Wersja polska (wiążąca) / Polish version (binding)

Privacy Policy — Pomago

Effective from: 2026-11-15. Controller: NEXUFAB Rafał Kalinowski. This is a translation; the Polish version prevails.

Working draft for closed testing. Before the app is made available to all users, this document will be reviewed by a lawyer and may change; we will announce any change in guardian mode.

This policy describes how we process the personal data of guardians and children in the Pomago application and on the pages at https://pomago.nexufab.pl. There is one application and it works in two modes: guardian mode (for adults: the Owner and Guardians) and child mode (on a child's device). Capitalised terms have the meaning given in the Terms of Service. A separate short text for children — the “Information for the child” — is available in child mode and at https://pomago.nexufab.pl/en/child-info.

1. Controller and contact

1. The controller of the data of guardians and children is Rafał Kalinowski, a sole trader operating under the business name NEXUFAB Rafał Kalinowski, ul. Graniczna 20, 05-825 Grodzisk Mazowiecki, Poland, tax identification number (NIP) 5342239126.
2. For personal data matters write to kontakt@nexufab.pl or to the postal address above. You can also call: +48 572 724 001.
3. We have not appointed a data protection officer. Data matters are handled personally by the controller.

2. Who this policy concerns and what we do not collect

1. This policy concerns: the Owner of a Family, Guardians, children for whom a guardian keeps a profile, people who report content to us, and people who write to us.
2. The Application stores: labels (nicknames) of guardians and child profiles, avatar number, chore titles, due times and recurrence, chore completion status and time, public keys and identifiers of the family's devices, a record of statements and consents made (kind, version, time), messages next to chores (help requests, notes, replies) in encrypted form only together with their technical data, the family's messages key in encrypted form only, content reports.
3. We receive a guardian's data from the guardian. A child's data is entered by a guardian; from the child's device we receive only the keys of that device, reports that chores are done and — if a guardian has switched on Messages — the child's Messages in encrypted form. If you link your Account to a Google account, we receive confirmation of your identity from Google. If you buy the “Family” plan, we confirm the subscription status with Google Play.
4. We do not collect: name and surname, email address, phone number, date of birth or age, photos, voice recordings, location, contact lists, lists of apps, advertising ID or hardware numbers of the device — neither of the guardian nor of the child. Sending photos and voice recordings is not available in the Application. We do not record IP addresses in the database or in the Application's logs. We do not record which child selected their profile on a shared device, or when.
5. Year of birth. On first launch the Application asks for the year of birth to determine whether guardian mode may work on the device. The year is checked only by the device; we do not save or send it. The device remembers only the result and the time of the answer.
6. We do not carry out marketing, do not send a newsletter and do not use analytics or advertising tools. There are no ads in the Application.

3. Guardians' data: why and for how long

“Point (a), (b), (c), (f)” means Article 6(1)(a), (b), (c), (f) GDPR.

We indicate our legitimate interests (point (f)) in the “Legal basis” column. Data related to Messages and content reports is described in section 4a.

4. Children's data

1. We process children's data because that is what the Service is: a guardian gives a child chores and the child marks them as done. A child does not create an Account, does not give us any data about themselves and does not conclude a contract. Child mode does not work until a guardian connects the device in guardian mode.

2. Legal basis. We process the child's data in the table above on the basis of Article 6(1)(f) GDPR. The legitimate interest is: the interest of the parent or guardian in organising the household chores of a child in their care, and our interest in performing the contract with the guardian. Before launching the Service we checked whether the child's interests and rights override these interests. We concluded that they do not, because: we use a nickname instead of a name and surname, we do not collect the data listed in section 2(4), the child's data is seen only by their Family, we do not create profiles or assessments of the child, we do not show ads, we do not encourage the child to make purchases and we do not share this data with anyone for their own purposes, and a guardian may at any time delete the profile, disconnect the device or delete the Family. Messages rely on a different basis — the guardian's consent (section 4a).
3. We do not ask the child for consent and do not base processing on it. A guardian makes statements when creating a Family, when accepting an invitation and each time a child's device is connected; we record them (row 3 of the table in section 3).
4. Who sees the child's data: the Owner and approved Guardians of the Family; Messages — the people listed in section 4a(4). The child sees their own list and their own Messages on their device. On a device to which a guardian has assigned several profiles, the children see each other's labels, pictures, lists and Messages.
5. Guardian, do not enter surnames, addresses, phone numbers or information about the child's health in labels, chore titles and replies. These fields are not meant for that.
6. The child's rights described in section 10 are exercised on the child's behalf by a parent or legal guardian. The simplest way to object to the processing of a child's data is to delete the profile or disconnect the device — processing of that child's data then ends. If a child writes to us directly, we will reply in simple language and ask a parent or guardian to take part.
7. We do not take any automated decisions about the child and we do not track how the child uses the device.

