Privacy Policy

Version 1.0

Version: 1.0
Effective date: <uzupełnij>[DATA WEJŚCIA W ŻYCIE POLITYKI PRYWATNOŚCI]

1. Purpose and scope of the Privacy Policy

  1. This Privacy Policy explains how personal data is processed in connection with the use of the ReputoNode social platform, available at https://reputonode.com.

  2. The Policy applies to:

    • persons visiting public ReputoNode pages without an Account;
    • Users who have an Account;
    • persons contacting the Controller;
    • persons submitting Reports, complaints or appeals;
    • persons whose data has been included in Content published by Users;
    • representatives of companies, organisations and other entities operating an Account.

  3. The Policy fulfils the information obligations arising in particular from Articles 13 and 14 of 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, hereinafter referred to as the “GDPR”.

  4. The Privacy Policy is an informational document. Confirming that you have read it does not constitute general consent to all processing operations described in it.

  5. Where specific processing requires consent, consent is collected separately, voluntarily and in a manner that allows it to be withdrawn later.

  6. Capitalised terms not defined in the Policy have the meanings assigned to them in the ReputoNode Terms of Service.

2. Key information at a glance

  1. The data controller is Damian Urbański. Address details required for publication: [[UZUPEŁNIJ: finalne dane adresowe Administratora / Usługodawcy wymagane do publikacji]]

  2. For matters concerning personal data, contact: privacy@reputonode.com.

    [[KONTROLA PRZED PUBLIKACJĄ: potwierdź aktywność i regularną obsługę adresu privacy@reputonode.com; usuń ten znacznik po weryfikacji.]]

  3. An Account and Profile on ReputoNode are public. Posts, Comments, Replies, topic-specific Reputation, public activity and the list of Accounts followed by a User may also be visible to people who are not logged in.

  4. The email address used to log in, password, private contacts, Drafts and administrative Account data are not displayed publicly.

  5. A precise Location is optional. If a User assigns it to a Profile or Post, it becomes public to the extent selected by the User.

  6. ReputoNode does not currently use Google Analytics 4 or any other optional analytics tools requiring consent. If such solutions are introduced, the Policy will be updated accordingly before they are activated.

  7. Topic-specific Reputation is calculated automatically, but it does not produce legal effects concerning the User or similarly significant effects solely on the basis of automated processing.

  8. After the final deletion of an Account, Account and Profile data is deleted or anonymised. Published Posts, Comments, Replies and related Media may remain public without identifying an active author, in accordance with the Terms of Service.

  9. Data subjects have the rights described in section 25, including the rights of access, rectification, erasure, restriction of processing, objection, data portability and the right to lodge a complaint with the President of the Personal Data Protection Office.

3. Data Controller and contact

  1. The controller of personal data processed in connection with the operation of ReputoNode is:

    Damian Urbański
    [[UZUPEŁNIJ: finalne dane adresowe Administratora / Usługodawcy wymagane do publikacji]]

  2. Contact for matters concerning personal data:

    • email: privacy@reputonode.com;
    • traditional correspondence: to the address indicated in paragraph 1.

  3. General contact with ReputoNode is also available at: contact@reputonode.com.

    [[KONTROLA PRZED PUBLIKACJĄ: potwierdź aktywność i regularną obsługę adresów privacy@reputonode.com i contact@reputonode.com; usuń ten znacznik po weryfikacji.]]

  4. The Controller has not appointed a Data Protection Officer. If a Data Protection Officer is appointed in the future, their contact details will be published in the current version of the Policy.

  5. The Controller may take proportionate measures to verify the identity of a person submitting a request, particularly where there is a risk of disclosing data to an unauthorised person.

4. Roles of the Controller and Users

  1. The Controller determines the purposes and means of processing data necessary for the operation of ReputoNode and, as a rule, acts as a data controller within the meaning of the GDPR.

  2. A User independently decides what Content to publish and what data concerning other persons to include in that Content. As a result, the User may have their own obligations under data protection law, image rights, copyright and personal rights law.

  3. ReputoNode does not act solely as a processor acting on a User's instructions. The Controller also processes Content for its own purposes connected with hosting, security, Moderation, Reports, compliance with legal obligations and protection of claims.

  4. Data concerning legal persons is not personal data; however, information concerning natural persons representing a company, organisation or institution is protected in accordance with this Policy.

5. Sources of data

Data may come from the following sources:

  1. Directly from the data subject, in particular during:

    • Account registration and activation;
    • logging in and recovering access;
    • completing the Profile;
    • publishing Content and Media;
    • providing a Location;
    • giving Reactions and following other Users;
    • contacting the Controller;
    • submitting Reports, complaints or appeals.

  2. Automatically from the device, browser, server or infrastructure, in particular in the form of an IP address, session identifier, date and time of a request, URL, HTTP headers, information about the browser, device and operating system, errors and security events.

  3. From other Users and third parties, where they include a person's data in Content, a Report, complaint, appeal or correspondence.

  4. From publicly available sources, where necessary for Moderation, verification of a Report, protection of rights or resolution of a dispute.

  5. From technical service providers, where they provide the Controller with data necessary to deliver a service, perform diagnostics, maintain security or handle an incident.

6. Categories of data processed

Depending on how ReputoNode is used, the Controller may process the following categories of data:

6.1. Data concerning persons visiting the Portal

  • IP address;
  • date and time of the request;
  • visited URL and request parameters;
  • referring page;
  • HTTP headers;
  • device type, operating system and browser;
  • browser language and selected Portal language;
  • cookie, local storage and session identifiers;
  • information concerning errors, performance and security.

