Privacy Policy

Last updated: March 8, 2026

1. Data Controller

The controller of your personal data is Foundation for the Promotion of Research on Smell and AI with its registered office at Jasionna, 99-417 Bolimow, Poland, KRS: 0001201057, NIP: 8361891220, REGON: 543082380.

For matters related to data protection, you can contact us at: [email protected]

2. What Data We Collect

2.1. Data Provided by the User

Email address - during account registration
Name (optional) - during account registration
Conversation content - messages exchanged with the REFLECTOR Chatbot

2.2. Automatically Collected Data

IP address
Browser and device information
Cookies
Date and time of visits

2.3. Payment Data

Payments are handled by the external operator Stripe. We do not store credit card numbers. We only store the Stripe customer identifier necessary for subscription management.

3. Purposes and Legal Bases for Processing

Purpose	Legal Basis (GDPR)
Providing REFLECTOR service	Art. 6(1)(b) - contract performance
Payment processing	Art. 6(1)(b) - contract performance
Newsletter delivery	Art. 6(1)(a) - consent
Handling complaints	Art. 6(1)(b) - contract performance
Tax and accounting purposes	Art. 6(1)(c) - legal obligation
Service improvement	Art. 6(1)(f) - legitimate interest

4. Data Recipients

Your data may be shared with the following categories of recipients:

Stripe, Inc. - payment processing (USA, SCC)
GetResponse S.A. - newsletter management (Poland)
Abacus.AI - AI infrastructure provider (USA, SCC)
Hosting provider - data storage on servers

Data transfers outside the EEA are based on Standard Contractual Clauses (SCC) approved by the European Commission.

5. Data Retention Period

Account data - until account deletion or 3 years from last activity
Conversation history - until account deletion
Billing data - 5 years from end of tax year (legal obligation)
Newsletter data - until unsubscription

6. Your Rights

Under GDPR, you have the following rights:

Right of access - you can obtain information about processed data
Right to rectification - you can correct inaccurate data
Right to erasure (right to be forgotten)
Right to restriction of processing
Right to data portability - you can receive data in a machine-readable format
Right to object
Right to withdraw consent - at any time
Right to lodge a complaint - you can file a complaint with the Polish Data Protection Authority (UODO)

To exercise these rights, contact us at: [email protected]

7. Cookies

7.1. What Are Cookies

Cookies are small text files stored on your device when using the service.

7.2. Types of Cookies Used

Type	Purpose	Duration
Essential	Service operation, login session	7 days
Functional	Language preferences	1 year
Analytical	Visit statistics	Up to 2 years

7.3. Managing Cookies

You can manage cookies in your browser settings.

8. Data Security

We implement appropriate technical and organizational measures to protect your data:

Connection encryption (SSL/TLS)
Password hashing
Regular backups
Data access control

9. Processing of Conversation Content

Content entered in the REFLECTOR Chatbot:

Is processed for the purpose of providing the service
May be used in anonymized form to improve the AI model
Is not shared with third parties in identifiable form
Is stored on secure servers

Recommendation: Do not enter sensitive data into the Chatbot (medical data, document numbers, etc.).

10. Changes to Privacy Policy

We reserve the right to update this Privacy Policy. We will inform you of significant changes by email or through a notice on the service.

11. Contact

If you have questions about data protection, contact us:

Foundation for the Promotion of Research on Smell and AI
Jasionna, 99-417 Bolimow, Poland
Email: [email protected]
Website: fundacja-wechai.pl