Privacy Policy

1. Operator and privacy contact

The operator and controller for the purposes described below is Paweł Gruszka, trading as VESPY PAWEŁ GRUSZKA, registered in CEIDG, ul. Warszawska 40/2A, 40-008 Katowice, Poland, NIP 6342331938, REGON 278021009. DINPanel is a service brand.

Privacy and rights contact: info@dinpanel.com, telephone +48 664 660 230, or the postal address above. This contact is not presented as a formally appointed Data Protection Officer.

2. Our role and customer instructions

For account administration, security, our own sales and legal obligations, support, our own supplier-contact work and any separately lawful marketing or analytics, the operator determines its purposes as controller. A customer's employee or company representative is not automatically the individual party to the service contract.

For client/project content processed to supply the customer's selected functions on documented instructions, DINPanel acts as processor, or as a further processor where the customer itself acts for another controller. Roles follow the actual purpose and relationship; not every supplier, payment or integration provider has the same role. This notice does not authorise unrelated advertising/model training or unknown recipients for customer content.

• The customer decides which data is needed, its lawful basis, required notices, recording authority and recipients. Technical names, labels, comments, drawings and speech can identify people. Do not enter unnecessary personal, special-category or criminal-offence data; an unexpected upload does not establish a lawful exception.
• These customer decisions do not remove DINPanel's own duties. A microphone permission, map confirmation or customer's checkbox is not another person's consent or legal basis.
• For customer-controlled personal data, the separately adopted Data Processing Agreement defines the instructed processing and authorised subprocessors. The customer name, account representative and declared role recorded on adoption identify the parties and authority; the exact version and language are retained as evidence. Privacy acknowledgment alone does not adopt that agreement.

3. Data categories and sources

Data comes from you and authorised users, normal use of the service, customer-supplied client/contractor information, payment or integration responses, correspondence and, for deliberate supplier research, public business sources such as official websites. Public contact details can still be personal data. Where we collect data indirectly for our own purposes, the applicable information duties remain. For our own indirect collection, information is normally due within one month or at first contact/disclosure if earlier, unless a specific exception applies.

• Account and access data: name/contact details, organisation/profile settings, account and session identifiers, authentication/authorisation records, application version, and records of document versions, acknowledgements, declarations and optional choices.
• Project data: designated client name/company/contact/tax/address/location fields; arbitrary technical names, room/floor labels, symbols, notes, comments, geometry and product/settings data; drawings, images and imported files that may contain identifying information.
• Copies and outputs: revisions, differences, snapshots, undo/application history, purchase lists, supplier/contact/order snapshots and attachments, generated documents/invoices, import/export jobs, media and downloaded/shared files.
• Voice and AI data: recordings, raw and edited transcripts, revisions, extracted details, proposals, source quotes, analysis/results, recording/upload language and technical metadata, hashes and separate metering/idempotency references. Pending audio, retry files and analysis/history can also remain on a device.
• Operational and business data: support/claim messages and internal case notes, supplier business contacts, own-sale buyer/subscription/payment/invoice/refund and historical ledger records and provider identifiers; integration settings and access secrets; device/network/security and delivery logs.

4. Purposes and GDPR legal bases

The following purpose-specific basis schedule concerns the operator's controller processing. It does not supply the customer's basis for client content. Only data necessary for the stated purpose is covered; describing an interest does not itself establish the required necessity and balancing assessment.

• Account/service contract and requested pre-contract steps: Article 6(1)(b), where the individual is the contracting party, for sign-in, selected service delivery, administration and necessary service correspondence.
• Company representatives and our own supplier/contact administration: Article 6(1)(f), for the legitimate interest in conducting and documenting relevant business relationships. This is not blanket authority to send marketing to public addresses.
• Security, fraud/abuse prevention, proportionate diagnostics and legal claims: Article 6(1)(f), for protecting accounts/service integrity and establishing, exercising or defending claims, subject to necessity, balancing and objection rights.
• Our applicable tax/accounting obligations and required authority disclosures: Article 6(1)(c), only within the relevant legal obligation. Our own sales records are distinct from invoices or project documents generated for the customer's clients.
• Optional usage analytics and optional marketing email: Article 6(1)(a), within the specific permission requested. Necessary security, billing, service and rights replies are assessed under their own purposes, not optional marketing consent.
• Rights handling and minimum compliance/document evidence: Article 6(1)(c) where necessary for GDPR duties, and Article 6(1)(f) where separately necessary to establish actual contractual decisions or defend claims. Acknowledging Privacy information does not grant generic processing consent.
• Poland's Electronic Communications Law (PKE) imposes additional marketing/device-storage rules: prior channel permission under PKE Article 398 and information/consent under Article 399 where required, with its necessary-transmission/requested-service exceptions. These rules are separate from the GDPR basis for subsequent personal-data processing.

