PRIVACY POLICY OF WOLF SYSTEM MOBILE APPLICATION

I. DATA CONTROLLER
Name: Softwarely sp. z o.o. with its registered office in Warsaw, Poland
National Court Register Number (KRS): 0000516129
Address: ul. Świeradowska 47, 02-662 Warszawa, Poland
Email address: iod@softwarely.pl

II. WOLF SYSTEM
Softwarely sp. z o.o. (“we”, “us”, “our”) operates WOLF System which monitors, collects and presents
both internal and external measurements of environmental parameters. Our sensors measure
parameters of air (temperature, humidity, dustiness), parameters of water and parameters ofsoil (soil
moisture). The measurements are conducted periodically. The data collected by our sensors are stored
on servers belonging to WOLF System. The data can be accessed through our Web App, our Mobile
App and our TV Dashboards. WOLF System provides you with access to statistical and retrospective
analyses of environmental parameters, as well as with current information collected by our sensors.
WOLF System offers push notifications and email notifications, allowing you to continuously monitor
the environmental parameters relevant to you.

III. DEFINITIONS
Service
All services related to the development and maintenance of WOLF System and the Mobile App,
provided to you by Softwarely sp. z o.o.

Mobile App
WOLF System Mobile Application which allows you to access WOLF System and the measurements of
environmental parameters conducted by our smart sensors.

Device
The device you use to run our Mobile App (e.g. a smartphone).

GDPR
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).

Member State
A member state of the European Union.

Personal Data
Any information relating to an identified or identifiable natural person; an identifiable natural person
is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a
name, an identification number, location data, an online identifier or to one or more factors specific
to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural
person.

IV. TYPES OF DATA COLLECTED AND PURPOSES OF THE PROCESSING
When you use our Mobile App, we collect various information and Personal Data in order to provide
you with access to WOLF System through the Mobile App and in order to maintain and continuously
improve WOLF System and the Mobile App.

ACCOUNT REGISTRATION DATA
You are required to register your account in order to use our Mobile App and in order to access WOLF
System. To register your account, you will need to provide us with the following Personal Data: name,
surname, email address (“Account Registration Data”). We will use your Account Registration
Data to identify you as our Client and to provide you with our Service.

DEVICE DATA
Depending on the specifications of your Device, our Mobile App may request permission to access
information and Personal Data stored on your Device (“Device Data”). Our Mobile App may request
the following permissions:

• Storage permission
  

Our Mobile App requests permission to access your Device Data in order to provide you with access to
all functionalities of the Mobile App. Your Device Data will not be accessed for other purposes.

You can revoke your permission at any time. In order to revoke your permission, you need to access
the relevant settings of your Device. Please note that revoking or refusing the requested permissions
may impact the functioning of our Mobile App. Should you require assistance regarding the matter,
we encourage you to contact us directly for information and technical support.

USAGE AND TRACKING DATA
Depending on the specifications of your Device, our Mobile App may upon installation begin to
automatically collect information regarding the usage of the Mobile App. Our Mobile App may collect
information about your Device and its operating system, as well as your Device’s ID and its IP Address.
Our Mobile App may also collect information aboutthe usage of the Mobile App,such asthe frequency
and the nature of user’s activity (“Usage and Tracking Data”).
We collect the Usage and Tracking Data to better understand how our Clients use the Mobile App and
WOLF System. We use the collected data for statistical and analytical purposes and to improve our
Mobile App and WOLF System. We may also use the Usage and Tracking Data to prevent, analyse and
solve technical issues concerning the Mobile App or WOLF System.
Depending on the specifications of your Device, you may be able to prevent the Mobile App from
collecting the Usage and Tracking Data. Please note that preventing access to the Usage and Tracking
Data may impact the functioning of the Mobile App. Should you require assistance regarding the
matter, we encourage you to contact us directly for information and technical support.

OTHER PERSONAL DATA
Our Mobile App collects and processes your Email Address in order to identify you as our Client and in
order to send you requested email notifications. Providing your email address is not required to use
our Mobile App.
We may collect other Personal Data you choose to share with us. For example, we may collect and
store the Personal Data you share with us through traditional or electronic correspondence in order
to respond to your requests and inquiries. You have the right to obtain information as to whether or
not your Personal Data is being processed and which categories of Personal Data are being processed
(see also: “VIII. YOUR RIGHTS”).

