How do we collect and store your data?

Website and newsletter

This privacy policy is adopted in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (Official Journal of the European Union No. L 119/1 of 4 May 2016; hereinafter referred to as the GDPR). The policy aims, in particular, to comply with the information obligation referred to in Articles 13 and 14 of the GDPR.

1. Definitions

In this policy, we use the following terms:

1) Website – the website operated by AISP at https://pl.aisp.pl/.

2) We, AISP, Administrator – AISP spółka z ograniczoną odpowiedzialnością with its registered office in Gliwice (44-100), at ul. Stanisława Konarskiego 18/C, registered in the Register of Entrepreneurs of the National Court Register maintained by the District Court in Gliwice, 10th Commercial Division of the National Court Register, under number 0001083846, Tax Identification Number (NIP): 6312719187, National Business Registry Number (REGON): 52755357300000, e-mail address: kontakt@aisp.pl.

3) You, Mr., Mrs., Mrs., Mrs., Mrs., Mrs., Client – individuals whose personal data are processed by AISP in connection with the use of the Website.

2. Who is the data controller?

A data controller is the person who determines the purposes and methods of processing personal data. The controller of your personal data is AISP.

3. Whose personal data do we process?

In connection with our business activities, we process, in particular, the personal data of Website users. The scope of data processed is always appropriate to the purposes of processing.

4. What data do we collect via the Website and for what purposes do we use it?

The scope of your data that we collect and the purposes of their processing depend on the functionalities of the Website used, as follows:

4.1. Browsing the Service website

I. What data do we collect?

Data stored in server logs, where the user is identified by a URL. This data includes:

a) time of request arrival,

b) time of response,

c) name of the client station – identification performed via the HTTP protocol,

d) information about errors that occurred during the HTTP transaction,

e) URL of the page previously visited by the user (referrer link) – if the Website was accessed via a link,

f) informacje o przeglądarce użytkownika, g) informacje o adresie IP.

II. For what purposes do we process data?

For the purposes of administering the server on which the Website is stored, as well as for statistical analysis of traffic on the Website.

III. Do you have to give us your data?

Providing data is voluntary, provided that it is a condition for the proper use of the Website.

IV. On what legal basis do we process your data?

Based on:

a) a concluded contract, the subject of which is a service provided electronically in the form of making the Website available (Article 6, paragraph 1, letter b of the GDPR) and,

b) our legitimate interest (Article 6, paragraph 1, letter f of the GDPR) – consisting in the possibility of making the Website available to third parties, as well as ensuring the correct display of the Website.

V. Who can we share your data with?

Personal data may be disclosed to third parties only if we are legally obligated or authorized to do so. Recipients of data may include, in particular:

a) individuals operating our infrastructure or IT systems,

b) individuals providing data hosting,

c) subcontractors participating in the performance of contracts concluded with you.

VI. How long will we process your data?

For the time necessary to perform concluded contracts or for the duration of our legitimate interest in data processing – but in any case not shorter than the period of your visit to the Website.

Please remember that if the basis for data processing is a legitimate interest, you have the right to object to further data processing, in accordance with point 8 below.

4.2. Newsletter

I. What data do we collect?

Email address and name, surname, or company name.

II. For what purposes do we process data?

For marketing purposes related to sending the newsletter, including providing information about our offer.

III. Do you have to provide us with your data?

Providing your data is voluntary, provided that it is a condition for receiving the newsletter.

IV. On what legal basis do we process your data?

Based on consent to receive the newsletter (Article 6, paragraph 1, letter a of the GDPR) – granted in particular by completing the appropriate form on the Website and clicking the confirmation button (“Subscribe”).

Please remember that you have the right to withdraw your consent at any time (e.g. by sending an appropriate email to: kontakt@aisp.pl) without affecting the lawfulness of processing based on consent before its withdrawal.

V. Who can we share your data with?

Personal data may be disclosed to third parties only if we are legally obligated or authorized to do so. Recipients of data may include, in particular:

a) individuals operating our infrastructure or IT systems,

b) individuals providing data hosting,

c) subcontractors through whom we can send the newsletter.

VI. How long will we process your data?

Until you withdraw your consent to receive the newsletter.

4.3. Cookies

The Cookie Policy is attached as Appendix 1 to this Privacy Policy.

5. Can data be processed in processes involving automated decision-making, including “qualified” profiling?

We currently do not use any automated decision-making processes that would have legal consequences for recipients or significantly impact them in a similar manner. Should we implement such personal data processing operations in the future, we will ensure their compliance with applicable regulations, including Article 22 of the GDPR.

6. Can your personal data be transferred outside the European Economic Area (EEA)?

We currently do not anticipate transferring your data outside the European Economic Area. However, we do not rule out the possibility that in the future we may deem it justified. In such a case, your data will be secured in a manner required by generally applicable regulations, in particular through the use of standard contractual clauses (SCCs).