6.2. Registration and Account data

  • technical User identifier;
  • username;
  • email address;
  • cryptographic password hash;
  • activation and email verification status;
  • Account creation date;
  • last login date, if recorded;
  • Account status, blocks and restrictions;
  • declaration of being at least 18 years old;
  • data connected with the Account deletion procedure;
  • history of presentation and acceptance of required legal documents.

The Controller does not store the password in plain text.

6.3. Profile data

  • display name;
  • avatar;
  • bio and its language versions;
  • original language of the bio;
  • voluntarily indicated Location;
  • public or private contact details and links;
  • date joined;
  • activity on the Portal;
  • topic-specific Reputation;
  • list of Accounts followed by the User.

6.4. Content and Media

  • titles and content of Posts;
  • Drafts;
  • Comments and Replies;
  • tags, Categories and Post Types;
  • images, graphics, videos, audio contained in videos and avatars;
  • links and metadata of external websites;
  • original language of Content and stored translations;
  • Location and geographic scope of a publication;
  • dates of creation, update, publication and deletion;
  • data concerning third parties included in Content.

6.5. Location data

  • place-search phrase entered;
  • geographic coordinates provided by the User or device after the relevant permission has been granted;
  • place label;
  • selected level of precision;
  • address elements and technical identifiers of the map provider;
  • source used to select the Location.

6.6. Reaction and Reputation data

  • person giving the Reaction;
  • rated Content and its author;
  • Reaction type;
  • Category of the parent Post;
  • Reputation of the voter at the time the Reaction was given;
  • weight of the Reaction;
  • Post Type and its multiplier;
  • change in Reputation points;
  • score before and after the change;
  • algorithm version;
  • date and time of the event.

The identity of the person giving a specific Reaction is not disclosed publicly.

6.7. Following and feature-usage data

  • identifiers of the following and followed Accounts;
  • date on which following began;
  • filters and search parameters, where processed as part of a request or stored;
  • information about how Portal features are used;
  • selected language and privacy settings.

6.8. Correspondence, Reports and Moderation

  • reporting person's contact details;
  • data concerning the author of the reported Content;
  • description of the matter and reasons;
  • links to Content;
  • attachments, documents and evidence;
  • correspondence;
  • analysis of the matter;
  • Moderation Decision;
  • warnings, blocks and restrictions;
  • appeals and complaints;
  • information provided to authorities where there is a legal basis.

6.9. Data concerning consents and legal documents

  • User identifier;
  • document type;
  • document version number;
  • date and time of acceptance or acknowledgement of having read the document;
  • content and time of granting, refusing or withdrawing optional consent;
  • technical information necessary to demonstrate that the consent mechanism operated correctly.

An IP address is not stored solely as evidence of acceptance of the Terms of Service or presentation of the Privacy Policy, but it may independently appear in technical and security logs.

7. Whether providing data is mandatory

  1. Providing a username, email address and password, accepting the Terms of Service, confirming that the Privacy Policy has been read and making the required declaration of being at least 18 years old are necessary to create and activate an Account.

  2. Confirming the email address is necessary to complete registration and use features requiring an active Account.

  3. Providing a display name, bio, avatar, contacts and precise Location is optional.

  4. Publishing Posts, Comments, Replies, Media and Reactions and creating following relationships is voluntary, but the relevant data is necessary to perform the function selected by the User.

  5. Technical data such as an IP address, session identifier or basic browser information is processed automatically because, without it, it is not possible to provide the online service correctly and securely.

  6. ReputoNode does not currently use Google Analytics 4 or other optional analytics technologies requiring consent. Introducing such a solution requires the relevant legal basis to be established in advance and the information provided to Users to be updated.

8. Public nature of ReputoNode

  1. Every active Account is linked to a public Profile.

  2. The following may be publicly available in particular:

    • username and display name;
    • avatar and bio;
    • Profile Location specified by the User;
    • public contacts and links;
    • Posts, Comments and Replies;
    • Media included in public Content;
    • topic-specific Reputation;
    • User activity;
    • list of Accounts followed by the User.

  3. Public data may be:

    • viewed by people who are not logged in;
    • indexed by Internet search engines;
    • copied, quoted, stored or archived by third parties;
    • accessible via a direct link;
    • visible outside the User's country of residence.

  4. The Controller cannot guarantee the immediate removal of copies of data from a search engine cache, Internet archive or third-party system after Content has been removed from ReputoNode.

  5. The public nature of data does not grant third parties the right to use it in violation of law, copyright, personal rights or the rules set out in the Terms of Service.

  6. The Account email address, password, contacts marked as private, Drafts and administrative Account data are not displayed publicly.

  7. A User should publish only data that they genuinely wish to make available to an unlimited audience.

  8. A User should not include confidential data, access credentials, document numbers, precise financial data or data whose disclosure may endanger the User or another person in public Content.

9. Purposes and legal bases of processing

9.1. Providing public Portal pages

Technical data concerning visitors is processed in order to deliver the page, handle requests, ensure compatibility, perform diagnostics and maintain security.

The legal basis is:

  • Article 6(1)(b) GDPR where processing is necessary for performance of the Agreement or to take action at the User's request;
  • Article 6(1)(f) GDPR, namely the Controller's legitimate interest in operating, securing and properly making the public Portal available.

