PP PackPlan

Privacy Policy

Effective from: 2026-05-29 · Version 1.0

This document describes how personal data is processed in the PackPlan service (pack.sniegula.com) in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and the Polish Act on Provision of Electronic Services. The Polish version at /prywatnosc is the binding version; this English translation is provided for convenience.

1. Data controller

Sławomir Śnieguła, doing business as Sniegula Expeditions, ul. Czarnieckiego 5, 88-400 Żnin, Poland, Polish tax ID (NIP) 5213392848.

Data protection contact: kontakt@sniegula.com.

The Controller has not appointed a Data Protection Officer — the scope of processing does not require one under GDPR Art. 37.

2. What data we process and why

Category Purpose Legal basis (GDPR) Retention
Email, username, password (bcrypt) Account creation and login Art. 6(1)(b) — contract performance Until Account deletion + 30 days backup
Content (packs, items, notes) Providing the planning service Art. 6(1)(b) — contract performance Until Account deletion + 30 days backup
IP address (SHA-256 hashed), user agent Security, abuse detection Art. 6(1)(f) — legitimate interest 90 days
Affiliate clicks (hashed IP + product ID) Conversion statistics, partner reconciliation Art. 6(1)(f) — legitimate interest 24 months (aggregates indefinitely)
Public packs (content + slug) Display under public link Art. 6(1)(a) — consent Until consent withdrawn

3. Cookies

The Service uses only cookies essential for operation (session, CSRF token, language preference). No third-party marketing, advertising or analytics cookies are used (no Google Analytics, no Google Ads, no Facebook Pixel, no Hotjar, etc.).

4. Data recipients

We transfer data to the following categories of recipients:

We do not sell personal data. We do not share it with data brokers.

5. International transfers

Data is processed within the EEA (Hetzner — Germany). Apple and Google process payment data in the United States — this is based on the European Commission's adequacy decision of 10 July 2023 (EU-US Data Privacy Framework) and on Standard Contractual Clauses (SCC).

6. What we do NOT do

7. Your rights

Under GDPR you have:

We respond to all requests within 30 days of receipt; in complex cases this may be extended by an additional 60 days with notice.

8. Security

We apply the following technical and organisational measures: password hashing with bcrypt and per-user salt, transmission only over HTTPS (TLS 1.3, Let's Encrypt certificate), session tokens in HttpOnly cookies with SameSite=Lax, SQLite database with file permissions restricted to the application process, encrypted backups with 30-day retention, security updates of dependencies at least monthly.

9. Children's data

The Service is not directed at children under 16. Persons under 16 may use the Service only with the consent and under the supervision of a legal guardian (GDPR Art. 8). If we discover that an Account belongs to a child without guardian consent, we delete it without delay.

10. Mobile application

PackPlan is also available as a mobile app on Google Play (Android) and the App Store (iOS). It uses the same data as the web version.

The mobile app does not collect: location, contacts, calendar, microphone, camera (unless you manually pick a photo — then only the selected file reaches us), advertising identifiers (Advertising ID).

The app may store a session token in local device storage (Android Keystore / iOS Keychain) to keep you logged in.

In-app payments (where available) are handled by Google Play Billing or Apple App Store. The Operator receives only the active subscription entitlement; card data is processed by Google or Apple under their respective privacy policies.

11. Partner shops

When you click an affiliate link from the Library you are taken to an external shop. The shop's privacy policy applies from that point. The Operator transfers to the shop only the product identifier in the UTM parameter, no User personal data.

12. Changes to this policy

Material changes are announced 14 days in advance by email and in-app notice. The current version is always available at pack.sniegula.com/en/privacy (PL: /prywatnosc).

13. Contact

Privacy questions and data subject requests: kontakt@sniegula.com. We respond within 7 business days (GDPR requests: within 30 days).