Tubbly Privacy Policy

Updated 7/8/2024

The Tubbly Privacy Policy is structured in such a way as to give our users complete confidence and security when using our app. We comply with all applicable data protection laws and make every effort to protect the privacy of our users. Any personal information held by Tubbly is treated as confidential and is protected from unauthorized access.
In accordance with the applicable data protection regulations, we inform you that this Privacy Policy forms the basis for the processing of your personal data in the Tubbly application.
In accordance with Article 13 and Article 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”), we inform you that:

I. Administrator of personal data

The administrator of personal data is TAM LABS SPÓŁKA Z OGRANICZONĄ ODPOŚCIALNOŚĆ (hereinafter referred to as “Administrator” or “Tubbly” depending on the context), entered in the register of entrepreneurs of the National Court Register by the District Court in M.ST. WARSAW, XII COMMERCIAL DIVISION, under KRS number: 0001070536, NIP: 5252981359, REGON: 527013380, with its registered office in Warsaw at ul. Twardej 18, with e-mail address hello@tubbly.io

II. Contact Details

You can contact the Administrator by e-mail by sending a message to the following address: hello@tubbly.io
A person who has submitted a request, question or request regarding the processing of his or her personal data, as part of the exercise of his or her rights, may be asked to answer several questions that will enable verification of his or her identity.

III. Data Subjects

The administrator collects or requests the provision of the following personal data in particular: e-mail address, password, IP address, unique device identifiers, location.
Please note that with your consent, the Administrator collects information about your location for the proper functioning of Tubbly and adequate monitoring and verification of activity. Location monitoring can be enabled or disabled at any time via the operating system settings of your mobile device. However, if you disable this function, the Administrator will not be able to collect GPS location information, which will prevent the proper functioning of Tubbly.
The Controller cooperates with third parties/entities (including, for example, business partners, subcontractors of technical, payment and delivery services, advertising networks, analytical service providers) who may provide him with information about you. This may include purchase history from Loyalty Merchants who provide rewards made available to you through Tubbly.
The Administrator processes personal data of persons using the Administrator's websites or contractors of the Administrator, persons using Tubbly (within the meaning adopted in the Conditions of Use of Tubbly), representatives of contractors, persons contacting the Administrator.
Personal data is also processed via Google Maps (https://www.google.pl/maps) which the Administrator uses. The user is fully aware of and accepts the privacy policy of Google Maps available on the website: https://policies.google.com/privacy?hl=pl.

IV. Purposes and legal bases for the processing of personal data

Personal data will be processed for the purposes of:
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(a) your use of Tubbly;
(b) the sending of the newsletter;
(c) marketing;
(d) implementation of promotional programmes organised by the Administrator;
(e) issuing and storing accounting and tax documents;
(f) contact persons sending inquiries or messages to the Administrator via Tubbly, Tubbly websites or by e-mail;
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The legal basis for the processing of personal data can be found in Article 6 (1) GDPR. This article provides for the following legal bases for data processing for the legitimate interest of the Controller:
(a) for your consent (pursuant to Article 6 (1) (a) GDPR);
(b) for the performance of contractual obligations (pursuant to Article 6 (1) (1) (b) GDPR);
(c) for a legal obligation incumbent on the Data Controller (pursuant to Article 6 (1) (c) of the GDPR);
(d) to protect the interests of the data subject or another natural person (pursuant to Article 6 (1) (d) GDPR);
(e) for legitimate interests pursued by the Controller of personal data or by a third party, for which the processing of personal data is necessary (pursuant to Article 6 (1) (1) (f) of the GDPR);
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The controller may also use your personal data for the following purposes:
(a) to provide the Controller's services using our own systems and those of the relevant external service providers (pursuant to Article 6 (1) (b) GDPR);
(b) to confirm/verify your location and issue/add Tubbly Tokens to your account (pursuant to Art. 6 (1) (a) GDPR);
(c) to analyse and improve the use of our services (pursuant to Article 6 (1) (a) and (b) GDPR);
(d) to be able to communicate with you, in particular to inform you of updates/changes to Tubbly, our Tubbly Terms of Use and/or this Privacy Policy (pursuant to Art. 6 (1) (b) GDPR).
(e) to carry out market research and customer opinion surveys (pursuant to Article 6 (1) (f) GDPR);
(f) to be able to sell our services to you (pursuant to Art. 6 (1) (a) and (b) GDPR);
(g) to offer and sell services to you from third parties (pursuant to Article 6 (1) (a) GDPR);
(h) to correct errors and problems related to our services (pursuant to Article 6 (1) (b) GDPR);
(i) to investigate and/or prevent suspected fraud or other criminal activity (pursuant to Article 6 (1) (c) GDPR);
(j) to create user rankings that include all users or selected users for marketing purposes, according to the number of Tokens collected or other criteria (based on Article 6 (1) (f) GDPR);
(k) to operate the Tubbly Map (pursuant to Art. 6 (1) (b) GDPR);
(l) to operate the Tubbly Backpack (pursuant to Article 6 (1) (b) GDPR);
(m) to investigate disputes between users (pursuant to Article 6 (1) (b) GDPR);
(n) to be able to respond to your questions, opinions or requests concerning the operation of Tubbly (pursuant to Art. 6 (1) (f) GDPR);
(o) to take action in the event of claims, complaints or other requests from you (pursuant to Article 6 (1) (f) GDPR);
(p) and, in order to carry out the Controller's business activities, the Controller uses the services of external suppliers in the country and abroad, who act on behalf of the Controller in accordance with his instructions pursuant to Article 28 of the GDPR and are obliged to comply with the provisions of the law on the protection of personal data.