9.2. Registration, Account and authentication

Data is processed in order to:

  • create and activate an Account;
  • verify an email address;
  • log in and maintain a session;
  • reset and change a password;
  • administer the Account;
  • communicate in connection with the Agreement;
  • enable Account deletion.

The legal basis is Article 6(1)(b) GDPR. For Account protection, prevention of Account takeover and preservation of security evidence, Article 6(1)(f) GDPR may also apply.

9.3. Profile, Content, Media and social features

Data is processed in order to operate a public Profile, publish and display Content, store Drafts, handle Comments and Replies, upload Media, follow Users, search, filter and use other features selected by the User.

The legal basis is Article 6(1)(b) GDPR.

9.4. Location and geocoding

Location data is processed only after the User consciously uses the relevant feature and for the purpose of assigning a place to a Profile or Post, searching for a place or displaying a map.

The legal basis is Article 6(1)(b) GDPR. If the browser or operating system requires permission to access the device's location, that permission is granted through the device mechanism and can later be withdrawn in its settings.

9.5. Reactions and topic-specific Reputation

Data is processed in order to:

  • record an R+ or R−;
  • calculate the effect of a Reaction;
  • determine public topic-specific Reputation;
  • present competence in individual Categories;
  • sort or filter Content in accordance with Portal features;
  • detect manipulation and abuse.

The legal basis is:

  • Article 6(1)(b) GDPR for operation of the core Reputation system;
  • Article 6(1)(f) GDPR for protecting the system against manipulation, fraud and artificial influence on results.

9.6. Automatic translations

Data is processed in order to detect the language, create a translation, store a language version and make it available to subsequent recipients.

The legal basis is Article 6(1)(b) GDPR. For error diagnostics and optimisation of the process, Article 6(1)(f) GDPR may also apply.

9.7. Moderation, Reports and appeals

Data is processed in order to:

  • receive and review Reports of Illegal Content;
  • fulfil obligations arising under the Digital Services Act (DSA);
  • enforce the Terms of Service and Community Standards;
  • protect the rights, safety and reputation of persons;
  • prevent spam, fraud, impersonation and abuse;
  • make and justify Moderation Decisions;
  • review appeals;
  • cooperate with authorised public authorities.

The legal basis is:

  • Article 6(1)(c) GDPR in connection with the Controller's legal obligations;
  • Article 6(1)(f) GDPR, namely the legitimate interest in protecting the Portal, Users, third parties and the Controller's own rights;
  • Article 6(1)(b) GDPR where the action forms part of performance of the Agreement.

9.8. Complaints, contact and handling requests

Data is processed in order to conduct correspondence, examine complaints, provide assistance, handle data-related requests and resolve disputes.

The legal basis is, as applicable:

  • Article 6(1)(b) GDPR;
  • Article 6(1)(c) GDPR;
  • Article 6(1)(f) GDPR, in particular for documenting a matter and protecting against claims.

9.9. Security, logs and prevention of abuse

Technical data is processed in order to:

  • maintain the security of the Portal and Accounts;
  • detect errors, intrusions, spam, bots and unusual activity;
  • limit the number of requests;
  • preserve evidence of incidents;
  • create and restore backups;
  • ensure continuity of operation.

The legal basis is Article 6(1)(f) GDPR and, where required by law, also Article 6(1)(c) GDPR.

9.10. Demonstrating acceptance of documents and compliance with legal obligations

Data concerning document versions and the time of their acceptance is processed in order to demonstrate the conclusion and content of the Agreement, fulfil information obligations, resolve disputes and protect claims.

The legal basis is Article 6(1)(b), (c) and (f) GDPR, depending on the specific purpose.

9.11. Account-related messages

The Controller may send messages necessary for registration, activation, password reset, security, Moderation, Account deletion, changes to the Agreement and operation of the Portal.

The legal basis is Article 6(1)(b) or (c) GDPR and, for security matters, also Article 6(1)(f) GDPR.

The welcome email is informational and connected with Account administration. It is not a newsletter.

9.12. Optional analytics

ReputoNode does not currently use Google Analytics 4 or other optional analytics tools requiring consent. Technical data may be processed only to the extent necessary for the operation, diagnostics and security of the Portal on the bases described in other parts of this Policy.

If optional analytics requiring consent are introduced in the future, they will be activated only after the required legal basis, consent mechanism and an update to this Policy have been provided.

9.13. Establishment, exercise and defence of claims

Data may be processed in order to establish, exercise or defend claims, conduct proceedings and demonstrate the course of events.

The legal basis is Article 6(1)(f) GDPR and, where appropriate, also Article 9(2)(f) GDPR.

9.14. Compliance with obligations towards authorities

Data may be disclosed and processed in order to comply with a legally binding request from a court, law enforcement authority, supervisory authority or another authorised body.

The legal basis is Article 6(1)(c) GDPR.

10. Registration, activation and Account security

  1. During registration, the Controller processes the username, email address, password hash, information confirming that the person is at least 18 years old and information concerning required legal documents.

  2. The email address is used for Account activation, logging in, password reset, security information and other messages necessary for performance of the Agreement.

  3. The activation message contains a time-limited link. The link is valid for 24 hours from generation. The verification token is cryptographically signed and is verified on the ReputoNode side when the Account is activated.

