Privacy Policy

01Data Controller

02Data We Collect

a) Contact form data:

• Company name and contact person name,
• Business e-mail address,
• Telegram username or other business contact,
• Target markets / GEOs,
• Selected campaign package,
• Project description or message content.

b) Business communication data: e-mail and Telegram correspondence, meeting notes, information needed to prepare a business offer.

c) Technical website data: IP address (via server logs and third-party tools), browser type and device information, website activity data, cookies.

d) Contract and accounting data (when cooperation is established): company name, address, tax identification details, invoice and payment data, contract-related correspondence.

03What We Do Not Collect

Just Money does not collect, store, verify, or process:

• users' identity documents or KYC/AML documentation,
• bank login credentials, card numbers, or payment security data,
• wallet private keys or seed phrases,
• personal data of end users who register or complete KYC within client platforms.

04Purposes of Processing

• Responding to business inquiries — to reply to your message and provide requested information,
• Preparing business offers — to analyze your project and prepare an individual proposal,
• Providing B2B services — to perform agreed services including activation campaigns, UX diagnostics, and Activation Diagnostics Reports,
• Contract and accounting obligations — to issue invoices, maintain accounting records, and comply with Polish tax and legal obligations,
• Website security and maintenance — to ensure functionality, prevent abuse, and maintain technical infrastructure,
• Establishing or defending legal claims — to protect Just Money's legal rights and enforce agreements.

05Legal Bases for Processing (GDPR Article 6)

• Art. 6(1)(b) GDPR — processing necessary to take steps before entering into a contract or to perform a contract,
• Art. 6(1)(c) GDPR — processing necessary to comply with legal obligations (accounting and tax obligations under Polish law),
• Art. 6(1)(f) GDPR — legitimate interest, including responding to business inquiries, maintaining business relationships, securing the website, and protecting legal claims,
• Art. 6(1)(a) GDPR — consent, where required (e.g. for optional analytical cookies).

This Privacy Policy constitutes fulfilment of the information obligation toward data subjects under GDPR Articles 13 and 14 and UODO guidance.

06Contact Form & FormSubmit

When you submit a form on our website, your data is transmitted via FormSubmit.co — a third-party form processing service — to our e-mail inbox.

FormSubmit.co processes your form submission data as a data processor on our behalf. Their privacy policy is available at formsubmit.co. Form data is transmitted to our e-mail address and stored in our mailbox.

07Recipients of Data

Your data may be shared with trusted service providers only when necessary:

• FormSubmit.co — contact form processing (transmits form data to our e-mail),
• Google — Google Fonts (your IP address is transmitted to Google servers when fonts load),
• Hosting and website providers — for website operation and maintenance,
• WordPress and Elementor — website content management tools,
• E-mail service providers — for business correspondence,
• Accounting and invoicing service providers — for invoice and contract administration,
• Legal, tax, or business advisors — where legally required or necessary to protect our rights.

08International Data Transfers

Some service providers may be located outside the European Economic Area (EEA):

• FormSubmit.co (USA) — processes contact form submissions. Transfers are based on standard data protection terms consistent with GDPR requirements,
• Google (USA) — Google Fonts loads fonts from Google CDN servers, which may involve transmission of your IP address. Transfers are based on Standard Contractual Clauses and adequacy decisions.

Where required, international transfers are based on appropriate safeguards permitted under GDPR Article 46, including Standard Contractual Clauses or adequacy decisions issued by the European Commission.

09Data Retention

• Contact form inquiries and business correspondence: for the duration of communication and up to 3 years after last contact, for claim-protection purposes,
• Client business relationships and contracts: for the duration of the relationship and the limitation period for claims (generally up to 6 years under Polish civil law),
• Accounting and invoice data: for the period required by Polish accounting and tax law (5 years from the end of the tax year),
• Technical logs: for a limited period necessary for website security (typically up to 12 months).

10Cookies

The website may use technical cookies necessary for website operation (e.g. session cookies, security cookies used by WordPress).

At this time, the website does not use analytical, marketing, or tracking cookies beyond what is technically necessary for operation.

If analytical or marketing tools are added in the future, this Policy will be updated and, where required under applicable law, appropriate consent will be obtained. You can manage cookies through your browser settings at any time.

11Your Rights Under GDPR

12No Automated Decision-Making

Just Money does not use personal data collected through the website to make automated decisions that produce legal or similarly significant effects.

13Security

We apply reasonable technical and organizational security measures to protect personal data against unauthorized access, loss, alteration, disclosure, or destruction.

14Data Processing on Behalf of Clients

As a general rule, Just Money does not process personal data of end users on behalf of client platforms in a processor capacity under Article 28 GDPR.

User feedback collected during campaigns is anonymized before inclusion in any report. No individual-level personal data is transferred to clients in Activation Diagnostics Reports.

If a specific project requires Just Money to act as a data processor for a client, a separate Data Processing Agreement (DPA) will be required before processing begins, consistent with GDPR Article 28 requirements.

15Changes to This Privacy Policy

We may update this Privacy Policy when we change our website, tools, services, or when legal requirements change. The current version is always available at justmoney.pl/privacy-policy/.

16Contact