V. LEGAL BASIS FOR PROCESSING
Performance of a contract
We collect and process the Account Registration Data, Device Data, the Usage and Tracking Data and
Other Personal Data in order to provide you with our Service and all of itsfunctionalities and to analyse
and solve technical issues concerning the Mobile App or WOLF System. Under GDPR, the legal basis
for processing data in that manner is point (b) of Article 6(1) of GDPR.
Legitimate interests
We collect and process the Usage and Tracking Data for statistical and analytical purposes in order to
continuously improve our Mobile App and our Service. The legal basis for processing data in that
manner under GDPR is point (f) of Article 6(1) of GDPR.
Consent
With your consent, we collect your Email Address in order to offer you additional functionalities of our
Mobile App,such as email notifications. The legal basisfor processing data in that manner under GDPR
is point (a) of Article 6(1) of GDPR. You have the right to withdraw your consent at any time. The
withdrawal of consent does not affect the lawfulness of processing based on consent before its
withdrawal.

VI. RECIPIENTS OF DATA
In order to provide, maintain and improve our Service, we cooperate with third party companies and
individuals (“Partners”). Our Partners may gain access to Personal Data in order to provide requested
services. Our Partners have been obligated not to use Personal Data for any other purposes and not
to disclose Personal Data to any third parties.

VII. PERSONAL DATA RETENTION
The period for which the Personal Data are stored islimited and depends on the purpose of processing.
The Personal Data collected to provide you with our Service are stored while you use our Service. The
Personal Data may be stored for a longer period of time if storing the Personal Data is necessary for
the establishment, exercise or defence of legal claims. The Personal Data collected for statistical and
analytical purposes are stored until those purposes are fulfilled. The Personal Data you choose to share
with us in your correspondence are stored until our communication is concluded.

VIII. YOUR RIGHTS
Withdraw your consent at any time
You have the right to withdraw your consentto the processing of your Personal Data based on consent.
The withdrawal of consent does not affect the lawfulness of processing based on consent before its
withdrawal. Once you withdraw your consent, we willstop processing your Personal Data, unlessthere
is another legal basis for processing.
Access your data
You have the right to obtain confirmation as to whether or not your Personal Data is being processed,
and, where that is the case, you have the right to obtain access to the Personal Data and to obtain
information such as the purposes of the processing, the categories of Personal Data concerned, the
recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in
particular recipients in third countries or international organisations, and the envisaged period for
which the Personal Data will be stored.
Right to rectification
You have the right to obtain the rectification of inaccurate Personal Data concerning you. Taking into
account the purposes of the processing, you have the right to have incomplete Personal Data
completed, including by means of providing a supplementary statement.
Right to erasure
You have the right to obtain the erasure of your Personal Data, especially if the Personal Data are no
longer necessary in relation to the purposes for which they were collected or otherwise processed, or
if you have withdrawn consent on which the processing is based, and where there is no other legal
ground for the processing, or if you object to processing pursuant to Article 21(1) of GDPR and there
are no overriding legitimate grounds for the processing.
Right to restriction of processing
You have the right to obtain restriction of processing your data, especially if you contest the accuracy
of the Personal Data or if you have objected to processing pursuant to Article 21(1) of GDPR, pending
the verification of your objection. Where processing has been restricted, such Personal Data will, with
the exception of storage, only be processed with your consent or for the establishment, exercise or
defence of legal claims or for the protection of the rights of another natural or legal person or for
reasons of important public interest of the European Union or of a Member State.
Right to object
You have the right to object, on grounds relating to your particular situation, to processing of your
Personal Data which is based on point (f) of Article 6(1) of GDPR. Once you object to processing of your
Personal Data, we will no longer process the data unless we can demonstrate compelling legitimate
grounds for the processing which override the interests, rights and freedoms of the data subject.
Regardless of the objection, we may process the Personal Data for the establishment, exercise or
defence of legal claims.
Right to data portability
You have the right to receive the Personal Data concerning you, which you have provided to us, in a
structured, commonly used and machine-readable format and have the right to transmit those data
to another controller, where the processing is carried out by automated means and where the
processing is based on consent pursuant to point (a) of Article 6(1) of GDPR or on a contract pursuant
to point (b) of Article 6(1) of GDPR.
Right to lodge a complaint with a supervisory authority
If you believe that the processing of your Personal Data infringes on the provisions of GDPR, you have
the right to lodge a complaint with a supervisory authority, in particular in the Member State of your
habitual residence, place of work or place of the alleged infringement.
The main regulator for data protection in Poland isthe President of the Personal Data Protection Office
(Prezes Urzędu Ochrony Danych Osobowych).

IX. EXERCISING YOUR RIGHTS AND REQUESTING FURTHER
INFORMATION
Should you wish to exercise any of the rights listed above or request further information regarding the
processing of your Personal Data, we encourage you to contact us through traditional mail or through
email. We will address your requests and inquiries without undue delay and in any event within one
month of receipt of the request. Any communication or actions taken by us in relation to your requests
and inquiries will be provided free of charge.