Rules

10. Privacy Policy

Last updated: 4 November 2025

Intro

IOOI Sp. z O.O (“PocketBank” or “we”) welcomes you. This Privacy Notice (“Privacy Notice”) applies to our Website https://pocketbank.net/ (the “Service”). The Privacy Notice describes which of your personal data PocketBank collects, how stores, processes, and uses it, and what happens when you use the Service.

About us

We are the controller of your personal data processed through the Service. This means that we determine the purposes and means of personal data processing. Pay attention that you can fall into several categories depending on your actions.

NameIOOI Sp. z O.O
Registration number525273421
AddressGęsia 8/205, 31-535 Kraków, Polska
Emailsupport@pocketbank.net – for general and privacy inquiries

About you

When you visit the Service, you become our user (“User”). We divide the Users into categories so you can easily find details about the processing of your personal data.

Type of UserDescription
VisitorUser who visits the Website
UserUser who registers with the Service
Other RequesterUser who fills out the “Contact us” form on another topic; User who contacts us via Telegram or email

Please note! We do not knowingly process the personal data of Users under the age of 18. If you are such a User or the legal representative of such a User, please contact us.

Personal data

Sources of data

We receive your data when you visit the Service and interact with it, depending on your actions on the Service. Additionally, we may receive your data when you contact us via Telegram or email.

You can change your personal data by exercising your right to rectification or by the Service functionality. Please note that the same lawful basis and storage terms apply to the changed data.

We may also (although we do not necessarily do so) receive data from third parties. It depends on your settings and the features you use.

Lawful bases for processing

To process your personal data, we rely on the following lawful bases:

  • performance of the contract — for the processing of personal data necessary for the negotiating on, conclusion, and performance of a contract (mainly, the Terms of Service) with you;
  • legitimate interest — for the processing necessary at the development of our services, taking into consideration your interests, rights, and expectations;
  • legal obligation — for the processing as required by applicable laws (for example, to comply with tax or KYC/AML regulations) or if requested by a law enforcement agency, court, supervisory authority, or another state-authorised public body;
  • consent — for additional specific purposes.

Visitors’ data

When you use the Website as the Visitor, we collect some data automatically. We need technical data to operate, support, and improve the Website’s functionality.

DataDescriptionReasons for processingLawful basis
Necessary technical dataInformation about your operating system, device type, browser name and versionThe smooth operation of the WebsitePerformance of the contract
Necessary cookiesInformation that is necessary for the operation of the WebsiteImproving your experience of using the WebsitePerformance of the contract
Marketing cookiesMarketing information used to match relevant advertising to youMarketingConsent
Preference cookiesInformation necessary for operating some services on the WebsiteThe operation of some services on the WebsiteConsent
Statistics cookiesInformation that helps us to understand how you interact with the Website by collecting and reporting informationImprovement of the Website and analysis of the statistic for other purposesConsent

Data storage

DataStorage period
Necessary technical dataStored during the use of the Website and for 5 years from the last visit.
CookiesStored during the expiry period provided in our Cookie Policy.

Registration data

When you register an account and start to use our service, we collect or assign the data to enable you access and correct work of the Service.

DataReasons for processingLawful basis
Name, surnameRegister and fill the accountPerformance of the contract
EmailRegister and fill the accountPerformance of the contract
Phone numberRegister and fill the accountPerformance of the contract
User IDRegister and fill the accountPerformance of the contract

Data storage

Data that is processed based on performance of the contract: Stored for 5 years from the last interaction.

General technical data

This section includes information collected for maintaining and optimising the technical aspects of the service, such as device information, browser details, and session logs. This data helps ensure the smooth functioning and security of the service.

DataReasons for processingLawful basis
IPIP address from which the request originated.Legitimate interest
User IdUnique identifier for the user.Performance of a contract
Browser InfoInformation about the user's browser.Performance of a contract
Event IDUnique identifier for the audit event.Performance of a contract
Creation TimeTimestamp indicating when the audit event occurred.Performance of a contract
Action typeIndicates if the audit event is an administrative action.Legitimate interest
SettingsIndicates if the user associated with the audit event is muted.Performance of a contract
Event typeType of audit event (e.g., login, logout, data access).Performance of a contract
User AgentUser agent information associated with the audit event (e.g., browser, device).Legitimate interest

Data storage

Data based on performance of the contract: Stored for 5 years from the last interaction.