4a. Messages next to chores and content reports

1. What it is. Next to a chore the child may ask for help with a ready-made reason (e.g. “I don't know how to do it”) or write a note of up to 280 characters; a guardian replies with text or a ready-made reply. The function works for a profile only after a guardian's consent. There is no chat, no photos, no recordings and no contact with people outside the Family.
2. Encryption. The content of Messages is encrypted on the Family's devices with a key that we do not have. On the server we keep the content only in encrypted form and cannot read it. We see technical data: the chore and profile, the sender's device, kind, time, size and key number. We keep the Messages key only encrypted for the Family's devices and — if the Owner has set this up — with the recovery code.
3. Legal basis: the guardian's consent. We process children's Messages and guardians' replies on the basis of consent (Article 6(1)(a) GDPR). In a Message a child may write something about their health or how they feel, so the consent is explicit and also covers such information (Article 9(2)(a) GDPR). Consent for a profile is given in guardian mode by a User who has stated that they have parental responsibility for, or care of, the child. Consent is voluntary: without it chores work exactly the same. You can withdraw consent at any time with the same switch; the profile's Messages are then deleted. Withdrawal does not affect the lawfulness of processing before withdrawal.
4. Who sees a profile's Messages: the Owner, Users who have made the statement in section 3, and Guardians chosen by the Owner; on a shared device — also siblings. We do not see them.
5. Other people. A Message may mention another person, e.g. a brother or a friend. We ask children and guardians not to write about other people. We do not inform such people separately — we do not know them and cannot read the content — and Messages disappear after a few days.

6. Content report. We learn the content of a Message only when a guardian reports it with the “Report content” button: after the guardian confirms, the Application sends us the decrypted content of that one Message. The report is examined by a human. If a report gives rise to a suspicion of a criminal offence threatening the life or safety of a person, we pass the information on to the law enforcement authorities (section 6(4)).
7. If we ever make photos or recordings available, we will ask for a new, separate consent and change this policy beforehand.

5. Do you have to provide data

To use the Service you need: the key of your device (created by the Application), a guardian label and acceptance of the Terms with the statement. The label may be a nickname. Linking a Google account, buying the “Family” plan and consent to Messages are voluntary. You add child profiles and chores to the extent that you want to use the Service.

6. Recipients of data

1. Microsoft — the provider of the Azure cloud in which the Application's server runs (Poland Central region). It processes data on our instructions under a data processing agreement. It stores Messages only in encrypted form.
2. Google as the Seller, if the Owner buys the “Family” plan in guardian mode: Google Commerce Limited (Ireland). You give your payment data directly to Google, which processes it as a separate controller under its own privacy policy. We do not receive your card details or email address. We send Google the purchase token to confirm the subscription status.
3. Google as the provider of the Google account — only if you link your Account to a Google account in guardian mode. You then sign in with Google, which as a separate controller learns that you use sign-in in the Application. We receive confirmation of identity from Google; we store only a hash of the account identifier from it.
4. Public authorities — where required by law, including law enforcement authorities if we become aware of a criminal offence threatening the life or safety of a person.
5. You download the Application from Google Play; downloads and updates are handled by Google under its own privacy policy.

Google services (purchase, sign-in) work only in guardian mode. Child mode connects only to the Application's server. We do not sell data and do not share it with other companies for their marketing purposes.

7. Transfers outside the European Economic Area

1. We store the Application's data in Poland.
2. Microsoft may exceptionally access data from outside the EEA, e.g. for technical support. Such transfers are safeguarded by the standard contractual clauses adopted by the European Commission and by Microsoft Corporation's participation in the EU-U.S. Data Privacy Framework.
3. You will receive a copy of the safeguards on request sent to kontakt@nexufab.pl.

8. Cookies, data on the device and notifications

1. The pages at https://pomago.nexufab.pl do not store cookies and have no sign-in. The invitation code from a link is read in the browser and does not reach our server until you use it in guardian mode.
2. The Application stores on the device what is necessary for the Service: the result of the year-of-birth question and the chosen mode, the device keys, a copy of the chore list, changes waiting to be sent and copies of Messages — encrypted only and deleted at the same time as on the server. The Application's data is not included in the device's cloud backup. After the device is disconnected, after “Clear device” and after a change of mode, the Application deletes this data from the device.
3. In guardian mode the Application uses the camera only to read the QR code from the child's device or from an invitation. The image is processed on the device; we do not save or send it. You can also type the code. Child mode does not use the camera, microphone or location.
4. Notifications. Reminders and notifications about a new chore, a report or a Message are created by the Application on the device after synchronisation with our server. A notification on a child's device does not contain a name or the name of a chore. On a child's device the Application sends no notifications between 21:00 and 7:00 and at most one every 10 minutes. You can switch notifications off in the phone settings.
5. Notifications through a Google service (Firebase Cloud Messaging) do not work in this version — neither in guardian mode nor in child mode. The Application does not contain this service and does not pass any identifier to Google for this purpose. Before we switch it on, we will change this policy and announce this in guardian mode; in child mode only a guardian will be able to switch it on.