7. What rights do you have in relation to data processing?

In particular, you may request:

1) access to the data we process (including information about our processing or the provision of a copy of the data),

2) rectification (correction) of data,

3) restriction of processing (suspension of data processing or non-deletion of data),

4) deletion of data ("right to be forgotten"),

5) transfer of data to another controller.

These requests may be submitted in particular as specified in section 11 below – and will be processed in accordance with applicable regulations, including Articles 15-20 of the GDPR.

8. Right to object

If your response has been received, you have the right to object to the analysis of data that is made available based on our legitimate interests. In such a case:

1) If personal data is processed for marketing purposes, we will immediately cease such processing.

2) If the basis for data processing is another interest, we will cease such processing unless we demonstrate: a) that such interest overrides your interests, rights, and freedoms, or b) there is a basis for establishing, pursuing, or defending against legal claims.

The right to object may be exercised in particular by sending an appropriate declaration in the manner specified in point 11 below.

9. Complaint to the supervisory authority

If you believe that the processing of your data violates applicable law, you have the right to lodge a complaint with the supervisory authority, i.e., the President of the Personal Data Protection Office. Contact details for the Office are available at https://uodo.gov.pl/pl/p/kontakt.

10. Place of publication and privacy policy updates

This privacy policy may be amended from time to time. The current version of the policy will always be available on our website at: https://pl.aisp.pl/start.

11. How can you contact us?

If you have any questions about how we use your personal data, you can contact us by telephone, email or post at the following numbers and addresses:

AISP Limited Liability Company

ul. Stanisława Konarskiego 18C

44-100 Gliwice

- with the note: "personal data protection"

e-mail: kontakt@aisp.pl

Appendix No. 1 to the Privacy Policy – COOKIES Policy

§1

1. This Policy defines the rules for the Administrator's storage of information and the Administrator's access to information already stored on Customer Devices in the form of Cookies.

2. All terms defined in the Privacy Policy retain their meanings within this Cookie Policy. Furthermore, the following terms shall have the following meanings:

a) Cookies - means IT data, in particular small text files, saved and stored on devices through which the Customer uses the Website. Cookies typically contain the name of the website from which they originate, their storage time on the end device, and a unique number.

b) First-Party Cookies - means Cookies placed by the Administrator, related to the provision of electronic services by the Administrator via the Website.

c) Third-Party Cookies - means Cookies placed by third parties via the Website.

d) Policy - means this Cookie Policy, constituting Appendix 1 to the Privacy Policy.

e) Device - means the electronic device through which the Customer accesses the Website.

§2

1. The Administrator uses cookies to store information on the Customer's Device or access information already stored – in accordance with the terms set out in this Policy.

2. The Administrator uses the following types of cookies:

a) Session cookies: these are stored on the Customer's Device and remain there until the browser session ends. The stored information is then permanently deleted from the Device's memory.

b) Persistent cookies: these are stored on the Customer's Device and remain there for the period specified in the file parameters or until they are deleted. Ending a browser session or turning off the Device does not delete these types of cookies from the Device.

3. The Administrator's use of cookies does not result in any configuration changes on the Customer's Device or the software installed on that Device.

§3

1. The Administrator uses First-Party Cookies to tailor the content of the Website to the User's preferences and needs, in particular taking into account the type of Device the User uses to access the Website. These types of Cookies include:

a) "essential" cookies, enabling the use of services available on the Website, e.g., authentication cookies used for services requiring authentication on the Website;

b) cookies used to ensure security, for example, used to detect authentication abuse on the Website;

c) "performance" cookies, enabling the collection of information about how the Website's web pages are used;

d) "functional" cookies, enabling the "remembering" of settings selected by the User and personalizing the User interface, e.g., in terms of the selected language or region of the User's origin, font size, website appearance, etc.;

e) "advertising" cookies, enabling the delivery of advertising content to Users that is more tailored to their interests.

2. The Administrator uses External Cookies to create aggregate statistics and analyses to monitor how Customers use the Website, enabling it to be best tailored to Customer needs. In this regard, the Administrator uses the following services:

a) Google Analytics – which, when the Website is opened, reads, writes, and sends information about the origin of users identified by their IP address to a secure Google server. Detailed information in this regard is available on the Google website (https://policies.google.com/technologies/types?hl=pl).

b) Google AdWords and Facebook Ads (Meta) – in which the Website uses so-called remarketing codes. The codes are used to tailor personalized ads to individual customers and then display them within the provider's advertising network (Google or Facebook). These networks include both the providers' websites and their business partners. Detailed information in this regard is available on the providers' websites, including:

• Google – https://policies.google.com/technologies/types?hl=pl

• Facebook: https://www.facebook.com/policy/cookies/

3. In connection with the use of cookies, the Administrator collects only statistical data related to browsing history. Other data (such as name, surname, address, etc.) is not recorded in any way.

