Privacy Policy

Telepon

Last updated: April 13, 2026

SAAC sp. z o.o. ("we", "us", or "our") operates the Telepon mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

By using Telepon, you agree to the collection and use of information in accordance with this policy.

1. Information We Collect

1.1 Account Information

When you create an account, we collect:

Email address
Login credentials (password is stored in hashed form)

1.2 Automatically Collected Information

When you use the App, we automatically collect:

Device Information — device model, operating system version, unique device identifiers
Usage Data — features used, screens viewed, session duration, interaction events
Crash and Performance Data — error logs, stack traces, app performance metrics

We do not collect precise geolocation, contacts, photos, microphone or camera data.

2. Legal Bases for Processing

We process your personal data on the following legal bases under GDPR Article 6:

Performance of a contract (Art. 6(1)(b)) — Account information is processed to create and maintain your account and provide the App's core services.
Legitimate interest (Art. 6(1)(f)) — Device information, usage data, and crash data are processed to improve the App, fix bugs, and ensure stability. Our legitimate interest is to deliver a reliable, high-quality product.
Legal obligation (Art. 6(1)(c)) — We may process data where required to comply with applicable laws or regulations.
Consent (Art. 6(1)(a)) — Where required by law (e.g., Apple's App Tracking Transparency framework on iOS), we will request your explicit consent before collecting analytics data. You may withdraw consent at any time.

3. How We Use Your Information

We use the collected information to:

Provide and maintain the App and your account
Improve the App's functionality and user experience
Analyze usage patterns and fix bugs
Communicate with you about updates, security alerts, and support
Comply with legal obligations

4. Third-Party Services

We use the following third-party service to process analytics data:

PostHog — product analytics platform. PostHog collects usage and device data to help us understand how the App is used and to improve the product. PostHog processes data on our behalf under a Data Processing Agreement (DPA) that ensures equivalent data protection standards. PostHog's privacy policy is available at https://posthog.com/privacy.

We do not sell, rent, or share your personal data with third parties for their marketing purposes.

5. Tracking and Analytics Consent

On iOS devices, we comply with Apple's App Tracking Transparency (ATT) framework. Analytics data collection through PostHog will only occur after you grant permission via the ATT prompt. You can change this permission at any time in your device's Settings > Privacy > Tracking.

On Android devices, we use anonymous device identifiers for analytics. We do not use Google Advertising ID for tracking purposes.

6. Data Storage and Security

Your data is stored on servers located in the European Union. We implement the following technical and organizational measures to protect your personal data:

Data in transit is encrypted using TLS 1.2 or higher
Data at rest is encrypted using industry-standard encryption (AES-256)
Access to personal data is restricted to authorized personnel only
Regular security reviews and updates are performed

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours in accordance with GDPR Article 33, and will inform affected users without undue delay where required by GDPR Article 34.

No method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee its absolute security.

7. Data Retention

We retain your personal data for as long as your account is active or as needed to provide you with the App's services. If you delete your account, we will delete your personal data within 30 days, except where retention is required by law.

Analytics data is retained in aggregated, anonymized form and is not linked to your identity after account deletion.

8. Your Rights

Under the General Data Protection Regulation (GDPR) and applicable laws, you have the right to:

Access — request a copy of the personal data we hold about you
Rectification — request correction of inaccurate data
Erasure — request deletion of your personal data
Restriction — request restriction of processing of your data
Data Portability — receive your data in a structured, machine-readable format
Object — object to processing of your personal data
Withdraw Consent — withdraw your consent at any time where processing is based on consent

To exercise any of these rights, contact us at [email protected].

We will respond to your request within 30 days. If you believe your rights have been violated, you have the right to lodge a complaint with the President of the Personal Data Protection Office (UODO) in Poland.

9. Children's Privacy

Telepon is not directed at children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at [email protected], and we will delete such data promptly.

Users between the ages of 13 and 18 may use the App with the consent of a parent or legal guardian.

10. Account Deletion

You can delete your account and all associated personal data directly from the App's settings (Settings > Account > Delete Account). The process works as follows:

You will be asked to confirm the deletion request
Your account is immediately deactivated (soft-delete)
All personal data (email, login credentials) is permanently erased within 30 days
Usage and analytics data linked to your account is anonymized
This action is irreversible — once completed, data cannot be recovered

You may also request account deletion by emailing [email protected].

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy within the App and updating the "Last updated" date at the top of this page.

We encourage you to review this Privacy Policy periodically for any changes.

12. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us:

SAAC sp. z o.o.
ul. Leona Frankowskiego 26
20-736 Lublin, Poland

Email: [email protected]