§ 1. WHO MANAGES THE WEBSITE | DATA CONTROLLER

1. The website timeCamp.com (hereinafter referred to as „TimeCamp”) is managed by TimeCamp Spółka Akcyjna [joint stock company] with its registered office at the following address in Wrocław: Al. Wiśniowa 36A, premise 331, 53-137 Wrocław, entered into the register of businesses under the number KRS 0000755317, registration entry of which is maintained by the District Court for Wrocław - Fabryczna in Wrocław, 6th Commercial Division of the National Court Register statistical identification number REGON: 021311614, tax identification number NIP: 8943003832, share capital PLN 112 200 (hereinafter referred to as “Supplier”).

2. The controller of your personal data processed to provide you with e-services offered by TimeCamp SA, such as TimeCamp software inquiry form or newsletter, as well as personal data processed for legitimate interests of the controller and its subcontractors(for example for the purposes of marketing of services or products offered by the data controller or third parties) is Supplier.

3. You can contact us here via email at [email protected] or by traditional mail at the following address: TimeCamp Spółka Akcyjna, Al. Wiśniowa nr 36A lok. 311, 53-137 Wrocław.

§ 2. WHAT THIS PRIVACY POLICY GOVERNS

1. This Privacy Policy applies to timeCamp.com website, TimeCamp E-service, User Account E-service, Newsletter and other E-services offered by Supplier and all other content, services and products which you can purchase or use via timeCamp.com, payment methods, Time Camp customer support and other services which we provide to you (we will call these services and products collectively “Time Camp Services” for short).

2. This Privacy Policy applies in particular to personal data and other information which we receive from you when you use TimeCamp Services.

3. We respect your right to privacy and will only process your personal data in accordance with applicable data protection legislation in the EU and other states.

4. In particular, we conform with the requirements of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as “RODO”, “GDPR” or “Regulation”) (Official Journal of the European Union of 2016, No L 119, pp. 1)

5. Supplier cooperates with subcontractors, including related company TimeCamp, Inc.,440 N Barranca Ave #4967 Covina, CA 91723 United States of America, payment providers, customer service software providers and other entities (hereinafter referred to as the „Partners”).

6. All Partners with whom Supplier cooperates meet the highest standards of data and information security, which is being verified by the Supplier during periodic audits. A detailed list of the subcontractors that Supplier uses can be found at the link: https://www.timecamp.com/legal-subprocessors2

§ 3. DATA WE COLLECT

1. When you create a TimeCamp User Account you need to provide the following information: (a) e-mail address and (b) password (which is encrypted, so we cannot access it). Without this information we cannot provide you with the User Account E-service. The above information is secured by your Time Camp account password. You are responsible for its security.

2. When you use TimeCamp Services we may also collect the following information:

a) technical details about devices which you use to access TimeCamp Services, including: Internet and/or network connection (including your IP address), mobile device identifiers, localisation your operating system, browser type or other software, your hardware details, or other technical details provided by your web browser, depending on your settings. The foregoing technical details concerning our users and their actions and patterns do not contain personal data;

b) details of your use of TimeCamp Services including, but not limited to: metrics information about when and how you use TimeCamp Services, traffic data, your geographical location, your purchase history and links accessed, your preferences and choices, preferred language and your chat communications;

c) localisation of the mobile device you are using, provided that the GPS service is activated by the Account Administrator and that you (User) accepts the use of GPS service;

d) other information required in order to help you with any queries/support you may need assistance with via TimeCamp and customer support, including communications between us;

e) other information which you supply us via our TimeCamp Services.

3. Whether and how Supplier processes your payment data depends on the used payment method/ platform or provider. Supplier processes only limited data concerning the payment in an encrypted/ anonymised form. When you purchase something, once the transaction is finished we receive a notice from the payment processor. We do not however get access to the actual data concerning the payment.

§ 4. PROTECTING CHILDREN

Under Article 8 (1) of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC we cannot knowingly collect personal data about children under 16 and we do not process such data.

§ 5. HOW WE COLLECT INFORMATION ABOUT YOU

1. Your data can be collected, processed and used directly or via our Partners, in the following ways:

a) information you give us using TimeCamp Services,

b) data given when you contact us or report a problem with TimeCamp Services.

