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Privacy Policy

The following Privacy Policy sets out the rules for storing and accessing data on Users’ Devices using the Service for the purpose of providing electronic services by the Controller, as well as the rules for collecting and processing Users’ personal data provided by them personally and voluntarily via tools available in the Service.

§1 Definitions

  • Service – the “RevoCure” website available at: https://revocure.com/

  • External Service – partner, service provider, or client websites cooperating with the Controller.

  • Service / Data Controller – the Service Controller and the Data Controller (hereinafter the “Controller”) is the company “Next Move Labs Sp. z o.o.”, with its registered office at: ul. Majowa 2, 71-374 Szczecin, Poland, tax identification number (NIP): 8522686489, providing electronic services via the Service.

  • User – a natural person for whom the Controller provides electronic services via the Service.

  • Device – an electronic device with software through which the User gains access to the Service.

  • Cookies – text data collected in files placed on the User’s Device.

  • GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

  • Personal data – information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

  • Processing – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

  • Restriction of processing – the marking of stored personal data with the aim of limiting their processing in the future.

  • Profiling – any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.

  • Consent – the data subject’s consent means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

  • Personal data breach – a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

  • Pseudonymisation – the processing of personal data in such a manner that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.j

  • Anonymisation – anonymisation of data is an irreversible process of operations on data that destroys/overwrites “personal data,” making it impossible to identify or link a given record to a specific user or natural person.

§2 Data Protection Officer

Pursuant to Article 37 of the GDPR, the Controller has not appointed a Data Protection Officer.

In matters related to data processing, including personal data, please contact the Controller directly.

§3 Types of Cookies

  • Internal cookies – files placed and read from the User’s Device by the Service’s ICT system.

  • External cookies – files placed and read from the User’s Device by the ICT systems of External Services. Scripts of External Services that may place Cookies on the User’s Devices have been intentionally included in the Service through scripts and services made available and installed in the Service.

  • Session cookies – files placed and read from the User’s Device by the Service during a single session of a given Device. After the session ends, the files are deleted from the User’s Device.

  • Persistent cookies – files placed and read from the User’s Device by the Service until they are manually deleted. The files are not automatically deleted after the Device session ends unless the User’s Device is configured to delete Cookies upon ending the Device session.

§4 Data storage security

  • Mechanisms for storing and reading Cookies – The mechanisms for storing, reading, and exchanging data between Cookies saved on the User’s Device and the Service are implemented through built-in web browser mechanisms and do not allow the retrieval of other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information. Transferring viruses, trojans, and other worms to the User’s Device is also practically impossible.

  • Internal cookies – The Cookies used by the Controller are safe for Users’ Devices and do not contain scripts, content, or information that could threaten the security of personal data or the security of the Device used by the User.

  • External cookies – The Controller takes all possible actions to verify and select Service partners with regard to User security. The Controller cooperates with well-known, large partners with global public trust. However, the Controller does not have full control over the content of Cookies from external partners. To the extent permitted by law, the Controller is not responsible for the security of such Cookies, their content, or their licensed use by scripts installed in the Service originating from External Services. A list of partners is included later in this Privacy Policy.

  • Cookie control

  • User-side risks – The Controller applies all possible technical measures to ensure the security of data stored in Cookies. However, please note that the security of this data depends on both parties, including the User’s actions. The Controller is not responsible for the interception of this data, impersonation of the User’s session, or its deletion resulting from the User’s deliberate or unintended activities, viruses, trojans, or other spyware with which the User’s Device may be or may have been infected. Users should follow safe browsing recommendations to protect themselves against these risks.

  • Storage of personal data – The Controller ensures that it makes every effort to keep the personal data voluntarily provided by Users safe, that access to them is limited, and that processing is carried out in accordance with their purpose and processing objectives. The Controller also ensures that it makes every effort to secure the data against loss by applying appropriate physical and organisational safeguards.

§5 Purposes for which Cookies are used

  • Improving and facilitating access to the Service
  • Personalising the Service for Users
  • Marketing and remarketing on external services
  • Compiling statistics (users, number of visits, types of devices, connections, etc.)
  • Serving multimedia services
  • Providing social services

§6 Purposes of personal data processing

Personal data voluntarily provided by Users are processed for one of the following purposes:

  • Provision of electronic services:
    • Newsletter service (including sending advertising content with consent)
  • Communication by the Controller with Users regarding the Service and data protection
  • Ensuring the Controller’s legitimate interests

Anonymised data about Users collected automatically are processed for one of the following purposes:

  • Compiling statistics
  • Remarketing
  • Ensuring the Controller’s legitimate interests

§7 External Service Cookies

Within the Service, the Controller uses JavaScript scripts and web components of partners that may place their own cookies on the User’s Device. Remember that in your browser settings you can decide which cookies are allowed for use by individual websites. Below is a list of partners or their services implemented in the Service that may place cookies:

Services provided by third parties are beyond the Controller’s control. These entities may change their terms of service, privacy policies, purposes of data processing, and methods of using cookies at any time.

§8 Types of data collected

The Service collects data about Users. Some data are collected automatically and anonymously, and some are personal data voluntarily provided by Users when subscribing to particular services offered by the Service.

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Opened subpages of the Service
  • Time spent on a given subpage
  • Type of operating system
  • Address of the previous subpage
  • Referrer URL
  • Browser language
  • Internet connection speed
  • Internet service provider

Data collected during registration:

  • First name / last name / nickname
  • Email address
  • Website addresses
  • Phone number
  • IP address (collected automatically)

Data collected when subscribing to the Newsletter service:

  • First name / last name / nickname
  • Email address
  • IP address (collected automatically)

Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to the statistics service provider.

