing tools - only with consent (cookies).
  2. Data may be made available to public authorities where this results from legal provisions.
  3. The list of processors and data recipients may change as the Service develops and as partners fulfilling individual Products are selected; the current list can be obtained by contacting the Controller.

§ 6. Data transfers outside the EEA

  1. If suppliers from outside the European Economic Area are used, data is transferred on the basis of appropriate safeguards: standard contractual clauses (SCC) or a European Commission adequacy decision (e.g. the EU-US Data Privacy Framework). This applies in particular to infrastructure, e-mail and AI assistant providers (including Vercel, Resend, OpenRouter), which may process data on servers in the United States. A copy of the safeguards can be obtained by contacting the Controller.

§ 7. Rights of the data subject

  1. You have the right to: access your data (Article 15), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18), data portability (Article 20), objection to processing based on Article 6(1)(f) (Article 21), and withdrawal of consent at any time (without affecting the lawfulness of processing prior to withdrawal).
  2. Rights are exercised by contacting the Controller (kontakt@roadence.com). A response is provided without undue delay, at the latest within one month.
  3. You have the right to lodge a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warszawa).

§ 8. Automated decisions and profiling

  1. Matching charges to the route is done automatically but does not produce legal effects concerning the Customer or similarly significantly affect them within the meaning of Article 22 GDPR - the final decision on purchase and payment is made by the Customer. The Controller does not use profiling for automated decision-making.

§ 9. Sources of data

  1. Data comes directly from the data subject (forms in the Service) and - to the extent of fulfillment - from the suppliers fulfilling the order.

§ 10. Data security

  1. The Controller applies technical and organizational measures ensuring data security appropriate to the risk (including transmission encryption, access control, backups).

§ 11. Cookies

  1. The rules for using cookies are described in the Cookie Policy; you manage consents in the cookie banner.

§ 12. Changes to the Privacy Policy

  1. The Controller may update the Policy; the current version, together with its effective date, is published in the Service.

This is a courtesy English translation; the Polish version is binding.