2. We can also ask you to fill in surveys, which we use for research purposes. The participation in a survey is entirely voluntary and if you don’t want to respond to the survey you don’t have to. We can collect this information ourselves via our TimeCamp Services or via trusted partners cooperating with us in optional features, such as surveys or polls.

§ 6. COOKIES

1. This policy describes the different types of cookies used on the timeCamp.com website and explains how you can control them.

2. Supplier and our Partners can collect data via cookies or similar technologies.

3. On our online and mobile services, we use technologies to collect information that help us improve our services users experience. We refer to these technologies, which include also cookies, collectively as “cookies”.

4. By using the Services and viewing the cookie notice that appears together with the TimeCamp services, you agree that we can store and access cookies as described in this policy.

5. Cookies are small text files that are stored on your device (e.g. computer or mobile phone), which are widely used in order to make webpages or other online services work or to be better or more efficient. They can do this because webpages and other online services can read and write these files, enabling them to recognise you and remember important information that will make your use of them more convenient.

6. Below we list the different types of cookies we may use when providing TimeCamp Services:

a) “Essential cookies” are essential to the proper operation of our services in order to enable you to move around them and to use their features. Without these cookies services you have asked for, such as accessing secure areas of a webpage cannot be provided. We also use cookies to help prevent fraudulent and illegal use of login data. These cookies are essential for using the Services, but you can turn them off. However, if you turn them off, it may severely affect the way we provide you with your Services as well as the way you use them.

b) Cookies aimed at boosting performance. These frequently include analytics cookies. They collect information about your use of timeCamp.com website and enable us to improve the way it works, e.g. these cookies show us which pages on our website are the most frequently visited by our Users, allow us to see the overall patterns of usage of the website, help us record any difficulties the users have with our Services and show us whether our advertising is effective or not. We also use cookies to help you navigate within our webpage and travel back to pages you visited.

c) In some circumstances, we may use functionality cookies, which allow us to remember the choices you make on the Services and to provide enhanced and more personalized features, such as customising a certain webpage. Thanks to these cookies we can also remember if we have asked you to participate in a promotion we organise. All of these features help us to improve your visit to the website.

d) We may also use targeting or advertising cookies to deliver ads that we believe are more relevant to you and your interests. Our service providers may use such cookies as well. For example, we may use targeting or advertising cookies to limit the number of times you see the same ad on our Services and to help measure the effectiveness of our advertising campaigns.

7. In certain circumstances, we may work with third parties to provide the Services. Third-party advertisers and other organizations may use their own cookies to collect information about your activities on the Services and/or the advertisements you have clicked on. This information may be used by them to serve advertisements that they believe are most likely to be of interest to you based on content you have viewed previously or to measure the effectiveness of their advertisements. We do not control these cookies and to disable or reject third-party cookies, please refer to the relevant third party’s webpage.

8. Currently we use cookies from external companies: Google Inc. (Google Analytics), Facebook Inc. (Facebook), to create website statistics and to deliver offers relevant to you and your interests.

9. At any time you can turn off cookies on Services. You may refuse to accept cookies at any time by activating the setting on your browser or device which allows you to refuse cookies or similar technologies. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider’s website via your help screen. If cookies are disabled, not all features of the Services may operate as intended.

§ 7. THE PURPOSES OF THE PROCESSING

1. When we process data about you, we do so as necessary to provide E-services to you (i.e. to perform agreement between us), and to meet our legal obligations (e.g. tax, accounting) or for other reasons that are important for us.

2. Reasons that are important for us:

a) informing you about services and products we offer

b) making sure that the information we provide is relevant for you

c) protecting the security of our systems and webpage TimeCamp

d) protecting you against payment fraud

3. When we rely on the reasons that are important for us while processing your personal data, each time we consider in advance any potential impact it may have on processing of your data and your rights. For other purposes we will ask for your consent and you will be entitled to withdraw this consent at any time, although, the withdrawal will not impact the validity of the processing before your consent has been withdrawn.

