Comarch Asset Tracking mobile application – Privacy Policy

By using our services, you entrust us with your personal data. We would like to assure you that we feel responsible for them and we respect your privacy, so we make every effort to ensure their safety. By reading the text below, you will learn about the rules on which we process personal data.

This Privacy Policy applies to the operation of the Comarch Asset Tracking mobile application. Terms used in the Privacy Policy will have the meaning given to them in the Terms & Conditions of the Comarch Asset Tracking mobile app.

Who are we?

The Controller of personal data is Comarch Spółka Akcyjna with its registered office in Kraków, Aleja Jana Pawła II 39A, registered in the National Court Register kept by the District Court for Kraków-Śródmieście in Kraków, 11th Commercial Division of the National Court Register under the number KRS 0000057567. The amount of the Company's share capital is PLN 8,133,349.00. The share capital has been fully paid up. NIP: 677-00-65-406.
 
In all matters related to the processing of personal data by us, please contact the Controller. The preferred form of contact is electronic correspondence to the following e-mail address: assettracking.support@comarch.com

What kind of data do we process?

We process personal data that you voluntarily provided to us during Account registration: your e-mail address, name and surname.

Verification information.

To help build and maintain a trusted community, we may collect verification information, including e-mail address.

Google Analytics
 
The Controller uses Google Analytics, an online analytical service offered by Google, to track and report activity in the Application. Data collected, processed and stored using Google Analytics is safe and confidential. If you want to learn more about Google Analytics, please click the link below:
  
https://analytics.google.com/analytics/web/provision/#/provision

Push notifications
 
The application sends notifications about alarms in the Comarch Asset Tracking system.
 
To send notifications, the Application uses the Google Firebase service, where the Application registers the User's device and obtains a token that allows to send notifications. This token is stored on the Controller's servers.

Losing access to the Account

 The collected contact details (e.g. e-mail address) may be used to verify the identity of the User who has lost access to their Account in the Application.
 
Marketing
 
If the appropriate consent is given, the data may be used in connection with promotional activities.

For what purposes and on what legal basis do we process personal data?

We process your personal data for the purpose of:

• providing Services electronically on the terms described in the Application Terms & Conditions. The provision of our Services is inextricably linked with the processing of personal data and without these activities we would not be able to provide you with our services;
• conducting marketing activities using electronic means of communication, e.g. SMS or e-mail; we will perform such activities only on the basis of your voluntary consent;
• pursuing our legitimate interests. Our legitimate interest should be understood as: conducting a User satisfaction level survey, possible determination, investigation and enforcement of claims or defence against claims, prevention of abuse and fraud, detection of cases of unauthorised use of services, ensuring IT security of the Application, financial analysis of the Controller, conducting activities for marketing nature, answering inquiries and messages from Users, keeping statistics and conducting analytical research and tests in order to better select services to the User’s needs or optimise processes, profiling the purpose of which is to best match the information sent to the needs and interests of the User, data storage for archiving and accountability purposes.

How long do we process personal data?

Your data will be processed as long as there is a basis for their processing, i.e.

• in the case of data processing on the basis of consent, until its withdrawal;
• in the case of the necessity to process data for the performance of the agreement, for the duration of its performance and until the expiry of the limitation of claims related to the subject of the agreement, taking into account the limitation periods for claims specified in generally applicable law;
• if the basis for data processing is the legitimate interest of the controller, until you object or the interest ceases to exist.

Do we share personal data?

Your data may be transferred to entities processing data on our behalf, e.g. IT service providers, marketing agencies, legal services, accounting services, customer service, etc., where such entities will process data only on the basis of relevant contracts and only in accordance with our instructions. We require our partners to maintain confidentiality and ensure appropriate security measures. Your data may also be made available to entities authorised to obtain it on the basis of applicable law, e.g. law enforcement authorities.

Data transmission outside the EEA

In principle, we do not transfer personal data to entities the registered offices of which are located outside the European Economic Area. The only exception is our cooperation with service providers operating under the Google brand. In connection with this cooperation we can provide data characterising the way of using services provided electronically (“operational data”) for marketing purposes. Google participates in the “EU-US Privacy Shield” programme, which guarantees that Google uses safeguards that are compliant with the provisions in force in the EEA.
 
Do we make decisions automatically?

We do not use automated data processing techniques.

What are your rights?

 According to the binding law, you have:

• the right to access your data, including obtaining copies of data;
• the right to rectification of data;
• the right to request the data to be deleted (“the right to be forgotten”);
• the right to restrict data processing;
• the right to object to the processing of data on the basis of our legitimate interest;
• the right to transfer personal data;
• the right to withdraw your consent.

In order to exercise the above-mentioned rights, please contact us by sending an e-mail to the following address: assettracking.support@comarch.com. If you send us a request to exercise any of these rights from an e-mail address other than the one for which the account was registered, we may request additional information to verify the identity of the person making the request.

If you feel that your personal data is being processed unlawfully, you have the right to lodge a complaint with the President of the Office for Personal Data Protection.