INFORMATION ON THE PROCESSING OF PERSONAL DATA (Articles 13 and 14 GDPR)
This is a translation. The Polish version is binding.
1. Controller
The controller of your data is KOSTIANTYN SOLDATKO (PL360•), ul. Powstańców Śląskich 5 lok. 405, 53-332 Wrocław, NIP 8992823570, REGON 544596129. For data matters contact us in the app (Profile → My data (RODO)), by phone at +48 787 451 787 or by post at the controller’s address. We have not appointed a data protection officer. We reply without undue delay and within one month at the latest.
2. Purposes, data and legal bases
- App account and login with an SMS / e-mail code — first and last name, phone, e-mail, language, city; Art. 6(1)(b) GDPR (terms of service).
- Handling your residence legalisation or citizenship case: questionnaire, documents, preparing and filing the application, contact and notifications about stages and missing documents, notifying the office of a change of address or employer — questionnaire answers, copies of documents, PESEL, case and PIO numbers, address and its changes, employer details, whether you have a Profil Zaufany; Art. 6(1)(b) GDPR (contract). We collect copies of your passport and other documents because the application requires them — only the pages and documents the office asks for.
- Short request to a partner (loan, insurance, real estate) — first and last name, phone, e-mail, what you are interested in, contact language, comment; Art. 6(1)(b) GDPR. Passing your data to a partner — Art. 6(1)(a) GDPR, a separate consent for each partner.
- Accounting: payments, receipts, invoices — Art. 6(1)(c) GDPR (tax and accounting laws).
- Reminders about the expiry of your residence card or insurance policy and information about our services — Art. 6(1)(a) GDPR (your consent).
- Account security and abuse detection, proving performance of the contract, establishing and defending claims — an event log without the content of documents; Art. 6(1)(f) GDPR (the controller’s legitimate interest).
3. Data of other people (Art. 14 GDPR)
We receive the data of your employer (name, tax number NIP, e-mail for signing the application in the MOS system, contract details), spouse or children from you. We use it only to prepare and file the application and to communicate about this case — Art. 6(1)(f) GDPR (your and the controller’s interest in handling the case). These people have the same rights as you and can contact us. Please tell them that you have given us their data.
4. Special categories of data
We do not ask about health, origin, beliefs or criminal records. If the office requires a document that contains such data (e.g. a driver’s medical examination, a criminal record certificate), we process it only to file it with the office and do not pass it to the AI model.
5. Recipients
OVH sp. z o.o. (Wrocław) processes data on our behalf: servers, files, backups, sending SMS and e-mail, the AI model. On your instruction we pass data to the voivode’s office and, for a request, only to the partner you consented to: Lendi Sp. z o.o., Lendi Care Sp. z o.o., Home Sp. z o.o. (ul. Zielonogórska 31 lok. 1.1, 71-084 Szczecin). After the transfer the partner is a separate controller and processes the data under its own privacy notice; ask the partner directly to delete data it holds. Data may also be received by PL360•’s accounting office and authorities entitled by law.
6. Where the data is
Only in the European Economic Area: server and files in Poland, encrypted backups in France. We do not transfer data to third countries.
7. How long we keep data
- Account — until it is deleted.
- Case — while the proceedings last and 30 days after the decision (time to appeal); after that only the card expiry date and contact remain, if you agreed to a reminder.
- Partner request — deleted the day after it is passed to the partner; if it was not passed — 7 days (insurance) or 30 days (loan, real estate) from creation.
- Payments, receipts, invoices — 5 years from the end of the year in which they were created.
- Consent records — while valid and 3 years after withdrawal (proof of consent).
- Security and login log — 1 year; case activity log (identifiers only) — while the case exists and 1 year.
- Backups — 14 days. One-time codes — only their hash, valid for 5 minutes.
8. Your rights
You have the right to access, rectify and erase your data, to restrict its processing and to data portability. You may object at any time, on grounds relating to your situation, to processing based on legitimate interest (points 2 and 3) — we will then stop unless we demonstrate compelling legitimate grounds. You can withdraw consent at any time in the app (Profile → Consents) as easily as you gave it; this does not affect the lawfulness of earlier processing. Submit requests in the app (Profile → My data (RODO)). You may lodge a complaint with the President of the Personal Data Protection Office (UODO, ul. Stawki 2, 00-193 Warszawa).
9. Do you have to give us data
It is voluntary, but without account and case data we cannot conclude or perform the contract. Consents are voluntary and are not a condition for using the app.
10. AI model and automated decisions
We do not take decisions based solely on automated processing and do not profile. An AI model in the EU (OVHcloud, no data storage, no training on it) pre-checks readability, type and validity of documents, reads receipt photos and, from a photo of a new contract, only the employer, tax number, contract type and start date (no salary). It does not recognise faces or assess people’s credibility. The result is only a hint — an employee decides.
11. Technical data
The app contains no analytics or advertising tools. We process your device’s IP address only at the moment of connection (security, choosing the region shown in the app background) and do not store it in the database.
12. Age
The app is intended for adults. A child’s data in a case is provided by a parent or guardian.
13. Account deletion and changes
You can request deletion of your account and data in the app (Profile → My data (RODO) → Delete my account and data). We will announce changes to this notice in the app; the current version is always in Profile → Consents.