5. Necessary data and optional choices

Providing data required to create/authenticate an account or fulfil a selected contract, invoice or legal obligation is necessary for that function; without it we may be unable to provide it. Optional fields and optional analytics, marketing, recording, AI or map functions can be declined without turning those optional purposes into conditions for basic service.

Marketing and analytics choices are separate from Terms and this notice. Withdraw them through the relevant preference control or info@dinpanel.com. Direct-marketing objections stop that marketing. Necessary service, security, payment and rights correspondence uses its own lawful purpose. Minimum evidence of the choice or suppression is retained only for the purpose and criterion described below.

6. Recordings, transcripts and AI

When you start recording, audio can be held locally for pending/offline work or retry. Deliberate processing can upload audio for transcription, save raw text, produce edited text and derive client/technical/supplier proposals. Releasing an audio file after acknowledgement or transcript acceptance does not erase saved text, revisions, analyses or previously applied changes. The wholesaler workflow has an automatic accept/apply option, enabled by default in the service, so recognised fields can be accepted/applied before manual review. Starting recording/upload and automatic application are separate choices. Check filled fields after automatic processing.

AI functions can send the selected transcript/text, necessary technical context or floor-plan image to configured endpoints for transcription, cleanup, extraction, translation/rephrasing, image editing or analysis. Explicit support composer tools can send the current draft. Supplier research can use hosted web search. Content can contain personal data even when entered in a technical field.

• Capture entry points do not automatically start browser-vendor speech recognition. Older builds/sessions and external browser/vendor copies are not certified erased.
• Supported chat/Responses requests explicitly set store: false. This is not proof of Zero Data Retention, absence of abuse/cache retention, training opt-out, a particular region or valid international safeguards. A configured gateway/base URL may represent a different provider or proxy.
• The configured AI service is the OpenAI API (api.openai.com), for transcription, extraction, text transformation and image processing. OpenAI Ireland Ltd is the EEA contracting entity under its published business DPA. This does not mean that every processing operation stays in Ireland or the EEA. The selected action determines the material sent; the provider and transfer arrangements are described below.
• AI outputs can be inaccurate. Review recognised information and technical proposals before relying on them; do not provide unnecessary recordings or third-party information.

7. Cookies, local storage and offline copies

The service uses authentication/request-protection cookies and browser storage for requested functions, language/theme/preferences, session continuity, offline project caches, queued changes, recordings/retries and local history. localStorage, sessionStorage and IndexedDB are distinct from the browser's HTTP cache. Such stores can contain personal content and are not anonymous.

The Privacy preferences control offers direct refusal and opt-in and remains available to reopen; Profile also exposes analytics choices. Optional technologies remain off until permission. If a choice cannot be saved, this page stays opted out and asks for a retry; persistence after reload cannot be promised when storage fails.

Embedded videos use youtube-nocookie.com (privacy-enhanced mode). This does not make playback anonymous or guarantee that no device storage is used after playback starts. Google controls storage and further processing in its player; opening youtube.com uses that website's own controls and policies. Choosing a tutorial does not enable DINPanel analytics or marketing. This feature does not create a separate viewing history in your DINPanel account.

• Closing the app or losing connectivity does not erase device copies. Supported cleanup runs when the device/app can perform it; downloaded files and permanently disconnected devices need separate action.
• If configured and separately permitted, Google Analytics can receive usage measurements and technical identifiers. Withdrawal disables further optional measurement and removes accessible Google Analytics cookies from this browser. This does not itself erase data already held by Google; contact us for the applicable provider-side rights/removal process. An unconfigured or unconsented optional analytics service must not collect through DINPanel.