9. Profiling and automated decisions

We do not create profiles of guardians or children and do not take decisions based solely on automated processing that produce legal effects or similarly significantly affect a person. Plan limits and the pausing of resources after a subscription expires follow directly from the Terms and do not depend on an assessment of the person. We do not analyse the content of Messages — we do not have the key.

10. Your rights and the child's rights

1. You have the right to: access to the data and a copy of it, rectification, erasure, restriction of processing and portability of data processed on the basis of a contract or consent. The child has the same rights; they are exercised by a parent or legal guardian.
2. You have the right to object at any time to processing based on our legitimate interest (rows 3, 8, 9, 10, 17 and 19 and the child's data — rows 11–15), on grounds relating to your or the child's particular situation. We will then stop processing the data unless we demonstrate compelling legitimate grounds or the need to establish, exercise or defend legal claims.
3. You can withdraw consent to Messages at any time in guardian mode, on the child's profile card.
4. You can exercise most rights yourself in guardian mode: downloading data (the Owner — of the whole Family, a Guardian — of their own Account), changing labels and chores, deleting a child profile, disconnecting a device, withdrawing consent to Messages, removing the link to a Google account, leaving the Family and deleting the Family. You can also delete the Family on the page https://pomago.nexufab.pl/delete with the Owner's recovery code.
5. Messages. You can read the content of Messages in guardian mode while they are kept. The file from “Download data” contains the technical data of Messages but not their content, because we do not have the key. For the same reason, on a request sent to us we can only provide the technical data and delete a Message without reading it. We do not correct the content of Messages — you can delete it by withdrawing consent.
6. For other matters write to kontakt@nexufab.pl. We do not have data that would let us link an email to a Family, and we do not collect such data only for this purpose. We may therefore ask you to confirm that the Family is yours — by an action in guardian mode; we never ask for a scan of an identity document or for the recovery code to be sent in a message.
7. We reply without undue delay, at the latest within one month of receiving the request. In complex cases we may extend this period by two months — we will tell you so within the first month. Handling requests is free of charge.
8. You have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes UODO), ul. Stanisława Moniuszki 1A, 00-014 Warsaw, Poland.

11. Deletion of data and backups

1. Deletion of the Family by the Owner immediately erases the data of all guardians and children of that Family (rows 1–7 and 11–18). Only the entry in the deletion register (row 10) and — until the period in row 19 ends — content reports, no longer linked to the Family, remain.
2. A Guardian leaving the Family erases their Account and the keys of their devices. Deleting a child profile erases its chores, history and Messages. Disconnecting a device erases its keys. After a Guardian is removed or a device is disconnected, the Family's devices set a new Messages key.
3. A Family in which nobody has used the Application for 12 months and which has no “Family” plan is deleted. For the last 30 days guardian mode shows a warning every time it is opened.
4. Deleting the Family does not cancel a subscription — you cancel it on Google Play.
5. We keep database backups for at most 30 days; Messages are only encrypted in them. Data deleted from the Application disappears from backups after that time at the latest.
6. If we restore a backup, the Application deletes again the Families recorded in the deletion register and Messages whose period has ended before it starts working.
7. If the Family loses all devices and the recovery code, the content of Messages cannot be recovered; chores and history stay.

12. Security

The connection to the Application's server is encrypted. We recognise devices by keys that never leave the device; there are no passwords. The content of Messages is encrypted and decrypted only by the Family's devices; our server does not have the key. We store codes (recovery, invitation, pairing) and the purchase token only as hashes; invitation and pairing codes work once and expire. The pairing code contains the fingerprint of the child's device key, which guardian mode checks. Each Family sees only its own data, and a child's device only the profiles a guardian has assigned to it. The Application has a separate database. Only the controller has access to the server.

13. Countries

We make the Application available in Poland. We apply this policy and the rights in section 10 to all guardians and children, regardless of country. We do not sell personal data and do not share it for advertising purposes. We accept requests at kontakt@nexufab.pl and reply within the time limit in section 10.

14. Changes to this policy

We publish the current version at https://pomago.nexufab.pl/en/privacy with its effective date. We announce significant changes — a new purpose, a new recipient, a new function (e.g. notifications through a Google service, photos) or a transfer outside the EEA — in guardian mode before they are introduced; we do not know your email address. We make previous versions available on request. The Polish version is binding; the English version is a translation.

Change history: 2026-11-14 — working draft for closed testing (two apps). 2026-11-15 — one app with guardian mode and child mode, year of birth checked on the device (section 2(5)), Messages next to chores based on consent and content reports (section 4a, rows 16–19), data on the device and notifications (section 8), rights for encrypted content (section 10(3) and (5)), deletion (section 11). Working draft for legal review.

Document version: 8c0cc843581e