Privacy and Cookie Policy of the ocu•vio platform
§ 1. General provisions
This Privacy Policy outlines the principles for processing and protecting the personal data of Users utilizing the ocu•vio website and application (hereinafter referred to as the "Platform").
The data controller is Magdalena Ojrzyńska, based in 50-505 Wrocław, email: kontakt@ocuvio.pl (hereinafter referred to as the "Controller").
The Administrator takes special care to protect the interests of individuals whose data is being processed, ensuring that the data collected is processed in accordance with the law, particularly with the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR) and the Polish Personal Data Protection Act.
§ 2. Purposes and basis for data processing
Users' personal data is processed by the Administrator for the following purposes:
- User registration and account management on the Platform, as well as the provision of services electronically (basis: Article 6(1)(b) GDPR – necessity for the performance of a contract).
- Payment processing for subscription access to the Platform (basis: Article 6(1)(b) GDPR).
- Fulfilling legal obligations of the Administrator, such as issuing invoices and maintaining accounting (basis: Article 6(1)(c) GDPR).
- Contact with the User via the contact form or email (basis: Article 6(1)(f) GDPR – legitimate interest of the Administrator).
§ 3. Data status – no processing of medical data
The ocu•vio platform provides services that are exclusively educational, preventive, entertaining, and supportive of daily digital well-being and eye hygiene (Digital Wellness category).
The platform does not collect, process, or store health-related data of Users as defined by Article 9 of the GDPR (special category data).
Any surveys, questionnaires, or forms available on the Platform are solely for assessing general lifestyle, screen habits, age, and the user's subjective feelings of fatigue to personalize the displayed content and do not constitute a medical interview or diagnostic assessment.
§ 4. Using the device's camera and AI module (Distance Control)
To enable the AI Distance Control feature for monitoring safe distance from the screen, the Platform requires a one-time user consent to access the device's front camera.
The camera image is processed exclusively in real-time, locally, directly in the device's RAM.
The Administrator states that the Platform does not record, capture, take photos, store, or transmit camera images or any biometric data to external servers.
After closing the session or disabling the feature, operational data is immediately and permanently removed from the device's RAM.
§ 5. Data retention period
Personal data will be stored for a period of:
- Duration of the agreement for the provision of services via electronic means (having an active account on the Platform).
- Required by tax and accounting regulations (for billing data and invoices – 5 years from the end of the tax year).
- Until the expiration of any potential claims or until the User raises an objection (in the case of data processed based on legitimate interest).
§ 6. Data recipients
To ensure the proper functioning of the Platform, the Administrator utilizes the services of external entities, to whom data may be entrusted (exclusively to the extent necessary to achieve the purpose):
- Provider of hosting and cloud computing services.
- Electronic payment operator — Stripe (Stripe Payments Europe, Ltd.), handling card payments and storing payment data; the Administrator does not store full payment card details.
- Accounting office servicing the Administrator.
- Email delivery system provider (transactional).
All these entities process data based on data processing agreements and guarantee a high standard of data protection (GDPR).
Due to the use of services from international providers (particularly payment operators and cloud infrastructure providers), personal data may be transferred to countries outside the European Economic Area. Such transfers occur solely with the application of legally mandated safeguards — based on decisions by the European Commission determining an adequate level of protection (including the EU-U.S. Data Privacy Framework) or standard contractual clauses approved by the European Commission.
§ 7. User Rights
Every User has the right to:
- Access to your personal data and obtaining a copy of it.
- Correction of your data.
- Data deletion ("right to be forgotten") – unless it conflicts with legal obligations (e.g., accounting).
- Data processing restrictions.
- Data transfer.
- Objection to data processing.
- Filing a complaint with the supervisory authority (President of the Personal Data Protection Office - PUODO).
§ 8. Cookies and Usage Data
The platform uses cookies (small text files stored on the User's device) to ensure the proper functioning of the platform, maintain the session of the logged-in User, and collect statistics (e.g., through tools like Google Analytics).
Analytical (statistical) cookies are installed only after consent is given in the cookie banner; consent can be changed at any time through "Cookie Settings" in the footer.
The platform also uses marketing cookies, including the Meta Pixel tool provided by Meta Platforms Ireland Limited (Merrion Road, Dublin 4, Ireland). These are used to measure the effectiveness of ocu•vio's advertising efforts and to target ads to individuals who have visited the site. Marketing cookies are installed only after separate consent is given in the cookie banner (category "Marketing"); consent can be withdrawn at any time through "Cookie Settings" in the footer.
Marketing tools operate solely on publicly accessible ocu•vio pages and are not activated in the logged-in section of the Platform. This means that no data regarding the use of exercises or responses provided in surveys is shared with Meta Platforms Ireland Limited — only information about visited informational subpages and cookie identifiers.
In terms of data collection by Meta Pixel and its use for measuring and displaying advertisements, the Administrator and Meta Platforms Ireland Limited are joint data controllers. Data may be transferred to the United States based on an executive decision by the European Commission determining an adequate level of protection (EU–U.S. Data Privacy Framework).
The user can change their cookie settings in their web browser at any time, including completely blocking their use. However, disabling essential cookies may hinder or prevent the use of the Platform.
§ 9. Waiting List
The email address provided in the ocu•vio waiting list registration form is processed solely for the purpose of informing the User about the opening of registration for the Platform.
The basis for processing is the User's voluntary consent (Article 6(1)(a) GDPR), expressed by checking the checkbox in the registration form.
Consent can be withdrawn at any time, without providing a reason, by contacting the email address: kontakt@ocuvio.pl.
Data from the waiting list is stored for up to 3 months from the day registration for the Platform opens, after which it is permanently deleted.