8. Optional analytics and independent operational records

With your explicit permission, limited usage events can link named views and actions to an account, event/session/project identifiers, capture time, application version, device category and viewport size. Form values, project content and titles, and raw URLs are excluded. Authorised administrators may inspect this limited history.

Internal journey events are retained for at most 90 days from capture/receipt. The browser queue also has a 90-day maximum and a 5,000-event limit; inactive or disconnected browsers apply expiry when the application can next run. Server retention and withdrawal apply independently of whether you generate further events.

• Withdrawal stops optional collection on the device immediately. Once the authenticated server withdrawal is accepted, prior consent-only usage events for the account are deleted and stale queued events cannot restore them. A new grant starts a new collection period and does not revive the old queue. Independent operational records with a separate lawful basis are not silently reclassified or erased as optional analytics.
• When offline or a request fails, the application keeps a minimal pending withdrawal instruction and retries when it can reconnect; it must show that server confirmation is still pending. Device withdrawal does not certify erasure on an unreachable server, other device or external provider.
• The current account choice and its revision are retained while the account exists to enforce that choice. Superseded analytics-only consent receipts expire 90 days after their decision; the latest choice remains until replacement or account deletion. Account deletion removes the account's analytics events and analytics receipts.
• Independent server observations, such as account-linked project requests, support reliability and service-use analysis on Article 6(1)(f), subject to necessity, balancing and objection. Server-request journey observations share the 90-day maximum; financial, security, contract and project records have the separate purposes below. The internal limit does not define an external provider's retention.

9. Support and correspondence

Support records correspondence you deliberately submit, necessary reply contact and minimum case/account routing information. It does not automatically attach complete profiles, projects, drawings, audio, transcripts or AI results. Technical support starts with an empty workspace rather than a source-project clone. Staff notifications contain case routing and a link.

Authored messages and internal case notes can still contain personal data. Include only what is necessary and never send passwords or payment secrets. Explicit AI composer actions are separate processing choices. Previously delivered mail and older copies are handled through the applicable retention and rights process; hiding a record does not constitute physical erasure.

10. Recipients and integrations

Access/disclosure depends on the selected purpose and function. Relevant categories include authorised staff/contractors, hosting/database/file/security providers, mail delivery/mailbox services, payment and invoice services, selected suppliers, AI/gateway/search providers, Google map/analytics services and advisers/authorities where necessary. Each recipient's controller/processor role depends on actual decisions and agreements.

• Where payments are enabled and initiated, PayU receives the relevant payment/transaction and necessary buyer information. Our own-sale invoice/accounting route, including Fakturownia/KSeF where applicable, is separate from the invoice provider a customer selects for its own client documents.
• Customer-selected invoice integrations transmit the required buyer/seller/document data and use configured access credentials. Available brands can include Fakturownia, inFakt, Comarch Betterfly or Fakturoid, only as supported/enabled. Provider roles and retention are not automatically identical; disconnecting cannot recall issued external documents.
• Supplier order/quote dispatch sends reviewed document/order/contact information to the chosen supplier/mail recipients. Client delivery-address information belongs to delivery where required, not pickup by default. Downloaded/sent/CC copies can survive DINPanel cleanup.
• Opening a map or deliberately finding an address can contact Google; address lookup can send the entered address, including a client's address, plus necessary technical connection data. Saving an address alone is not a lookup in service. Your map permission is not the client's legal basis.
• Configured AI/gateways and hosted search can receive the content described above; optional external analytics is a separate choice. Mail services, including configured SMTP/Zoho routes, can hold deliberate correspondence and older copies.
• Our configured services include Hetzner infrastructure, OpenAI API, Zoho Mail (smtppro.zoho.eu), PayU payments and Fakturownia for DINPanel's own invoices/KSeF. Customer-selected invoice services, suppliers and Google Maps have the role appropriate to that specific action. The DPA names the customer-content subprocessors and their functions. A provider receiving data for its own legal purposes is not thereby our processor for all of its activities.
• Optional video tutorials use YouTube (Google). Embedded playback starts only after you select Play; DINPanel serves the preview image locally and does not load that video player in advance. Some help links open YouTube in a new tab only after selection. Watching is optional and is not a condition of using DINPanel.
• When you play a video or follow a YouTube link, Google receives connection data such as your IP address, browser/device information and the requested video. Google handles its own service data under its Privacy Policy: https://policies.google.com/privacy. This tutorial feature does not send your project contents, recordings or transcripts to YouTube.

