Article 1. Administrator of personal data
1. Surro is the Administrator of personal data of Users who are natural persons within the meaning of the Personal Data Protection Act of May 10th, 2018 (Dz.U.2018.1000). The personal data of Users in accordance with the regulations of the Personal Data Protection Act of May 10th, 2018 and the Act of Rendering Electronic Services of July 18th, 2002 (Dz.U.2017.1219) in order for Surro to provide services and for marketing purposes related to the functioning of Rehafil, including the Surro Platform. The User will not receive marketing and commercial information without his/her previous consent.
2. The information given by the Users consisting of: first name, last name, e-mail address, telephone number, location and personal image (in the form of pictures and videos) are processed by Surro solely in order to establish contact between Users and enable the Users to commission specific tasks and services. Simultaneously Surro ensures that personal data in the form of e-mail address and telephone number of the Users are processed with the sole purpose of verification of Users by Surro and remain inaccessible for other Users.
3. Surro ensures the implementation of rights deriving from the Personal Data Protection Act and the Regulation of the European Parliament and of the Council (UE) 2016/627 of April 27th, 2016 on the protection of natural persons with regards to processing of personal data and the free flow of such data and the repeal of Directive no. 95/46/WE including the right to access one’s own personal data and to correct this data as well as the right to control the processing of one’s personal data on the terms described in the following act and the right to demand that the Administrator removes the data. At the same time it needs to be accentuated that the removal of personal data by the Administrator is equal to the removal of the particular User account from the Surro application.
4. As part of the right to control the processing of one’s personal data the User is particularly entitled to file a written request for the limitation or cessation of processing of personal data, request that his/her personal data be transferred to another service provider as well as demand that his/her data be removed in accordance with the provisions of the Regulation of the European Parliament and of the Council (UE) 2016/627 of April 27th, 2016 on the protection of natural persons with regards to processing of personal data and the free flow of such data and the repeal of Directive no. 95/46/WE as well as other generally applicable laws.
5. The personal data of Users may be shared with entities authorized by legislation in force to receive this data, including judicial authorities, as well as – after previous consent of the person whose data are to be shared – Contractors or entities commissioning a specific service, task or work. Personal data of Users may also be transmitted to third parties designated by Surro, including parties performing tasks related to the services performed by Surro for the Users within the Platform on commission of Surro. The provided personal data will be processed only in relation to and for the purposes described during the granting of the consent, especially with the purpose of ensuring the realization of a particular service, task or work, as well as the realization of performing tasks related to the services performed by Surro for the Users within the Platform on commission of Surro. The consent referred to in the previous sentences will be clear and unambiguous each and every time. The consents are subject to verification by the Administrator. Consent may be provided electronically by means of choosing a proper checkbox or through e-mail confirmation.
6. Personal data of Users are protected by Surro against their sharing with unauthorized persons, as well as other cases of disclosure, destruction or unlawful modification of the following data and information through the implementation of proper organizational security, as well as technical and programming security, especially data coding (encryption) systems.
Article 2. Types of information about Surro Platform Users that are being collected
1. The information collected by us can be divided into 2 categories:
• Information provided to us voluntarily by the User
• Information we receive when the User is using our services
2. Information provided to us voluntarily by the User
When the User is using our services we gather information provided by the User through the process of registration and filling out the User Account information. The abovementioned include: unique User Name, password, e-mail address, first name, last name, telephone number, gender, birthdate and location. In order to enable other persons to find the User the User may be asked to provide additional information which will be publically available within our services. The following include: profile pictures, promovideo, picture gallery, additional video or other identification information. Charging the account or withdrawing funds from the account requires the User to provide PayPal account information. It is to be remembered that content, messages and videos sent to other Users may be saved and/or copied by them (and potentially used beyond the application). Therefore, special safety measures need be taken while using the Surro application, e.g. if we do not wish for specific messages or content to be shared we ought not send it to other persons.
3. Information we receive when the User is using our services
When the User is using our services we gather information related to specific services within the app – which services were used and how. We collect data regarding:
• Using the Surro Platform:
We gather information on the activity of the User, namely:
• how does the User use our services (search history, call log, activity history),
• how does the User communicate with other Users of the Platform (nickname, time and date of calls, number of messages – sent and received, which persons did the User contact,
• content created by the User,
We collect the content created by the User within our services, e.g. the promostory, additional video, picture gallery and information regarding the content created or shared by the User, including the information whether the receiver viewed the incoming content and its metadata.
• Type of device used by the User
We collect information regarding and from the device of the User, such as:
• Information on the type of device used by the User, i.e. hardware model, operating system version, operational memory, advertisement identifiers, unique application identifiers, unique device identifiers, installed applications, type of browser, language, battery level and time zone;
• Information coming from the device detectors, such as accelerometers, gyroscopes, compasses, microphones and information regarding whether the phones are plugged into the device, as well as
• Information regarding the connection with wireless and/or mobile network, such as telephone number, service provider and signal strength,
Many of the services we offer requires us to collect photographs as well as other information coming from the camera of the device. The User will be unable to connect to the application unless he/she allows the application to access the following information.
• Regarding location:
When the User is using the Surro application we are allowed to collect information regarding his/her location. With the consent of the User we may gather information relating to the precise location of the User on the basis of information coming from the GPS, wireless networks, cell towers, Wi-Fi spots as well as other detectors such as gyroscopes, accelerometers and compasses. The following is a standard requirement if the User wishes to make an InPerson connection via Surro.
• Information gathered by cookie files and other technologies