ParagonOS™ Privacy Policy

1. Controller and contact

The data controller for personal data processed in connection with the App is the operator of ParagonOS™. For privacy, GDPR rights requests and complaints: kontakt@estateos.pl.

kontakt@estateos.pl is the operator’s inbox. Please put “ParagonOS” in the subject line.

2. Scope — ParagonOS™ only

This Policy covers only the App: a wallet for bottle-return tickets, fiscal receipts and loyalty cards, including a map of return points, deadline reminders, optional family sharing via iCloud, and optional add-to-Apple-Wallet.

Property listings, estateos.pl accounts, CRM, portal payments and other EstateOS™ features are governed by separate documents and are outside this Policy.

3. How processing works

The App does not operate its own account server and does not require a login or password with the operator. Your identity is your Apple ID on the device.

Content you create (scan photos, OCR text, barcode/QR payloads, amounts, dates, notes, display name) is stored on device. If you enable iCloud, it may sync in your private Apple cloud (CloudKit, container `iCloud.pl.paragonos.app`). The App operator cannot read the contents of your private CloudKit database.

4. Categories of data

Depending on the features you use, we may process:

• User content — photos of tickets, receipts and cards; OCR text; barcode and QR values; amounts and dates; notes; the retailer you assign.
• Name / display name — if you provide one, including for family sharing.
• Location data — approximate or precise device location only if you grant the iOS permission and open the bottle-return map. Location is used on-device to sort nearby results.
• Apple / iCloud identifiers — as needed for sync and sharing (CKShare) after you opt in.
• Device technical data — as required by iOS (camera, photos, notifications, Face ID locally only).

5. Purposes and legal bases (GDPR)

We process data to:

• provide the App (store and display tickets, receipts and cards, till codes, reminders) — GDPR Art. 6(1)(b) (performance of the contract to use the App) and Art. 6(1)(f) (legitimate interest in running features you enable);
• show nearby return points — Art. 6(1)(a) (iOS system permission, which you can withdraw in iPhone Settings);
• sync and share with family via iCloud — Art. 6(1)(b) and Art. 6(1)(a) (your decision to enable iCloud / send an invite);
• add a card to Apple Wallet — Art. 6(1)(b), at your request, via PassKit on the device;
• answer mail to kontakt@estateos.pl — Art. 6(1)(c) (legal duties, including GDPR) and Art. 6(1)(f);
• establish, exercise or defend legal claims — Art. 6(1)(f).

6. Camera, photos and Face ID

The camera and photo library are used only to scan a ticket, receipt or loyalty card, or to import a photo when live scanning is unavailable. They are not used for advertising profiles.

Face ID / Touch ID — if you enable the in-app lock — runs only on the device. Biometric data is not sent to us or stored outside Apple’s on-device mechanisms.

7. Location and return-point map

The map uses public datasets: MapaKaucji.pl (a catalogue of machines is downloaded; your home address is not sent) and OpenStreetMap / Overpass API. Overpass receives a map bounding box for the current view, not a street address.

You may refuse location permission; the App still works without “nearby” map results.

8. Apple Wallet (PassKit)

If you choose Add to Apple Wallet, the loyalty pass is assembled and signed on the device and handed to system Wallet via PassKit. The operator does not run a user-pass hosting server and does not receive a copy of your card in order to host it outside the App and your iCloud.

9. Notifications

Reminders about ticket expiry, warranty or returns are scheduled locally on the device (iOS notifications) after you allow them. They are not used to build an advertising profile.

10. Family (iCloud)

Sharing tickets, receipts and cards with invited people uses Apple CloudKit Share. Only people who accept the invite can see that content. The operator does not moderate family content and cannot view it.

11. Recipients

Recipients — only as needed for features you enable — may include:

• Apple — iOS, iCloud / CloudKit, notifications, PassKit / Apple Wallet, the App Store, under Apple’s policies;
• OpenStreetMap / Overpass — a query for points in the map area;
• MapaKaucji.pl — a public machine catalogue (not your profile).

12. Transfers outside the EEA

Apple may process data outside the European Economic Area under Apple’s terms (including standard contractual clauses). Using iCloud, Apple Wallet or the App Store also means Apple’s rules apply.

13. Retention

Data in the App remains until you delete it or uninstall the App. iCloud data follows your Apple ID settings. Mail to kontakt@estateos.pl is kept as needed to handle the request and for limitation periods or legal duties.

14. Your rights

You have the rights of access, rectification, erasure, restriction, portability, objection and withdrawal of consent (where processing is based on consent), and the right to lodge a complaint with the President of the Polish DPA (uodo.gov.pl) or another competent supervisory authority.

Delete in-app content on the device (for example a card, receipt or ticket), or uninstall the App and turn off iCloud for ParagonOS™. For other requests write to kontakt@estateos.pl with subject “ParagonOS”.

15. Children

The App is not directed at children under 13 and is not in Apple’s Made for Kids programme. We do not knowingly collect children’s data.

16. No tracking or ads

We do not sell personal data. We do not use it for behavioural advertising. We do not use App Tracking Transparency because we do not track you across apps and websites as defined by Apple.

17. Changes

An updated version will be published at the same URL with a new date. Material changes will be announced in the App or on the support page where proportionate.

18. Contact

Privacy questions about ParagonOS™: kontakt@estateos.pl (subject: “ParagonOS — privacy”).