  4. The password-reset link is valid for 30 minutes from generation and may be used only once. The ReputoNode database stores only a cryptographic hash of the password-reset token, not the token's plain value.

  5. The Controller does not ask Users to send their full password by email.

  6. If Account takeover is suspected, the Controller may temporarily block a session or Account, request additional verification or require a password reset.

  7. Data concerning incomplete registration and tokens is retained for the periods specified in section 21.

11. Profile, Content and Media

  1. Information voluntarily placed in a public Profile is available to an unlimited audience.

  2. The User decides which supported contacts are marked as public and which as private.

  3. Private contacts are visible to the Account owner and may be accessible to the Controller only to the extent necessary for service provision, security, Moderation or compliance with legal obligations.

  4. Drafts are not public. They are available to the Account owner and to the Controller only to the extent technically necessary.

  5. The Controller may technically process Media, including in particular changing the format, size, resolution, codec, bitrate, file name and compression and creating thumbnails.

  6. The Portal does not guarantee automatic removal of all metadata from every uploaded file. The Controller limits unnecessary metadata to the extent implemented for the relevant format, and the User should independently check a file before uploading it.

  7. Media may contain personal data, an image, voice, the place where a photo was taken and other information concerning the User or a third party.

  8. A User should have an appropriate legal basis for publishing data and materials concerning other persons.

12. Location, geocoding and maps

  1. The default designation of a Profile and Post is global scope. Providing a more detailed Location is optional.

  2. The “Here and now” feature or a similar feature uses the device's location only after the User activates it and grants permission in the browser or operating system.

  3. ReputoNode does not track the device's Location in the background and does not create a history of the User's movements.

  4. The following may be sent to the geocoding provider:

    • the place-search phrase entered;
    • latitude and longitude;
    • preferred response language;
    • technical IP address of the ReputoNode server.

  5. ReputoNode uses the public Nominatim service available at nominatim.openstreetmap.org for place search and reverse geocoding.

  6. When using public Nominatim, the User should not enter personal data or confidential information into the search field. The public service may record queries and technical data in accordance with its own privacy policy.

  7. After a place is selected, ReputoNode stores only the data needed to present and filter the Location, in particular the label, coordinates, selected scope and necessary technical place identifiers.

  8. If a User assigns a Location to a public Profile or Post, the selected information becomes public.

  9. When displaying a map, the browser connects directly to the tile.openstreetmap.org tile server. The tile provider may therefore receive technical connection data, in particular the IP address, browser headers and information about the requested map area.

  10. The map interface uses Leaflet 1.9.4 served locally from ReputoNode resources. Loading the Leaflet library itself does not require the browser to connect to an external library CDN.

13. Automatic language detection and translations

  1. The language of Content may be detected locally using a language-detection library. Language detection itself does not require Content to be transferred to an external provider.

  2. If a translation into the selected language is not available, the text may be sent to the DeepL API service provided by DeepL SE in Germany. The plan used and data-processing terms: <uzupełnij>[PLAN DEEPL I WARUNKI POWIERZENIA DANYCH].

  3. The following may be transferred in particular:

    • Post title;
    • text blocks of a Post;
    • bio;
    • Comments and Replies;
    • source and target language.

  4. Tags, text contained within images and videos, and content from external websites are not automatically translated by this mechanism.

  5. The translation result is stored in the ReputoNode database and may be displayed again without sending the original Content to the provider again.

  6. The Controller selects a plan and configuration that enable lawful processing of Content containing personal data and that are covered by appropriate data-processing terms and rules concerning deletion or limited retention of Content by the provider.

  7. If translation is performed by a local model operated by the Controller, the Content is not transferred to an external provider for that reason.

  8. Content is not used by the Controller to train publicly available language models. An external provider may process Content only in accordance with the selected product, agreement and its own privacy policy.

  9. Automatic translation may contain errors. In the event of a discrepancy, the original Content takes precedence.

14. Reactions, Reputation and profiling

  1. Topic-specific Reputation is an automated assessment of a User's activity in specified Categories.

  2. When calculating the effect of a Reaction, the system may take into account in particular:

    • R+ or R−;
    • Category of the parent Post;
    • Post Type;
    • Reputation of the voter at the time the vote was cast;
    • weight of the vote;
    • algorithm version;
    • corrections connected with an error, Moderation or abuse.

  3. Internal Reputation points cannot fall below zero. The public score is presented on a scale from 0.00 to 10.00 using a logarithmic transformation or another method specified in the current algorithm.

  4. The topic-specific Reputation score is displayed publicly. Raw points, the number of R+ and R− reactions and the identity of the person giving a specific Reaction are not disclosed publicly.

  5. Reputation may affect how Content is sorted, filtered and presented, the weight of subsequent Reactions and the indication of the User's top Category.

  6. Reputation does not constitute formal confirmation of qualifications, education, a professional licence or the truthfulness of Content.

  7. Processing described in this section may constitute profiling within the meaning of the GDPR because it is used to automatically evaluate selected aspects of a User's activity.

  8. ReputoNode does not currently make decisions concerning a User based solely on automated processing that produce legal effects or similarly significantly affect the User within the meaning of Article 22 GDPR.

  9. A User may report a suspected error, manipulation or incorrect assignment of a Reaction and request human review of the result.

15. Following, feed, search and personalisation

  1. The list of Accounts followed by a particular User is public. The list of persons following that Profile is not public.

  2. Following relationships are used to filter Content and may be used by feed features described in the Terms of Service.