Data based on legitimate interest: Stored for 5 years from the last interaction, if you do not object.

Account data

Account data consists of information related to user accounts, including registration details, authentication records, and account preferences. This data is essential for user access and customization of the service.

DataDescriptionLawful basis
AML statusIndicates if AML (Anti-Money Laundering) is enabled for the user’s transactions.Legal obligation
Company NameName of the company associated with the user.Performance of a contract
Creation timeTimestamp indicating when the user account was created.Performance of a contract
EmailEmail address of the user.Performance of a contract
Name and surnameName of the user.Legitimate interest
Group IdIdentifier for the group associated with the user.Performance of a contract
LocaleLocale settings for the user.Legitimate interest
TimestampTimestamp indicating when the user account was last modified.Legal obligation
OIDC ProviderOpenID Connect (OIDC) provider type associated with the user.Performance of a contract
Password hashPassword associated with the user.Performance of a contract
PhonePhone number associated with the user.Performance of a contract
Referral dataReferral code associated with the user. Identifier for the user who referred this user.Legitimate interest
Registration IPIP address from which the user registered.Legitimate interest
UserTypeType of user account.Performance of a contract
Verification LevelLevel of verification for the user.Legal obligation

Data storage

Data based on legal obligation: Stored for 5 years from the collection.

Data based on performance of the contract: Stored for 5 years from the last interaction.

Usage data

Usage data encompasses information about how users interact with the service, including pages visited, actions performed, and duration of sessions. This data aids in understanding user behaviour and improving the service based on usage patterns.

DataDescriptionLawful basis
Password_logPassword-related actions: password forgotten, changed, incorrect login attempt, and attempts counter reset.Performance of the contract
Email_logContact information updates: email and phone number changes.Performance of the contract
Account statusAccount security actions: temporary freezing, blocking, excessive login attempts, and unblocking.Performance of the contract
Verification statusAccount verification and completion: confirmation of signup, phone verification, and completion of KYC process.Performance of the contract
History of changesAccount profile updates: changes in user type or role, and updates to associated names.Performance of the contract

Data storage

Data based on performance of a contract: Stored for 5 years from the end of service usage.

Сrypto exchange process

Data related to cryptocurrency exchange processes, including transaction history, exchange rates, and wallet information. This data is necessary for executing and monitoring cryptocurrency transactions securely.

DataDescriptionLawful basis
UniqueIDUnique identifier for the transaction.Performance of the contract
AmountAmount of the transaction.Performance of the contract
Creation timeTimestamp indicating when the transaction was created.Performance of the contract
CurrencyCurrency type of the transaction.Performance of the contract
Timestamp dataTimestamp indicating when the transaction expires. Timestamp indicating the last update time of the transaction.Performance of the contract
Transaction NameName associated with the transaction.Performance of the contract
StatusStatus of the checkout.Performance of the contract
Transaction typeType of the transaction.Performance of the contract
User IdIdentifier for the user associated with the transaction.Performance of the contract

Data storage

Data based on performance of a contract: Stored for 5 years from the end of service usage.

Notification and marketing data

Information gathered for managing communication with users, including email preferences, notification settings, and marketing analytics. This data helps in delivering relevant updates and promotions to users.

DataDescriptionLawful basis
LocationTo inform you about useful information, promos and other activitiesConsent
EmailTo send you emails related to the usage of the ServiceLegitimate interest
History of interactionAnalyse and improve serviceLegitimate interest
Data received from 3rd partiesAnalyse and improve serviceLegitimate interest, Consent

Data storage

Data based on legitimate interest: Stored for 5 years from the last interaction, if you do not object.

Data based on consent: Stored for 5 years from collection, if you do not withdraw consent.

Third-party providers

We use 3rd-party providers for our marketing activities. Here you can see the list and read how we involve them.

NameDescription
Google tag managerGoogle service that allows quickly and easily updating measurement codes and related code fragments collectively known as tags on your website or mobile app. Please see details at Privacy Notice.

Report and customer support data

Data collected during customer support interactions, including issue reports, support tickets, and user feedback. This data is vital for resolving user queries and improving the overall service experience.

DataReasons for processingLawful basis
User IDTo identify the userPerformance of a contract
Request dataUnderstand and complete your requestPerformance of a contract

Data storage

Data based on performance of a contract: Stored for 5 years from the end of service usage.

Data received from third parties

We may receive some personal data from third parties. The amount of data collected, the purposes, and the lawful basis for processing is determined by the respective privacy documents of these third parties.

