ROOFCRAFT PLATFORM PRIVACY POLICY

Version effective as of December 1, 2025

§1. Data Controller

  1. The Controller of the personal data of RoofCraft Platform Users is the Service Provider: EU Spółka z ograniczoną odpowiedzialnością (Limited Liability Company) with its registered office in Lublin, at ul. Willowa 18, 20-819 Lublin, Lublin Voivodeship, entered into the National Court Register (KRS) under number 0000279091, NIP (Tax ID) 5213439076, REGON 140928239, with a share capital of PLN 50,000, fully paid up.
  2. Contact with the Controller regarding personal data protection and the exercise of User rights is possible via e-mail at: roofcraft@elcaro.pl.
  3. The Controller processes data in accordance with applicable laws, including Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR).

§2. Purposes and Legal Basis for Data Processing

  1. The RoofCraft Platform, in connection with providing services within the Basic Functionality, processes exclusively a minimal scope of personal data of a technical nature, which are necessary to ensure the proper functioning of the Platform and the General Service.
  2. Exclusively necessary technical data, which do not allow for direct identification, are processed for the following purposes:
    1. Ensuring the security, stability, and diagnostics of the Platform
      1. Purpose: Monitoring system logs (IP, server logs) to ensure proper operation, enable Update installation, and prevent abuse.
      2. Legal basis: Art. 6(1)(f) GDPR (legitimate interest of the Controller).
    2. Establishment, exercise, or defense of legal claims
      1. Purpose: Handling complaints or defense against claims based on technical connection logs.
      2. Legal basis: Art. 6(1)(f) GDPR (legitimate interest of the Controller: legal defense).

§3. Scope of Processed Data

  1. In connection with the use of the RoofCraft Platform, the Controller processes exclusively the following categories of technical data (Logs and Device Data):
    1. IP Address (internet address).
    2. Server logs and connection information.
    3. Device information (model, operating system version/OS).
    4. Type and version of the Application.
  2. Input data and carpentry calculation results are stored exclusively locally on the User's device. They are not transmitted to nor saved on the Service Provider's server.
  3. Providing technical data while using the application is necessary to use the RoofCraft Platform. Failure to provide such data will make it impossible to use the application.

§4. Data Recipients

  1. Users' technical data are transferred exclusively to entities supporting the Controller in providing services (processors), including:
    1. IT and hosting service providers: in particular Amazon Web Services (AWS) – for hosting the General Service and Application Update files.
    2. Distribution Platform Operators: Google Play (Google LLC) and App Store (Apple Inc.) – to enable downloading and updating of the Application.
    3. Analytics service providers: Google LLC – for analytical purposes (e.g., Google Analytics for measuring website traffic).
    4. Entities providing accounting and advisory services (regarding documentation of transactions related to the distribution of the Application).

§5. Data Transfer Outside the EEA

  1. Data may be transferred outside the European Economic Area (EEA) in connection with the use of services from partners such as Amazon Web Services (AWS) and Google LLC, whose servers are located in third countries (e.g., the USA).
  2. In such cases, appropriate safeguards are applied, in particular Standard Contractual Clauses (SCC) approved by the European Commission, to ensure an adequate level of data protection.

§6. Data Retention Period

  1. Personal data are stored for the following periods:
    1. Data concerning defense of claims: minimal set of data (e.g., identification data) necessary for defense against claims or pursuing them – stored for 6 years from the date of agreement termination (uninstallation of the application), which corresponds to the statute of limitations for civil claims.
    2. Technical logs and analytics data: up to 12 months.

§7. User Rights

  1. The User has the right to:
    1. access the data and obtain a copy thereof,
    2. rectify the data,
    3. erase the data ("right to be forgotten"), unless one of the exceptions provided for in the GDPR applies (e.g., defense of claims),
    4. restrict processing,
    5. object to data processing, if it is carried out based on a legitimate interest,
    6. lodge a complaint with the President of the Personal Data Protection Office (PUODO).

§8. Cookies and Analytics

  1. The RoofCraft Application and General Service use cookies and similar technologies.
    1. Purpose of cookies: used for technical purposes (e.g., session maintenance), functional purposes (e.g., remembering settings), and analytical purposes (e.g., Google Analytics, for traffic analysis and optimization).
    2. User Control: The User may delete cookies or block their collection at any time using web browser or mobile device settings. Restricting the use of cookies may affect the functionality of the Platform.
  2. Google Analytics operates on the roofcraft.app website using IP anonymization. Data serve exclusively statistical purposes and do not allow for user identification.

§9. Automated Decision-Making and Profiling

  1. The Controller does not make decisions producing legal effects concerning Users based solely on automated processing.
  2. The Platform may use User segmentation mechanisms for analytical or marketing purposes (e.g., researching service efficiency), but this does not produce legal effects for the User.
  3. The Platform does not create user profiles for marketing purposes and does not conduct personalized advertising.

§10. Contact

  1. For matters regarding personal data processing, please contact us:
    1. e-mail: roofcraft@elcaro.pl
    2. post: EU Sp. z o.o., ul. Willowa 18, 20-819 Lublin, Poland