11. International transfers

OpenAI, Zoho and Google services can involve processing or support outside the EEA, including the United States or India depending on the service and onward provider. An EU contracting entity or .eu endpoint is not a promise of EU-only processing. Hosting location and authorised access follow the applicable infrastructure order and processing arrangement.

Third-country processing requires the applicable lawful safeguard, such as an adequacy decision covering the recipient or contractual safeguards, including the European Commission's standard contractual clauses where required, with the relevant assessment and supplementary protection. OpenAI's published business DPA includes a restricted-transfer framework; Zoho and Google provide service-specific data protection arrangements. We must apply the arrangement appropriate to our actual account and service. Contact info@dinpanel.com for the applicable destination, safeguard and a copy or explanation, with necessary commercial/security redactions that do not conceal the protection.

12. Retention by purpose

Retention depends on the purpose, not simply on the existence of an account. The following events and criteria govern erasure or restricted retention. A specific legal hold covers only the relevant evidence until the proceeding or applicable limitation period ends; it does not preserve unrelated project content.

• Account/project content: while the requested service/instructions require it, then through the applicable verified return/removal process. Inactivity alone does not trigger automatic whole-project erasure. Archive retains technical documentation; soft project deletion is not a retention deadline.
• Recordings/text/history: pending/retry audio remains until the relevant durable acknowledgement, transcript acceptance or deliberate discard/removal under that workflow. Saved raw/edited text, revisions, applied project changes and other copies have distinct lifecycles; note removal does not erase every related project record.
• Journey telemetry: the internal 90-day scope described above, subject to earlier applicable withdrawal/erasure duties. A suspended browser applies queue expiry when the application next runs; server retention operates independently of further event collection.
• DINPanel's own tax and accounting evidence is kept for the statutory period applicable to that document and obligation, normally until expiry of the tax limitation period (generally five years from the end of the year in which the tax payment deadline falls, allowing for lawful suspension or interruption). KSeF retains its structured invoices for its statutory ten-year period from the end of the issue year; this is not a ten-year rule for all DINPanel content. Unresolved payments/refunds remain until reconciled and are then minimised. User-issued client invoices do not automatically become DINPanel's tax evidence.
• Contract/adoption/delivery evidence is limited to the document version or snapshot, party/authority, decision/time and necessary delivery state. It is retained while needed to perform and prove that agreement and afterward only for an applicable legal obligation or identifiable claim within its limitation period. Support correspondence remains while the case is active and afterward only the necessary dispute or security evidence under that criterion. Routine technical logs must have a defined operational/security purpose and deletion schedule; a documented incident hold is reviewed separately. No indefinite general log, support or anti-abuse archive is authorised.
• Providers, delivered mail/order recipients and user downloads have separate retention and ownership. We pursue deletion or assistance where required by our role; an independent recipient may retain its own lawful transaction evidence. Offline copies are cleared when the device can execute the instruction. A permanently disconnected device and previously downloaded file require action by the person controlling them.

13. Archive, deletion and copies

Archive, project Delete, note removal and full account deletion have different scopes. Read the relevant confirmation before instructing an irreversible operation.

• Archive permanently closes ordinary editing, removes designated client identity/contact/company/tax/address/location fields and covered structured/history/voice/export/order copies, and preserves read-only technical documentation. Arbitrary names, labels, notes, drawings and technical transcripts remain and may identify people; Archive does not anonymise the project.
• Project Delete is ordinary soft deletion. It does not physically erase the project/history/files or replace a properly scoped rights request. An accepted privacy Archive fence remains.
• Full account deletion covers complete attributable active, archived and soft-deleted project content, technical text, histories, drawings/files, recordings/transcripts/AI copies, support copies, credentials/integration access and supported local stores. Other owners' content and specifically justified minimum own-controller evidence remain separate. Access is fenced before cleanup; pending/failed work stays retryable and is not reported complete.
• Removing a note erases its covered text/revisions/proposals/receipts and attributable merged/local copies, but does not undo already applied project changes or erase independent history. Removing/accepting a wholesaler recording does not erase previously accepted supplier/contact records.
• Sent messages, external recipients/providers, user downloads, legacy unlinked copies and disconnected devices require separate handling. Any future backup restore must reapply accepted removals before data/workers reopen; no blanket backup-delay exception is created.