§ 8. HOW DO WE USE YOUR DATA

1. We will use your data for the following purposes:

a) to carry out our obligations arising from any contracts between you and us, like providing access to User Account, providing the services you purchased, providing you with the technical support and allowing you to use Time Camp Services and their functionalities;

b) to ensure that TimeCamp Services are provided in the most effective manner for you and for your device from which you access TimeCamp Services;

c) tax, legal and accounting;

d) to send newsletters concerning the services offered by Supplier, special and time-limited offers or advertisements, offers or recommendations concerning services based on the information concerning your orders or activities at our webpage- if you agree to such communication channel;

e) to protect you from an unauthorized use of your account and against fraud during payments;

f) to evaluate the effectiveness of our marketing actions and improve the quality of our marketing;

g) to notify you about changes to TimeCamp Services and our legal documents;

h) to improve or modify TimeCamp Services;

i) to calculate conversion rates and other elements of TimeCamp performance;

j) in connection with the services of our Partners, such as payment processors, located in and outside the European Union, but only to the extent necessary to provide those services;

k) for the accountability purposes as defined by EU legislation (GDPR);

l) to create a universal TimeCamp user’s profile, based on information about your use of TimeCamp Services, in order to make our TimeCamp Services and other products and functionalities offered by us even more interesting for you.

2. Whenever we’re personalizing our marketing communications, offers and adverts, we may profile your personal data.

3. We do not make however automated decisions (forced for example via algorithms) that could affect your legal situation.

4. If you decide that you no longer want to receive personalized offers or no personalized advertising news at all, you can contact us and object to this at any time.

5. You can object to the processing of personal data concerning you for marketing purposes, by following the link "unsubscribe" attached to our marketing emails or just contacting us directly here and at the following address: TimeCamp SA, Al. Wiśniowa nr 36A lok. 311, 53-137 Wrocław.

6. We might process some aggregated and general non-personal data on user behaviour (e.g. sales per region, number of support tickets) and share it with third party partners who cooperate with us in the scope of providing TimeCamp Services (for example, payment providers) in order to support, improve or amend TimeCamp Services or to help partners improve their products, which our users have ordered. We may also share nonpersonal data with data analysis services to help us provide TimeCamp Services.

§ 9. HOW WE STORE YOUR DATA

1. All information you provide to us is stored on our secure Supplier servers or those of our verified Partners.

2. Supplier with the account Administrator does not provide otherwise, the data collected by Supplier are stored on servers located in United States of America by the company Amazon Web Services EMEA SARL that has implemented the highest security measures and is ISO certified. Amazon Web Services EMEA SARL provides data center services in accordance with the following privacy policy: https://aws.amazon.com/privacy/ If you would like the data collected by the Supplier to be stored in another data center, please email [email protected]

3. We apply appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage.

4. We will store your personal data only for as long as we will be required in order to fulfil the purposes outlined in this Privacy Policy. Longer storage period might be required by law e.g. tax, accounting purposes or other legal requirements and obligations.

5. As soon as we will no longer require your personal data to provide Time Camp Services or for other purposes mentioned in this Policy, we will promptly delete or anonymise it. In particular:

a) we will store information that is associated with your User Account for the duration necessary to provide TimeCamp Services pursuant to the agreement between us (that is until you delete your User Account). If you decide to delete your User Account limited information may still be stored for tax, legal or accounting purposes;

b) if you don’t have a User Account and you decide to contact us, we will store the correspondence with you as long as necessary for legal or accountability purposes;

6. Terms and Conditions of providing TimeCamp services can determine different rules concerning processing of your data. Then, such special conditions may be superior or complementary to this Policy.

§ 10. DATA SHARING

1. Any communications you have via TimeCamp Services may reveal your username or other details about you.

2. In general, we don’t share information about you to third parties. There are exceptions, like our Trusted Partners, that help us deliver our TimeCamp Services and functionalities to you. We can assure you that we provide our partners only with minimum information necessary. These entities may have potential or actual access to limited data about you and process it on our behalf as “Processors”:

a) third party vendors that provide us with internal management and data sharing tools (e.g. Google);

b) third party vendors that provide us with analytical tools (e.g. Chartmogul, Amplitude);

c) third party vendors that provide us with email marketing tools and help us manage our email communications;

d) third party vendors that provide us with error tracking and crash reporting tools (e.g. Jira, Stackify);

e) third party vendors that provide us with customer service software & support ticket system to help us manage requests (e.g. LiveChat, HelpDesk);

f) our professional advisors dealing f.ex. with legal, tax, audit or accounting matters;

g) social media platforms for the purpose of personalized and targeted communication (e.g. Twitter, Facebook);

3.During the payment process, we may also share information about you with other trusted partners who process it independently as the so-called data controllers:

h) payment-providers for payment processing purposes;

i) banks and financial institutions to obtain payment;

j) third party anti-fraud service providers;

4. When required by law, we may also share your data with police or other government authorities (including your IP address and details of suspected unlawful or fraudulent activity like unauthorized use of payment methods and security risk scores).