§4

1. The Customer may limit or disable access of Cookies to their Device in their web browser settings or through service configuration – in particular, by blocking the automatic handling of Cookies or by notifying them each time Cookies are placed on the Customer's Device. Descriptions of the necessary steps can be found on the manufacturers' websites, e.g.:

a) Mozilla Firefox: https://support.mozilla.org/pl/kb/W%C5%82%C4%85czanie%20i%20wy%C5%82%C4%85czanie%20obs%C5%82ugi%20ciasteczek

b) Google Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=pl

c) Microsoft Edge: https://privacy.microsoft.com/pl-pl/windows-10-microsoft-edge-and-privacy

2. The Customer may delete Cookies at any time.

3. Restricting the use of Cookies may affect some of the functionalities available on the Website.

AISP cloud, client program and data processing

AISP Cloud Privacy Policy

1. Definitions

In this policy, we use the following terms:

1) AISP Cloud – AISP's proprietary software running on physical servers and managing the Firebase Google Cloud Services cloud and processing Customer Orders.

2) Application – AITracker computer program, available in binary form and under the MIT license for the client, the AITracker program for Windows, along with all program code. The program is used to register, log in, and send/receive user data to/from the AISP Cloud.

3) We, AISP, Administrator – AISP spółka z ograniczoną odpowiedzialnością with its registered office in Gliwice (44-100), ul. Stanisława Konarskiego 18/C, registered in the Register of Entrepreneurs of the National Court Register maintained by the District Court in Gliwice, 10th Commercial Division of the National Court Register, under KRS number 0001083846, Tax Identification Number (NIP): 6312719187, National Business Registry Number (REGON): 52755357300000, e-mail address: kontakt@aisp.pl.

4) You, Mr., Mrs., Mrs., Mrs., Mr. and Mrs., Client – persons whose personal data are processed by AISP in connection with the use of the AISP Application and Cloud.

2. Who is the data controller?

The data controller is the person who determines the purposes and methods of personal data processing. The controller of your personal data is AISP.

3. Whose personal data do we process?

In connection with our business activities, we process, in particular, the personal data of users of the AISP Application and Cloud. The scope of data processed is always appropriate to the purposes of processing.

4. What data do we collect using the Application and AISP Cloud, and for what purposes

do we use it?

The scope of your data we collect and the purposes of its processing depend on the functionalities of the Application and AISP Cloud used, as follows:

4.1. Using the AISP Cloud

I. What data do we collect?

Data stored within the AISP Cloud, assigned to the User Panel. This data includes:

a) video recordings, which may include the image of the driver or passengers,

b) visible vehicle registration number.

II. For what purposes do we process data?

For the purpose of fulfilling orders placed through the Account, including sending related emails, sharing counting results, and handling any complaints regarding the Application or AISP Cloud.

III. Do you have to provide us with your data?

Providing your data is voluntary, provided that it is a condition for the performance of the contract and the proper use of the Application and AISP Cloud.

IV. On what legal basis do we process your data?

Based on:

a) a concluded contract, the subject of which is a service provided electronically in the form of providing access to the Application and the AISP Cloud (Article 6, paragraph 1, letter b of the GDPR), and

b) our legitimate interest (Article 6, paragraph 1, letter f of the GDPR) – consisting in ensuring the correct display of the Application and the AISP Cloud.

V. Who can we share your data with?

Personal data may be shared with third parties only if we are legally obliged or authorized to do so. Data recipients may include, in particular:

a) persons operating our infrastructure or IT systems,

b) persons providing data hosting,

c) subcontractors participating in the performance of contracts concluded with you.

VI. How long will we process your data?

For the time necessary to perform concluded contracts or for the duration of our legitimate interest in data processing – however, after video data has been processed in the cloud, it is deleted, and the counting results are stored for 14 days from the date of transmission.

Please note that if the basis for data processing is a legitimate interest, you have the right to object to further data processing, in accordance with point 8 below.

4.2. AI Training

I. What data do we collect?

Image, registration number.

II. For what purpose do we process data?

For the purposes of artificial intelligence training for the provision of services in the program via the AISP Cloud.

III. Are you required to provide us with your data?

Providing your data is voluntary, provided that it conditions the AISP's ability to provide services.

IV. On what legal basis do we process your data?

Based on the Agreement concluded with the Controller (Article 6, Section 1, Letter f of the GDPR).

V. Who can we share your data with?

Personal data may be shared with third parties only if we are legally obliged or authorized to do so. Recipients of data may include, in particular:

a) AISP employees, associates, contractors, and persons operating our infrastructure or IT systems,

b) persons providing data hosting,

VI. How long will we process your data?

For the duration of the contract.