  3. The search engine may process entered phrases, Categories, tags, dates, Locations, User names and other filters in order to return results.

  4. Search parameters may appear in technical logs. They are not used to create an advertising profile without a separate legal basis.

  5. ReputoNode does not currently use browsing history for individualised advertising. Introducing an advanced behavioural recommendation system would require the Policy to be updated in advance and, where required, appropriate consent to be obtained.

16. Reports, Moderation, complaints and appeals

  1. To the extent required for the relevant matter, the Report form collects the reporting person's contact details, identification of the Content, URL, description of the violation, reasons, evidence and required declarations.

  2. A Report may be submitted by a person who is not logged in.

  3. If the reporting person provides electronic contact details, the Controller sends confirmation of receipt and information about the decision where required by law, and in other cases may provide such information where justified by the circumstances of the matter.

  4. The reporting person's data is not normally disclosed to the author of the reported Content unless disclosure is required by law or necessary in proceedings.

  5. The author of the Content may receive information about the allegations and the basis of the Moderation Decision without unnecessary disclosure of the reporting person's data.

  6. Data may be used to detect repeated violations, false Reports, circumvention of blocks and manipulation of Reputation.

  7. Reports and Moderation Decisions are stored in the ReputoNode database. If handling the matter involves email correspondence, messages may additionally be stored by the email service provider in use.

  8. Access to this data is limited to the Controller and persons expressly authorised and bound by confidentiality.

17. Links, metadata previews and embedded materials

  1. If a User provides a URL in order to create a link preview, ReputoNode may connect to the indicated website and retrieve public metadata such as the title, description, image and domain name.

  2. In such a case, the operator of the destination website receives technical connection data concerning the ReputoNode server, in particular the server IP address, request time and requested URL. It does not automatically receive the User's IP address for this reason.

  3. If external material such as a video, player, map or another embedded element is displayed in a Post, the recipient's browser may connect directly to its provider. The provider may then receive the IP address, browser headers, cookie identifiers and information about the page being viewed.

  4. External materials requiring optional cookies or similar technologies are loaded only after an action by the recipient or the granting of appropriate consent where consent is required.

  5. Providers of external materials are identified in the interface, cookie information or the current list of data recipients.

18. Cookies and similar technologies

18.1. Necessary technologies

ReputoNode uses the technical Flask session cookie named session. The cookie is used in particular to maintain login, store session data and link CSRF protection to the current session. In the standard configuration used by the Portal, the cookie is a session cookie and expires when the browser session ends.

ReputoNode currently does not create its own entries in localStorage, sessionStorage or IndexedDB. The selected language is determined by the URL and does not require a separate language cookie.

Some external features may use their own technical technologies. In particular, Cloudflare Turnstile is loaded on the registration page and may process technical data or mechanisms in accordance with Cloudflare's rules; this service is described in section 19.

Strictly necessary technologies do not require consent where they are necessary to carry out a transmission or provide a service expressly requested by the user of the terminal device.

18.2. No optional analytics in version 1.0

  1. ReputoNode does not currently use Google Analytics 4 or any other optional analytics or advertising tools requiring the User's consent.

  2. The Portal does not currently use a CMP or Consent Mode v2 because it does not activate analytics or advertising tools for which such a mechanism would be required.

  3. If optional analytics, advertising or similar technologies are introduced in the future, information about their providers, purpose, legal basis, retention period and the method of granting and withdrawing consent will be added to the Policy before those technologies are activated.

19. CAPTCHA and bot protection

  1. The ReputoNode registration form is protected using Cloudflare Turnstile, a solution provided by Cloudflare, Inc. to distinguish user traffic from automated traffic and reduce abuse.

  2. When Turnstile operates, the browser connects to Cloudflare infrastructure, and on the ReputoNode server side the token received from the form is verified using Cloudflare's Siteverify service.

  3. In connection with Turnstile, Cloudflare may process technical signals needed to assess whether a request comes from a human or automated system, including information about the IP address, browser, system, device and the course of the challenge. Turnstile is not used to send Cloudflare the contents of ReputoNode form fields.

  4. Detailed information on data processing by Turnstile is available in Cloudflare's Turnstile Privacy Addendum: https://www.cloudflare.com/turnstile-privacy-policy/.

20. Data recipients

Data may be disclosed to the following categories of recipients:

  1. An unlimited audience on the Internet – with respect to data consciously published in a public Profile and Content.

  2. Hosting, server, database and file-storage providers: <uzupełnij>[DOSTAWCA HOSTINGU I LOKALIZACJA INFRASTRUKTURY].

  3. Email service providers: <uzupełnij>[DOSTAWCA POCZTY ELEKTRONICZNEJ].

  4. Translation providers: DeepL SE in Germany; <uzupełnij>[PLAN DEEPL I WARUNKI POWIERZENIA DANYCH].

  5. Geocoding, map and tile providers: the public Nominatim service (nominatim.openstreetmap.org) and the OpenStreetMap tile server (tile.openstreetmap.org).

  6. Registration bot-protection provider: Cloudflare, Inc. – Cloudflare Turnstile.

  7. Other security infrastructure, CDN, WAF or error-monitoring providers: [[UZUPEŁNIJ: finalna lista dodatkowych dostawców wykorzystywanych produkcyjnie, jeżeli występują]].