5. Your data may be processed, stored and transferred outside the European Economic Area (EEA) to states such as Canada. Privacy laws in these states may not offer the same level of protection as in your country or in the EEA. But whenever we’re sharing your personal data outside this area, we will do so on the basis of the EU standard contractual clauses or Privacy Shield Framework which are lawful measures to transfer your data and establish adequate protection of your personal information.

6. TimeCamp use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

§ 11. THIRD PARTY DATA COLLECTION AND EXTERNAL SERVICES

Supplier Services may, from time to time, contain links to and from the webpages or services of third parties. Our Privacy Policy does not extend to these external webpages or companies, so please refer directly to their privacy policies.

§ 12. MISCELLANEOUS

1. Please be aware that we are subject to various laws and we may be required to comply with law enforcement or other legal requirements.

2. In the unlikely event of a reorganisation or merger of Supplier or Supplier accounts, we may transfer personal data to an involved third party who will protect it to at least the same level as Supplier does in this Privacy Policy.

§ 13. USERS RIGHTS

1. You have the right to object to the processing of your personal data in certain situations f.ex. for marketing purposes at any time. You can do so by contacting us here, changing your settings within TimeCamp account, and also by choosing an optout/ unsubscribe option contained in the email communications from TimeCamp.

2. Depending on where you live, you may have additional privacy rights. Pursuant to GDPR you have, among others, the following rights:

a) to access data we hold about you;

b) to request that we delete your personal data;

c) to rectify/correct your personal data;

d) to restrict processing of your data;

e) request for the cessation of data processing;

f) to transmit your data to another entity;

g) obtain information about the use of automated decision-making, including profiling;

h) to indicate whether the provision of personal data is a statutory or contractual requirement and about the possible consequences of failing to provide the data;

i) to lodge a complaint with a data protection authority.

3. In addition to the rights set forth in paragraph 2 above, at any time Your Account Administrator may contact Supplier to schedule a security audit of Your data subject to the following:

a) Your Account Administrator will write an email to [email protected] to determine the date, purpose and scope of the audit;

b) Supplier and the Account Administrator will agree in advance on the audit start date, purpose and duration, as well as its security and confidentiality rules applied during and after the audit;

c) The Supplier may charge a fee (based on reasonable costs incurred) and will provide it to Your Account Administrator along with the basis for its charge before the audit begins. Your Account Administrator will be responsible for payment of any fees charged by the designated auditor;

d) Supplier may object to the appointed auditor on behalf of Your Account Administrator for objective reasons. If this occurs, Your Account Administrator will need to appoint another auditor or conduct the audit itself;

e) Nothing in this Privacy Policy will obligate Supplier to provide in an audit data regarding other customers' confidential information, financial data, intellectual and legal values, and other confidential information of Supplier, the disclosure of which in Supplier's opinion could violate applicable laws, including the rights of Supplier's other customers and/or the security of Supplier's system.

4. You may exercise these rights by contacting us by sending an email to [email protected] or at: TimeCamp SA, Al. Wiśniowa 36A lok. 311, 53-137 Wrocław.

5. These rights can be limited by other legal provisions, for example the right to erasure (‘right to be forgotten’) may be limited when processing of your data is necessary to comply with legal obligation requiring data processing on the basis of EU laws or laws of the member state to which Supplier is subject. An example of such provision is article 74 (2) (1) of the Accounting Act of 29 September 1994 (consolidated text, Journal of Laws of 2018, item 395) requiring us to store account books for the period of 5 years from the beginning of the year following the financial year which the account books concern.

§ 14. CHANGES TO THIS PRIVACY POLICY

1. We may change this Privacy Policy if we think it's necessary for legal reasons or to reflect changes in TimeCamp Services. If so, we will make the changed Privacy Policy available online and we'll notify you.

2. Once we change the Privacy Policy, it will become legally binding on you 30 days after we post the new version online.

3. If you don't agree to those changes (regardless of whether you email us), then unfortunately we must ask you to cease using TimeCamp Services.