Party nameType of dataReasons for processing
Google analyticsUser behaviour, Contact InformationAnalytics and monitoring
Google Search ConsoleUser behaviour on the site, Demographic InformationImproving user experience
CalendlyInterests and preferences, Communication preferencesPersonal connection with clients
HotjarSession Recordings, Surveys and Polls, Chat historyEvaluating the effectiveness of email marketing
Zoho Live ChatPurchase and transaction dataIntegration with external services, Brand reputation monitoring

Data storage

Legal basisTerm
Legitimate interest5 years from the last interaction, if you do not object.
Сonsent5 years from collection, if you do not withdraw consent.

Data sharing with third parties

We can share your personal data with third parties without any harm to you and in full compliance with applicable law. In addition, we have implemented organisational and technical measures to ensure the security of personal data during data transfer to third-party.

Third partiesDescription
Analytics toolsWe use analytics tools to understand and promote our business.
MessengersWe use messengers to communicate with you in ways that are convenient for you.
Contractors, services providers on ServiceWe cooperate with service providers and contractors to provide you with their services, operate, develop and improve the features and functionality of the Service, fulfil your support requests, complete payment transactions, etс.
Providers of the services our team useWe use CRM systems, messengers, and other services in our organisation to provide you with our services.
State authorities, courts, law enforcement agencies, etcWe may be obliged to transfer some of your data to tax authorities, courts, law enforcement agencies, and other governmental bodies: to comply with a government request, court order, or applicable law; to prevent unlawful use of the Service; to protect against claims of third parties; to help prevent or investigate fraud.

To get a detailed list of the third-party recipients of your personal data, contact us.

To share your data, we rely on the following lawful bases, depending on the case: consent, compliance with the law, and performance of a contract.

Data transfer outside the European Economic Area

The data is stored in Germany by default, but we may need to process your personal data in another country.

If there is no adequate decision by the European Commission regarding the country we transfer data to, we use the adopted Standard Contractual Clauses based on legislation assessments for data protection during transfer and storage.

If there is an adequate decision by the European Commission regarding the country we transfer data to, we can transfer personal data to that third country without any further safeguard being necessary.

You can read more detailed measures to protect your personal data here.

Data protection

We are regularly certified by ISO 27001 Standard. We apply a variety of security measures appropriate to the possible risks.

Organisational measures

  • Staff training
  • Internal policies and instructions
  • Non-disclosure agreements (NDA)
  • Transfer protection

Physical measures

  • Video monitoring
  • Signalling
  • Limited access to premises
  • Round the clock security

Technical measures

  • Two-factor authentication
  • Backups
  • Firewalls
  • Encryption technologies

Data subjects rights

You, as a data subject (individual), have the right to interact with your data directly or through a request to us. This section describes these rights and how you can exercise them depending on your residency.

European Economic Area residents

You, as a data subject, have the right to interact with its data directly or through a request to us. This section describes these rights and how you can exercise them:

RightDescription
Right to accessYou can request an explanation of the processing of your personal data.
Right to rectificationYou can change the data if it is inaccurate or incomplete.
Right to erasureYou can send us a request to delete your personal data from our systems. We will remove them unless otherwise provided by law.
Right to restrict the processingYou may partially or completely prohibit us from processing your personal data.
Right to data portabilityYou can request all the data you provided to us and request to transfer data to another controller.
Right to objectYou may object to the processing of your personal data.
Right to withdraw consentYou can withdraw your consent at any time.
Right to file a complaintIf your request was not satisfied, you could file a complaint to the regulatory body.

To exercise your rights, contact us. If your request was not satisfied, you can submit a complaint to your local Data Protection Authority. You may find it here.

Cookies

We use cookies that are needed for the website’s operation. By using cookies, we receive automatically collected data. You can read more in the Cookie Policy.

If you want to turn off cookies, you can find instructions for managing your browser settings at these links:

  • Internet Explorer
  • Firefox
  • Chrome
  • Opera
  • Microsoft Edge
  • Vivaldi
  • Safari
  • Brave

Privacy Notice updates

This Privacy Notice is developed according to the General Data Protection Regulation, other applicable privacy laws, and best privacy practices.

Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice.

If there are material changes to the Privacy Notice or the Service that affect your data privacy rights, we will notify you by displaying information via the Service and, if necessary, ask for your consent.

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