PRIVACY POLICY – STRATEGIOAPP

(effective from the date of publication)

1. Personal data controller

The controller of personal data is:

Alfaplus Sp. z o.o.
Al. Nad Jasieniem 33a
93-557 Łódź, Poland
VAT EU ID: PL7292750093
KRS: 0001039399
E-mail: contact@strategioapp.com

The Controller is the owner of the StrategioApp website (hereinafter: the “Service”).

2. Scope of processed data

Depending on how the Service is used, the Controller may process the following data:

a) Technical and statistical data

• IP address,

• device and browser type,

• operating system,

• approximate location (country / city),

• statistical data related to activity within the Service (e.g. clicks, redirects to partners).

b) Data voluntarily provided by the User

• e-mail address,

• data provided via forms (e.g. travel preferences, flight route, travel dates),

• communication language,

• marketing consents.

❗ The Controller does not process payment data, credit card data, or any data required to process payments.

3. Purposes of personal data processing

Personal data is processed for the following purposes:

a) Provision of the Service

• enabling the use of search engines and travel planning tools,

• generating search results and recommendations,

• ensuring security and stability of the Service.

b) Community building and mailing lists

• registering Users within the StrategioApp community,

• sending newsletters,

• sending price alerts, special offers, and promotional information,

• marketing communication related to travel and associated services.

c) Affiliate marketing

• identifying referrals to affiliate partners’ services,

• settlement of affiliate programs.

Personal data is not used for profiling within the meaning of Article 22 GDPR, nor for automated decision-making producing legal effects concerning the User.

Legal basis for processing:

• Article 6(1)(b) GDPR – performance of a service,

• Article 6(1)(f) GDPR – legitimate interest of the Controller (analytics, affiliate marketing),

• Article 6(1)(a) GDPR – User consent (newsletter, marketing communication).

4. Newsletter and marketing communication

The User may voluntarily subscribe to:

• the StrategioApp newsletter,

• price alerts and travel opportunity notifications.

Providing an e-mail address and granting marketing consent is voluntary but necessary to receive such communications.

The User may at any time:

• withdraw consent,

• unsubscribe from the newsletter (unsubscribe link included in every message),

• request deletion of personal data.

5. External partners and affiliation

The Service uses services provided by External Partners, in particular:

• affiliate platforms (e.g. Travelpayouts),

• flight, hotel, and travel service search engines,

• mailing, analytics, and hosting service providers.

After clicking an affiliate link, the User is redirected to the Partner’s service, which acts as an independent data controller and processes personal data in accordance with its own privacy policy.

The Controller is not responsible for the data processing practices of External Partners.

6. Cookies and similar technologies

The Service uses cookies for the purpose of:

• ensuring proper functioning of the Service,

• statistical analysis and quality improvement,

• affiliate and marketing functionalities.

The User may modify cookie settings at any time via their web browser.

7. Data transfers outside the EU

If personal data is transferred outside the European Economic Area (e.g. to technology service providers), such transfers are carried out in accordance with GDPR, in particular based on:

• standard contractual clauses,

• other legally permitted safeguards.

8. User rights

The User has the right to:

• access personal data,

• rectify data,

• erase data,

• restrict processing,

• object to processing,

• withdraw consent at any time,

• lodge a complaint with the President of the Personal Data Protection Office (UODO).

9. Contact

For matters related to personal data protection, the Controller can be contacted at:
📧 contact@strategioapp.com

10. Changes to the Privacy Policy

The Controller reserves the right to amend this Privacy Policy in the event of:

• changes in legal regulations,

• changes in Service functionality,

• development of new services.

The current version of the Privacy Policy is always available within the Service.