  8. Providers of embedded external materials, where the recipient chooses to activate them.

  9. Persons providing technical, legal, accounting or organisational assistance, where access to data is necessary and appropriately secured.

  10. Courts, law enforcement authorities, supervisory authorities and other authorised bodies, where disclosure has a legal basis.

  11. A purchaser or legal successor of ReputoNode, if the business is lawfully transferred and the required information obligations are fulfilled.

  12. Entities processing data on behalf of the Controller act under an appropriate agreement and only within the scope of the instructions given, unless the law requires them to act otherwise.

  13. Some providers may act as independent data controllers to a certain extent, especially where they independently determine the purposes and means of processing technical data or data connected with their own service.

  14. The Controller does not sell Users' personal data.

21. Retention periods

Data is retained no longer than necessary for the purposes for which it was collected, taking into account legal obligations, the integrity of public discussions and the protection of claims.

21.1. Account and Profile

  • active Account and Profile data – for the duration of the Agreement;
  • data of an Account awaiting deletion – for the 30-day waiting period;
  • after final deletion – in accordance with the anonymisation rules described in section 22.

21.2. Incomplete registration and tokens

  • activation link – until use or expiry, for no more than 24 hours from generation; the verification token is not stored in a separate table as an active token;
  • password-reset token – until use or expiry, for no more than 30 minutes from generation; only its cryptographic hash is stored in the database, not the token's plain value; after expiry, use or revocation, the technical token record becomes eligible for deletion and is removed by a periodic maintenance task;
  • technical record of incomplete registration – for 7 days from Account creation; after that period, an unverified Account showing no user activity is deleted together with its associated Profile and document-acceptance records.

A correctly activated Account is not deleted solely because of inactivity.

21.3. Content

  • Draft – until publication, manual deletion or final Account deletion;
  • published Post – until deletion by the author, Moderation or closure of the Portal, subject to retention of the technical discussion page;
  • Comment and Reply – until deletion following Moderation, exercise of a right, a justified request or closure of the Portal;
  • after Account deletion, public Content may remain without identifying an active author.

21.4. Media

  • temporary file in temp_uploads – normally for up to 24 hours; a periodic maintenance task removes older temporary files;
  • Medium of a published Post – for as long as the Post is stored publicly;
  • Medium of a deleted Post – after the deletion of the Post has been successfully recorded, the Portal attempts to delete the local file if it is not used by other Content; the file may remain longer where it is shared, a technical error occurs or there is a separate retention basis, in particular related to Moderation, security or a legal obligation;
  • replaced or deleted avatar – until the file-deletion process is completed.

21.5. Reactions and Reputation

  • Reaction and Reputation-event data – for the period necessary to preserve system integrity, detect manipulation and protect claims;
  • after Account deletion, Reactions previously given by the User may remain under a technical identifier disconnected from the public Profile;
  • the public Reputation summary of a deleted Account is removed.

21.6. Acceptance of documents and consents

  • evidence of acceptance of documents – for the duration of the Agreement and for <uzupełnij>[OKRES RETENCJI DOWODÓW AKCEPTACJI PO ZAKOŃCZENIU UMOWY];
  • evidence of optional consents – for the duration of the consent and for the period necessary to demonstrate the lawfulness of processing and protect claims.

21.7. Reports, Moderation and correspondence

  • Reports, Moderation Decisions and administrative audit entries linked exclusively to the particular matter, including the snapshot of the reported Content, reasoning, basis of the decision and notification statuses – as a rule for 6 months from the date of the final Moderation Decision;
  • if, before that period expires, an appeal, complaint, dispute, proceeding, legally binding authority request is pending, or retention is necessary to establish, pursue or defend claims, retention may be extended for the duration of that matter and, as a rule, for 30 days after it ends, unless there is a basis for longer storage;
  • complaints – <uzupełnij>[OKRES RETENCJI REKLAMACJI];
  • other correspondence not covered by the above retention of a moderation matter – <uzupełnij>[OKRES RETENCJI KORESPONDENCJI];
  • data concerning claims – until the applicable limitation period expires or proceedings are finally concluded.

21.8. Logs and security

  • application, server and security logs – <uzupełnij>[OKRES RETENCJI LOGÓW TECHNICZNYCH I BEZPIECZEŃSTWA];
  • documentation of personal-data breaches – <uzupełnij>[OKRES RETENCJI REJESTRU NARUSZEŃ].

21.9. Backups

  • backups – in accordance with a rotation cycle of <uzupełnij>[OKRES ROTACJI KOPII ZAPASOWYCH];
  • data deleted from the production system may remain in a backup until the backup is overwritten or deleted;
  • data from a backup is not restored to ordinary use; if it is restored as a result of a failure, the deletion or anonymisation process is repeated.

21.10. Data stored by external providers

  • ReputoNode does not currently transfer data to Google Analytics 4 because the service is not used;
  • data processed by other external providers is retained in accordance with the configuration of the relevant service, the applicable agreement and the provider's rules, taking into account requirements arising under law.

21.11. Anonymous data

Permanently anonymised data that can no longer be linked to a natural person is not personal data and may be retained for longer periods, including for statistical, security and Portal-development purposes.

22. Account deletion and anonymisation

  1. A User may initiate the Account deletion procedure. The User may cancel the request for 30 days.

  2. During the waiting period, the Account continues to exist technically, but its active features are restricted in accordance with the Terms of Service. The User may still perform clean-up operations that reduce the amount of data or relationships: delete their own Drafts and previously published Posts and unfollow other Accounts.