§9 Access to personal data by third parties

As a rule, the only recipient of personal data provided by Users is the Controller. Data collected as part of the services provided are not transferred or sold to third parties.

Entities responsible for maintaining the infrastructure and services necessary to operate the Service (most often under a data processing agreement) may have access to the data, i.e.:

  • Hosting companies providing hosting or related services for the Controller
  • Companies through which the Newsletter service is provided

Entrusting the processing of personal data – Hosting, VPS, or Dedicated Servers

To operate the Service, the Controller uses an external hosting/VPS/dedicated server provider – home.pl SA. All data collected and processed in the Service are stored and processed in the provider’s infrastructure located in Poland. Access to the data may occur as a result of maintenance work carried out by the provider’s personnel. Access to such data is governed by an agreement between the Controller and the provider.


§10 Manner of processing personal data

Personal data voluntarily provided by Users:

  • Personal data will not be transferred outside the European Union unless they have been published as a result of an individual action by the User (e.g., posting a comment or entry), which makes the data available to any person visiting the Service.
  • Personal data will not be used for automated decision-making (profiling).wania).
  • Personal data will not be sold to third parties.

Anonymous data (without personal data) collected automatically:

  • Anonymous data (without personal data) will be transferred outside the European Union.
  • Anonymous data (without personal data) will not be used for automated decision-making (profiling).
  • Anonymous data (without personal data) will not be sold to third parties.

§11 Legal bases for personal data processing

The Service collects and processes Users’ data on the basis of:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR)
    • Art. 6(1)(a)
      the data subject has given consent to the processing of his or her personal data for one or more specific purposes
    • Art. 6(1)(b)
      processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
    • Art. 6(1)(f)
      processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party
  • The Polish Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)
  • The Polish Telecommunications Law Act of 16 July 2004 (Journal of Laws 2004 No. 171, item 1800)
  • The Polish Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24, item 83)

§12 Period of personal data processing

Personal data voluntarily provided by Users:

As a rule, the indicated personal data are stored only for the duration of the Controller’s provision of the Service. They are deleted or anonymised within up to 30 days from the end of service provision (e.g., deletion of a registered user account, unsubscribing from the Newsletter, etc.).

An exception is a situation requiring the protection of the Controller’s legitimate purposes for further processing of such data. In such a case, the Controller will store the indicated data, from the time of the User’s request for deletion, for no longer than 3 years in the event of a breach or suspected breach of the Service Regulations by the User.

Anonymous data (without personal data) collected automatically:

Anonymous statistical data that do not constitute personal data are stored by the Controller for the purpose of keeping Service statistics for an indefinite period.

§13 Users’ rights related to personal data processing

The Service collects and processes Users’ data on the basis of:

  • Right of access to personal data
    Users have the right to obtain access to their personal data, exercised upon request submitted to the Controller.

  • Right to rectification of personal data
    Users have the right to request the Controller to promptly rectify inaccurate personal data and/or complete incomplete personal data, exercised upon request submitted to the Controller.

  • Right to erasure of personal data
    Users have the right to request the Controller to promptly erase personal data, exercised upon request submitted to the Controller. In the case of user accounts, data deletion consists of anonymising data that enable identification of the User. The Controller reserves the right to suspend the execution of an erasure request to protect the Controller’s legitimate interests (e.g., when the User has violated the Regulations or data were obtained as a result of correspondence).
    For the Newsletter service, the User can delete their personal data independently by using the link included in every email message sent.

  • Right to restriction of processing
    Users have the right to restrict the processing of personal data in the cases indicated in Article 18 of the GDPR, including contesting the accuracy of personal data, exercised upon request submitted to the Controller.

  • Right to data portability
    Users have the right to receive from the Controller the personal data concerning them in a structured, commonly used, machine-readable format, exercised upon request submitted to the Controller.

  • Right to object to processing
    Users have the right to object to the processing of their personal data in the cases specified in Article 21 of the GDPR, exercised upon request submitted to the Controller.

  • Right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory authority responsible for personal data protection.

§14 Controller’s contact details

You can contact the Controller in one of the following ways:

  • Postal address: Next Move Labs Sp. z o.o., ul. Majowa 2, 71-374 Szczecin, Poland

  • Email address: contact@nextmovelabs.com

  • Telephone: +48 733 644 002

  • Contact form: available at: /kontakt

§15 Service requirements

  • Restricting the saving and access to Cookies on the User’s Device may cause some functions of the Service to operate improperly.

  • The Controller bears no responsibility for malfunctioning Service functions if the User, in any way, restricts the ability to save and read Cookies.

§16 External links

The Service – including articles, posts, entries, or User comments – may contain links to external websites with which the Service Owner does not cooperate. These links and the websites or files indicated by them may be unsafe for your Device or pose a security threat to your data. The Controller is not responsible for content located outside the Service.

§17 Changes to the Privacy Policy

  • The Controller reserves the right to change this Privacy Policy at any time without informing Users insofar as it concerns the use of anonymised data or the use of Cookies.

  • The Controller reserves the right to change this Privacy Policy with regard to the processing of Personal Data, of which Users who have user accounts or are subscribed to the newsletter will be informed via email within 7 days of the changes being made. Continued use of the services constitutes awareness and acceptance of the changes introduced to the Privacy Policy. If the User does not agree with the changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter.

  • Any changes to the Privacy Policy will be published on this subpage of the Service.

  • The changes take effect upon publication.