Privacy Policy

1. Data Controller

X93 Łukasz Biegaj
ul. E. Orzeszkowej 5, 59-225 Chojnów, Poland
Email: troll0@x93.org

2. Why We Process Data

To analyze and filter internet users' comments posted on Facebook pages connected by our clients.

3. What Data We Process

• Personal data voluntarily provided by users.
• Automatic technical logs (IP address, browser, similar device data).
• Comment content.

4. Legal Basis (GDPR Art. 6)

• Performance of a contract (Art. 6(1)(b)).
• Legal obligations, including accounting (Art. 6(1)(c)).
• Legitimate interest: service security and abuse prevention (Art. 6(1)(f)).
• Consent, where required (Art. 6(1)(a)).

5. Data Recipients

• Hetzner Online GmbH - EU cloud hosting and data storage infrastructure for our app and internal AI models.
• Stripe - secure subscription payment processing. We do not store full payment card details on our servers.

6. Retention

• Service data: for the service period and for 1 year after it ends.
• Accounting documents: at least 5 years, or longer if required by law.

7. Your GDPR Rights

If you are an EU resident, you can request access, correction, erasure, restriction, objection, and data portability.

You can also withdraw consent at any time (when consent is the legal basis) and file a complaint with your supervisory authority (in Poland: UODO).

8. International Transfers

Our infrastructure is EU-based. If a provider transfers data outside the EEA, we rely on GDPR-compliant safeguards, such as Standard Contractual Clauses.

9. Contact

To exercise your rights or ask privacy questions, contact: troll0@x93.org.