4.3. Registering the User Panel in the AISP Application and Cloud and placing orders via the User Panel

I. What data do we collect?

Data required to register a User Panel in the AISP Application and Cloud, including: name, address, shipping address (if different), email address, login, password, Tax Identification Number, and company name.

II. For what purpose do we process data?

For the purpose of:

a) performing the contract for the provision of electronic services – in the form of registering the User Panel in the AISP Application and Cloud,

b) fulfilling orders placed via the User Panel, including sending related emails, sending counting results, and handling any complaints;

c) conducting correspondence using all known technologies, including traditional mail, electronic mail (email), or other communication methods (e.g., instant messaging, etc.).

d) creating reports, analyses, and statistics – including, in particular, marketing research, commercial data analysis, service development planning, etc.

e) pursuing claims or defending against claims.

III. Do you have to provide us with your data?

Providing data is voluntary, provided that it conditions the possibility of registering the User Panel in the Application and AISP Cloud and using the related functionalities of the Application and AISP Cloud.

IV. On what legal basis do we process your data?

Based on:

a) concluded agreements concerning the management of the User Panel in the AISP Application and Cloud, as well as the provision of services ordered via the AISP Application and Cloud (Article 6, paragraph 1, letter b of the GDPR),

b) generally applicable provisions that impose legal obligations on us, the implementation of which requires data processing - in particular in the field of tax law and accounting or archiving regulations (Article 6, paragraph 1, letter c of the GDPR),

c) our legitimate interest (Article 6, paragraph 1, letter f of the GDPR) – consisting in the possibility of taking the actions indicated in point II, letters c-g above.

V. Who can we share your data with?

Personal data may be disclosed to third parties only if we are legally obligated or authorized to do so. Recipients of data may include, in particular:

a) individuals operating our infrastructure or IT systems,

b) individuals providing data hosting,

c) subcontractors through whom we can fulfill orders,

d) individuals providing auditing or advisory services to us – e.g., in the field of legal, tax, or accounting assistance,

e) buyers of receivables related to transactions concluded via the AISP Application and Cloud – in the event that we decide to sell such receivables, in particular due to the existence of significant payment arrears.

VI. How long will we process your data?

Depending on the basis for processing, this will be:

a) the time necessary to perform the contract concluded through the AISP Application and Cloud, as well as the statute of limitations for related claims,

b) the duration of the legal obligations that require the processing of your data,

c) the duration of our legitimate interest in processing the data.

Please note that if the basis for processing is a legitimate interest, you have the right to object to further processing of the data, in accordance with point 8 below.

5. Can data be subject to automated decision-making processes, including "qualified" profiling?

6. Can your personal data be transferred outside the European Economic Area (EEA)?

We currently do not anticipate transferring your data outside the European Economic Area. However, we do not rule out the possibility that this may be necessary in the future. In such a case, your data will be secured in a manner required by generally applicable regulations, in particular through the use of standard contractual clauses (SCCs).

7. Can data be processed in processes involving automated decision-making, including "qualified" profiling?

8. Can your personal data be transferred outside the European Economic Area (EEA)?

We do not currently transfer data outside the European Economic Area. However, we will not disclose that it may be used in the future as deemed necessary. In the event of a threat, the method of handling adverse effects should be applied. Contractual provisions (SCC).

9. What rights do you have in relation to data processing?

In particular, you may request:

1) access to the data we process (including information about our processing or the provision of a copy of the data),

2) rectification (correction) of data,

3) restriction of processing (suspension of data processing or non-deletion of data),

4) deletion of data ("right to be forgotten"),

5) transfer of data to another controller.

These requests may be submitted in particular as specified in section 11 below – and will be processed in accordance with applicable regulations, including Articles 15-20 of the GDPR.

10. Right to object

Notwithstanding the above, you have the right to object to the processing of your data based on our legitimate interests. In such a case:

1) if personal data are processed for marketing purposes – we will immediately cease such processing.

2) if the basis for data processing is another type of interest, we will cease such processing unless we demonstrate: a) that the said interest overrides your interests, rights and freedoms or b) there is a basis for establishing, pursuing or defending against claims.

The right to object may be exercised in particular by sending an appropriate declaration in the manner specified in point 11 below.

11. Complaint to the supervisory authority

12. Place of publication and updates of the privacy policy

This privacy policy may be amended from time to time. The current version of the policy will be available at all times within the App's functionality.

13. How can you contact us?

If you have any questions about how we use your personal data, you can contact us by telephone, email or post at the following numbers and addresses:

AISP Limited Liability Company

ul. Stanisława Konarskiego 18C

44-100 Gliwice

- with the note: "personal data protection"

e-mail: kontakt@aisp.pl