V. Recipients of personal data

Personal data may be disclosed to entities authorized on the basis of applicable law, in particular to the bodies controlling the activities of the Administrator or to institutions authorized to obtain personal data in accordance with the provisions of law. In addition, data may be transferred to external entities, such as accounting service providers, auditors, lawyers or tax advisors and IT service providers, in order to provide services to the Administrator.
Access to personal data is limited only to persons whose case justifies such access, in connection with the duties performed and the services provided. Any person authorized to process personal data is obliged to maintain the confidentiality of the data and to protect them against unauthorized disclosure.
The administrator of personal data may make available the data processed by him, for the purposes described in the Privacy Policy, to entities associated with the Administrator. The provision is made solely for management purposes within the enterprise.

VI. Data retention period

The controller deletes personal data after they are no longer needed for the purposes for which they were collected or used. Typically, personal data is retained for the duration of use or for the duration of the agreement regarding the use of Tubbly.
If there is a legal conflict or other legal proceedings with you, the data may be stored for the period necessary to resolve that conflict. Third parties that receive an order to store data from the Administrator, store them for as long as is necessary for the execution of contracts concluded with them regarding the processing of personal data.
The legal requirements relating to the storage and deletion of personal data remain in force. After the expiration of the statutory storage period, personal data will be blocked or deleted immediately, unless it is necessary to store them further by the Administrator and there is a legal basis for this.

VII. Guidelines for Sharing Personal Information Outside the Country

In the course of conducting business activities, the Personal Data Controller may disclose or transfer personal data to third parties, which may be located outside the European Economic Area. Such data processing is permitted only for the purpose of fulfilling contractual and commercial obligations and maintaining commercial relations with the Controller. The administrator will inform accordingly about the details of the transfer of data.
The European Commission confirms an adequate level of data protection for certain third countries by means of an adequacy decision (more information on this can be found at: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.html).

VIII. Source of data

The Controller obtains personal data directly from the data subjects to whom the data relates or from the Controller's business partners. As far as other data are concerned, they have been collected independently by the Administrator based on your use of Tubbly.

IX. Rights related to the processing of personal data

In accordance with Art. 16 GDPR, you have the right to correct your personal data stored by the Controller. To exercise this right, you must send an email to hello@tubbly.io with the theme “Correction”.
In accordance with Article 15 of the GDPR, you have the right to ask the Controller about the personal data stored about you and to request a copy of your personal data. You can exercise this right of access by sending a message to the e-mail address hello@tubbly.io with the topic “Data access request”.
In accordance with Article 17 of the GDPR, you have the right to delete your personal data that has been stored by the Administrator. You may exercise your right to delete your Tubbly account and related personal data by sending an email to hello@tubbly.io with the topic “Delete my account”.
In accordance with Article 21, you have the right to object to the processing of your personal data by the Controller for marketing purposes. You can use the option to withdraw your consent to data processing by sending an e-mail to hello@tubbly.iowith the theme “Unsubscribe”.
You also have the following rights:
(a) the right to withdraw consent (pursuant to Article 7 (3) GDPR),
(b) the right to restriction of data processing (pursuant to Art. 18 GDPR),
(c) the right to data portability (pursuant to Art. 20 GDPR),
(d) the right to object to certain means of data processing (pursuant to Art. 21 GDPR),
(e) the right to lodge a complaint with a supervisory authority (pursuant to Art. 77 GDPR).

IX. Safeguards

The Controller undertakes to take appropriate technical and organizational measures to protect your personal data. The availability of your personal data will be limited only to persons who will need to obtain it in order to fulfill the purposes and tasks set out in the Privacy Policy. All such persons are obliged to treat your personal data confidentially and to comply with applicable laws and regulations on the protection of personal data.

IX. Changes to this Privacy Policy

The Administrator reserves the right to make changes to this Privacy Policy at any time. Any such changes that will be made to this Privacy Policy will be published on the website https://www.tubbly.io/polityka-prywatnosci-tubbly-app and can be sent to you by e-mail. The Administrator encourages you to periodically check the Privacy Policy available on https://www.tubbly.io/polityka-prywatnosci-tubbly-app. If you make such a change, your continued use of Tubbly constitutes your acceptance of the change.