Privacy Policy

DRAFT — this text is a structure for review by a lawyer, not final legal wording.

1. Controller

The controller of personal data is Maciej Wróblewski, ul. Wiejska 13, 89-606 Chojniczki, Poland, contact@refracta.eu.

2. Patient data

Refracta works offline. Patient data entered into the program is stored only on your device and is never sent to us. You are the controller of that data; we do not process it.

3. Data processed when you buy

E-mail address, name, billing address, VAT number (if given) and payment details — to perform the contract, issue the invoice and deliver the licence key (Art. 6(1)(b) and (c) GDPR). Invoices are kept for the period required by tax law.

4. Recipients

Stripe (payments, invoices), our hosting provider (Hostinger), our e-mail provider, and accounting services. [TO COMPLETE: list of processors and any transfers outside the EEA].

5. Cookies

We use one essential cookie (“lang”) that remembers your language choice for 12 months. We do not use analytics or advertising cookies.

6. Your rights

You have the right of access, rectification, erasure, restriction, data portability and objection, and the right to lodge a complaint with a supervisory authority — in Poland the President of the Personal Data Protection Office (UODO), or the authority in your own country.