The Polish version is binding.
Consents in the app — full text
Each consent is separate. Withdrawing is as easy as giving it. Optional consents are never pre-selected. You can change them at any time in Profile → Consents. We handle your case on the basis of the contract, not of a consent. Withdrawing a consent doesn't affect your case.
News and offers from PL360
I agree to receive information about PL360• services from PL360• (Kostiantyn Soldatko) by SMS to my phone number and by e-mail to my address. This consent is voluntary and does not affect use of the app; I can withdraw it at any time in the app (Profile → Consents).
Remind me when my residence card expires
I agree that after my case ends PL360• (Kostiantyn Soldatko) keeps the expiry date of my residence card, my phone number and e-mail in order to remind me by SMS or e-mail about the expiry about 12 months in advance (processing a new application now often takes over a year) and again about 3 months in advance. The data is kept until the reminder is sent or until I withdraw consent. The reminder may contain information about PL360• services. I can withdraw this consent at any time in the app (Profile → Consents).
Remind me when my insurance policy expires
I agree that PL360• (Kostiantyn Soldatko) keeps the end date of my insurance policy, my phone number and e-mail in order to remind me about renewing it about 30 days in advance. The data is kept until the reminder is sent or until I withdraw consent. The reminder may contain information about PL360• services. I can withdraw this consent at any time in the app (Profile → Consents).
Sharing contacts: Lendi Sp. z o.o.
I agree that PL360• (KOSTIANTYN SOLDATKO, ul. Powstańców Śląskich 5 lok. 405, 53-332 Wrocław, NIP 8992823570) passes my first and last name, phone number, e-mail, information about what I am interested in, contact language and comment to Lendi Sp. z o.o. (ul. Zielonogórska 31 lok. 1.1, 71-084 Szczecin, KRS 0000641775, NIP 8522625163) so that they can contact me by phone, SMS or e-mail to offer me a mortgage or a cash loan. I do not write data about my health, income or assets in the comment. After the transfer Lendi Sp. z o.o. becomes a separate controller of my data and processes it under its own privacy notice. PL360• deletes its copy of the request the day after the transfer, or 30 days after it was sent if it is not passed on. This consent is voluntary; I can withdraw it at any time in the app (Profile → Consents) — PL360• will then not pass my data on any more and will inform the partner. Withdrawal does not affect the lawfulness of processing before it. Lendi Sp. z o.o. is a tied mortgage credit intermediary entered in the register of credit intermediaries kept by the KNF (knf.gov.pl) and does not provide advisory services within the meaning of the Mortgage Credit Act. The request will be handled by Kostiantyn Soldatko — an agent acting solely in the name and on behalf of Lendi, KNF register of credit intermediaries no. RHA0020112.
Sharing contacts: Lendi Care Sp. z o.o.
I agree that PL360• (KOSTIANTYN SOLDATKO, ul. Powstańców Śląskich 5 lok. 405, 53-332 Wrocław, NIP 8992823570) passes my first and last name, phone number, e-mail, information about what I am interested in, contact language and comment to Lendi Care Sp. z o.o. (ul. Zielonogórska 31 lok. 1.1, 71-084 Szczecin, KRS 0000932977, NIP 8522677036) so that they can contact me by phone, SMS or e-mail to offer me insurance. I do not write data about my health, income or assets in the comment. After the transfer Lendi Care Sp. z o.o. becomes a separate controller of my data and processes it under its own privacy notice. PL360• deletes its copy of the request the day after the transfer, or 7 days after it was sent if it is not passed on. This consent is voluntary; I can withdraw it at any time in the app (Profile → Consents) — PL360• will then not pass my data on any more and will inform the partner. Withdrawal does not affect the lawfulness of processing before it. Lendi Care Sp. z o.o. is an insurance agent working with several insurance companies. The request will be handled by Kostiantyn Soldatko — performing agency activities on behalf of Lendi Care, KNF register of insurance intermediaries no. 11792213/P.
Sharing contacts: Home Sp. z o.o.
I agree that PL360• (KOSTIANTYN SOLDATKO, ul. Powstańców Śląskich 5 lok. 405, 53-332 Wrocław, NIP 8992823570) passes my first and last name, phone number, e-mail, information about what I am interested in, contact language and comment to Home Sp. z o.o. (ul. Zielonogórska 31 lok. 1.1, 71-084 Szczecin, KRS 0000854950, NIP 8522665760) so that they can contact me by phone, SMS or e-mail to help me buy or sell property. I do not write data about my health, income or assets in the comment. After the transfer Home Sp. z o.o. becomes a separate controller of my data and processes it under its own privacy notice. PL360• deletes its copy of the request the day after the transfer, or 30 days after it was sent if it is not passed on. This consent is voluntary; I can withdraw it at any time in the app (Profile → Consents) — PL360• will then not pass my data on any more and will inform the partner. Withdrawal does not affect the lawfulness of processing before it. The request will be handled by Kostiantyn Soldatko — a HOME network partner acting in the name and on behalf of Home Sp. z o.o.
This website
- pl360.eu uses no cookies, analytics, ads, external fonts or scripts — which is why there is no cookie banner.
- There are no forms or logins on this website and we collect no data here. Your account and case live only in the app.
- The server needs your IP address to deliver the page; we keep no visitor log.