Porami Privacy Policy

This Privacy Policy describes the processing of personal data in the Porami service, including when using campaigns, surveys, phone verification, the My Rewards section, Nearby Rewards, and tools for confirming reward redemption.

Porami designs the user flow so that the user's phone number is used as an identifier within Porami and is not routinely disclosed to businesses or their staff.

1. Data controller and contact

The operator of Porami is the controller of personal data processed for the service's basic operation. For privacy matters, contact contact@porami.pl.

The controller's identifying details may be completed or updated before the service is fully launched to the public.

2. Categories of data

Porami may process:

• phone number, phone-verification status, and Porami account identifiers;
• language, communication preferences, and optional profile data if provided by the user;
• survey responses, session status, selected reward, and reward-saving and redemption status;
• technical data relating to OTP, security, device, requests, and system logs;
• consents, acceptance of documents, document versions, dates, and sources of acceptance;
• events relating to reward validation and redemption.

3. Purposes and legal bases for processing

Data is processed to provide the Porami service, run surveys, save rewards, display saved rewards, verify phone numbers, prevent abuse, manage consents, prepare reports for businesses in a way that limits user identification, and ensure service security.

The legal basis for processing may be performance of a contract or steps requested by the user, Porami's legitimate interests, a legal obligation, or the user's consent for optional features such as Nearby Rewards or future SMS communications.

4. Phone number and non-disclosure to businesses

The phone number is used for verification, saving rewards, limiting repeated use of the same campaign, and restoring access to rewards.

In the standard process for checking or redeeming a reward, Porami does not disclose the user's phone number to businesses or their staff. Businesses see the reward status and information needed to handle the campaign, not the user's full contact details.

5. Reports for businesses

Porami may provide businesses with campaign reports, statistics, aggregated responses, insights, and information about reward redemption.

Reports should be prepared so that businesses are not given raw phone numbers or direct user identifiers.

6. Data recipients

Data may be processed by providers of hosting, infrastructure, security, communications tools, OTP/SMS, technical operations, support, analytics, or legal and accounting services where needed to operate Porami.

Data may also be disclosed to competent authorities, courts, or regulators where required by law.

7. Retention period

Data is retained for as long as needed to provide the service, handle rewards, prevent abuse, maintain records of consents, ensure security, prepare reports, and establish or pursue claims or defend against them.

Retention periods may differ by data type. Technical and OTP data may be retained for less time than information needed to document consent or the saving or redemption of a reward.

8. User rights

Users have rights under the GDPR, including:

• the right of access to data;
• the right to rectify data;
• the right to erase data in cases provided for by law;
• the right to restrict processing;
• the right to object to processing based on legitimate interests;
• the right to data portability, where applicable;
• the right to withdraw consent for processing based on consent.

9. Complaint to a supervisory authority

Users have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych) if they believe that the processing of their data infringes personal-data protection laws.

10. Changes to this Policy

Porami may update this Privacy Policy as the service develops, the law changes, or data-processing practices change. The current version is available on the Porami website.