  3. After the waiting period has expired and final deletion is performed, the following in particular is deleted or anonymised:

    • email address;
    • cryptographic password hash;
    • verification status;
    • Profile data;
    • bio and bio translations;
    • public and private contacts;
    • avatar;
    • Profile Location;
    • following relationships;
    • public Reputation summary;
    • Drafts and Media used only in Drafts.

  4. The original username is deleted or replaced with an anonymous identifier in a manner that allows it to become available for reuse, unless there is a justified basis for temporarily reserving it, for example in connection with Moderation, security or protection against impersonation.

  5. A technical identifier may remain in the system where necessary to preserve data integrity, Reactions, Moderation history, legal evidence and anonymous association of remaining Content.

  6. Posts, Comments and Replies that the User did not delete before finalisation may remain public without being linked to an active Account.

  7. Media belonging to a remaining Post and its stored translations may also remain.

  8. Reactions previously given by the deleted Account may continue to affect the Reputation of other Users. The identity of the former User is not disclosed publicly.

  9. Data may be retained after Account deletion where necessary to:

    • comply with a legal obligation;
    • comply with a request from an authorised authority;
    • establish, exercise or defend claims;
    • prevent fraud or circumvention of blocks;
    • preserve the integrity of public discussions and the Reputation system;
    • document a serious violation.

  10. After final deletion, the Account cannot be restored.

  11. A person whose Account has been deleted may request deletion of specific remaining Content. The Controller may request credible confirmation of authorship or authority to act.

23. Data concerning third parties posted by Users

  1. Users may include information concerning other persons in Content, including their name, image, voice, statement, Location, contact details or correspondence.

  2. Such data may originate from the User publishing the Content, the person submitting a Report or another source identified in the particular matter.

  3. The Controller processes third-party data for the purposes of hosting public Content, displaying it, Moderation, responding to requests, complying with legal obligations and protecting claims.

  4. The legal basis may be Article 6(1)(f) GDPR, namely the legitimate interest in operating a Portal enabling freedom of expression and the exchange of information, protecting the rights of persons and performing Moderation. In appropriate cases, Article 6(1)(c) GDPR may also apply.

  5. Following an individual assessment, the Controller may not provide information directly to every person appearing in Content where doing so proves impossible or would involve disproportionate effort. In such a case, the Controller applies appropriate safeguards, in particular by making this Policy publicly available, in accordance with Article 14(5) GDPR.

  6. A person whose data has been published may contact the Controller at privacy@reputonode.com or submit a Report concerning the Content.

  7. The Controller considers the request taking into account the right to data protection, freedom of expression and information, the author's rights, the rights of other persons, legal obligations and the need to protect claims.

  8. A User publishing a third party's data should have an appropriate legal basis and provide that person with the required information where such an obligation applies to the User.

24. Special categories of data and data concerning violations of law

  1. ReputoNode does not normally require Users to provide data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data used for identification, health data or data concerning sex life or sexual orientation.

  2. A User should not publish such data concerning themselves or other persons unless this is necessary and the User has an appropriate legal basis.

  3. If special-category data appears in Content, it may be processed only where one of the conditions in Article 9(2) GDPR is met, in particular where the data has manifestly been made public by the data subject or processing is necessary for the establishment, exercise or defence of legal claims.

  4. The mere fact that a User has published a third party's data does not mean that the third party has manifestly made it public themselves.

  5. Reports and Content may contain information concerning suspected criminal offences, convictions or violations of law. The Controller processes such information only to the extent necessary for Moderation, security, compliance with legal obligations, cooperation with authorities and protection of claims, in accordance with Article 10 GDPR and applicable law.

  6. The Controller may remove or restrict Content containing particularly protected data where continued public availability is unlawful or creates a disproportionate risk to the person concerned.

25. Rights of data subjects

To the extent provided for by the GDPR, a data subject has the following rights:

25.1. Right of access

The right to obtain information on whether data is being processed, access to the data and a copy of it.

25.2. Right to rectification

The right to correct inaccurate data and complete incomplete data. Some Profile data can be corrected directly by the User.

25.3. Right to erasure

The right to request erasure of data where one of the conditions under the GDPR applies. This right is not absolute. Data may remain where it is needed, among other things, to comply with a legal obligation, exercise freedom of expression and information, establish, exercise or defend claims or on another basis provided for by law.

Deleting an Account and deleting all public Content are separate actions described in the Terms of Service and section 22 of this Policy.

25.4. Right to restriction of processing

The right to request restriction of processing in the cases specified in Article 18 GDPR.

25.5. Right to object

The right to object, on grounds relating to a particular situation, to processing based on Article 6(1)(f) GDPR. The Controller may continue processing where it demonstrates compelling legitimate grounds that override the interests, rights and freedoms of the person concerned, or grounds for the establishment, exercise or defence of legal claims.

25.6. Right to data portability

The right to receive data provided to the Controller in a structured, commonly used format and, where technically feasible, to have that data transmitted to another controller where processing is carried out by automated means on the basis of consent or an Agreement.

The absence of an automatic export function in Account settings does not limit this right.

25.7. Right to withdraw consent

Where processing is based on consent, consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

25.8. Rights concerning automated decisions

If the Controller introduces decisions in the future that meet the conditions of Article 22 GDPR, the person concerned will receive the relevant information and will be able to exercise the rights required by that provision, including the right to obtain human intervention, express their point of view and challenge the decision.