14. Security and recovery limitations

We remain responsible for risk-appropriate technical and organisational safeguards, authorised access, confidentiality and lawful incident/rights handling. Customers protect their accounts, devices and deliberate disclosures; this does not transfer all responsibility for platform processing to them.

Controls include account/project authorisation, restricted administration, encrypted integration credentials, protected transmission, private response cache controls, minimised diagnostics and scoped erasure with retry and late-write protection. This is not a promise that every stored project is encrypted, every incident is prevented or an independent security certification exists.

• As of this version there is no operational DINPanel backup system. Recovery infrastructure is a later stage; no recovery time or maximum data-loss guarantee is offered. Keep appropriate exports of important work. This information does not waive our security, availability or conformity duties.
• If recovery copies are introduced, their scope, access, location, retention and erasure procedure must be defined. A restore must reapply accepted removals before making data available or resuming workers. We do not claim that a proposed backup period or recovery target is already implemented.

15. Your rights

Depending on the processing and legal conditions, you can seek information/access and a copy, correction, erasure, restriction and objection. Consent may be withdrawn at any time; lawful earlier processing is unaffected, but continued retention needs a valid basis. Direct-marketing objections stop that marketing, including related profiling.

• Portability concerns personal data you supplied where processing is automated and based on consent or contract, in a structured, commonly used machine-readable format, including direct transfer where technically feasible. It is not an unconditional right to every internal record or another person's data.
• An objection to legitimate-interest processing is assessed on your particular situation and the applicable overriding-ground/claims conditions. A direct-marketing objection does not require that balancing.
• Erasure is not absolute: specific legal obligations, necessary claims and others' rights can limit it. Any exception must cover only justified fields/purposes and be explained; account closure, soft deletion and Archive are not substitutes for assessing a scoped request.
• Available exports/downloads support return of the covered data but are not a promise that a complete account return is already automated. Rights/support and account-removal access must not depend on accepting unrelated new legal documents.

16. How requests are handled

Use the privacy contact above or the available support/rights route. We decide requests for our own controller purposes. For customer-controlled project data, we identify/forward the request to the responsible customer where appropriate and assist under lawful instructions; that routing does not remove our own duties or justify ignoring the request.

Requests are normally free and answered without undue delay within one month. Where legally justified by complexity/number, an extension of up to two further months requires notice and reasons within the first month. Additional identity/authority information is requested only where reasonably needed; do not send full projects or identity documents by default. If a request is refused or limited, the reasons and complaint/remedy route must be explained. Manifestly unfounded/excessive requests are subject only to the GDPR's justified exceptions. Where required, corrections, erasure or restrictions must be communicated to recipients unless impossible or disproportionate; this does not mean external copies can automatically be recalled.

17. Supervisory complaints

You may complain to the supervisory authority in your habitual residence, place of work or alleged infringement. In Poland: President of the Personal Data Protection Office (Prezes UODO), ul. Stanisława Moniuszki 1A, 00-014 Warszawa; current contact and complaint instructions: https://www.uodo.gov.pl/p/kontakt. A complaint to the authority does not depend on first accepting this notice or exhausting DINPanel support.

18. Automated processing and children

AI transcribes or extracts information and can apply selected fields automatically where you enable that workflow. Outputs can be wrong and require review. These functions are not intended to make decisions about a person with legal or similarly significant effects. Payment and access controls reflect the agreed entitlement and verified events; if you dispute an automated outcome, contact Support for review. Any processing falling within GDPR Article 22 requires its applicable information and safeguards.

DINPanel is designed for people planning electrical work, not as a child-directed service. Do not enter children's or sensitive information without an appropriate lawful purpose and safeguards. Contact the privacy route if such data has been included so the correct controller/instructions and necessary handling can be established.

19. Versions and changes

This version applies when published and communicated for the relevant processing. Material changes are explained before they affect that processing, with separate consent where required. Exact prior texts and minimum evidence of real decisions may be retained for the justified contract/compliance purposes described here; history is not rewritten.

Language selection does not open another sales market or authorise a disabled function. Publication or receipt of this notice does not itself execute the separate DPA or a vendor agreement.