25.9. Right to lodge a complaint

A person may lodge a complaint with the President of the Personal Data Protection Office if they believe their data is being processed unlawfully.

25.10. Exercising rights

  1. Requests may be sent to privacy@reputonode.com or to the Controller's correspondence address.

  2. A request should make it possible to determine what it concerns and enable secure verification of the person's identity.

  3. The Controller responds without undue delay, as a rule within one month. This period may be extended by a further two months due to the complexity or number of requests, and the person will be informed of the extension within the first month.

  4. Exercising rights is generally free of charge. In the case of manifestly unfounded or excessive requests, the Controller may charge a reasonable fee or refuse to act, in accordance with the GDPR.

  5. The right of access and to obtain a copy must not adversely affect the rights and freedoms of others.

26. Data security

  1. The Controller applies technical and organisational measures appropriate to the nature of the Portal, the scope of the data, the scale of the activity and identified risks.

  2. Measures may include in particular:

    • HTTPS connection encryption;
    • storing passwords as cryptographic hashes;
    • restricting administrative access;
    • session control and cookie safeguards;
    • protection against CSRF, brute force, spam and automated requests;
    • logging security events;
    • software updates;
    • backups and restoration tests;
    • minimisation of data transferred to providers;
    • deletion and anonymisation procedures;
    • confidentiality obligations for authorised persons.

  3. Details of safeguards whose disclosure could reduce security are not published.

  4. No online system can completely eliminate risk. The Controller regularly assesses safeguards and responds to identified threats.

  5. In the event of a personal-data breach, the Controller documents the incident, assesses the risk and – where required – notifies the President of the Personal Data Protection Office without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach.

  6. If the breach is likely to result in a high risk to the rights or freedoms of individuals, the Controller informs the data subjects unless an exception provided for in the GDPR applies.

27. Transfers of data outside the European Economic Area

  1. The Controller prefers providers processing data in the European Economic Area, but some services may involve a transfer of data outside the EEA or remote access to data from outside the EEA.

  2. Before transferring data outside the EEA, the Controller establishes an appropriate basis, in particular:

    • a European Commission adequacy decision;
    • valid certification under the Data Privacy Framework, where applicable;
    • European Commission Standard Contractual Clauses;
    • another safeguard permitted under the GDPR.

  3. The Controller may apply additional measures, in particular encryption, data minimisation, limitations on provider functionality and a transfer-impact assessment.

  4. Current transfers or the possibility of transfer may concern in particular:

    • DeepL and its subprocessors;
    • Cloudflare Turnstile;
    • hosting, email, CDN, WAF or monitoring;
    • external materials activated by the recipient.

  5. Details of transfers: <uzupełnij>[LISTA TRANSFERÓW POZA EOG I ICH PODSTAWY].

  6. Information on the safeguards used, or a copy of them, may be obtained by contacting the Controller, subject to protection of confidential information and security.

28. Minors

  1. Only a person who is at least 18 years old may create an Account.

  2. ReputoNode does not require a date of birth, but during registration it requires a declaration that the person is at least 18 years old.

  3. Public Portal pages may technically be accessible to minors, but the Account service is not directed to them.

  4. If there is a reasonable suspicion that an Account is being operated by a person under the age of 18, the Controller may restrict the Account and request proportionate confirmation of age.

  5. A document or information provided solely to confirm age is processed to the minimum extent necessary and deleted after verification has been completed, unless further retention is required by law or necessary to protect claims.

  6. If it is confirmed that an Account is operated by a minor, the Controller may delete or anonymise the Account in accordance with the Terms of Service and the interests of that person.

29. Changes to the Privacy Policy

  1. The Privacy Policy is versioned separately from the Terms of Service.

  2. The Policy may be changed in particular because of:

    • changes in law;
    • changes to Portal features;
    • changes of providers;
    • changes in the scope or purpose of processing;
    • changes in retention periods;
    • security improvements;
    • removal of ambiguity or an error.

  3. The current version is publicly available in ReputoNode.

  4. If a change is material, the Controller informs Users in a manner appropriate to the nature of the change, for example by a notice in the Portal or an email where such a channel is required or justified.

  5. A new version of the Policy does not automatically mean that new consent has been given. Where specific processing requires consent, consent is collected separately.

  6. Acknowledgement of having read a new version may be required to document that the information was provided, but it is not equivalent to general consent to processing.

30. Language versions

  1. The Policy may be made available in different language versions.

  2. The Polish version is the source version.

  3. Translations should preserve the same legal and informational meaning.

  4. In the event of discrepancies, the Polish version forms the basis for interpretation, taking into account the mandatory rights of the data subject.

31. Final provisions

  1. Matters not regulated by the Policy are governed by the GDPR, the Polish Act of 10 May 2018 on the Protection of Personal Data, the Polish Act of 12 July 2024 – Electronic Communications Law, the Digital Services Act and other applicable provisions.

  2. The Terms of Service set out the rules for using ReputoNode, publishing Content, Moderation, Account deletion and User liability.

  3. The Community Standards elaborate on the rules concerning prohibited Content and behaviour.

  4. Questions concerning the Policy and data processing may be sent to: privacy@reputonode.com.

Privacy Policy version: 1.0
Effective date: <uzupełnij>[DATA WEJŚCIA W ŻYCIE POLITYKI PRYWATNOŚCI]