Privacy Policy
Last updated: 26 July 2026
This policy describes both Provider-controlled data processing and Customer Data processing roles in a B2B environment. If an English and Lithuanian version conflict, the Lithuanian version prevails.
1. Controller Identity and Scope
This Privacy Policy explains how personal data is processed in connection with PLN System.
For Provider-controlled processing, the controller is Jonas Liubinas, Vilkpėdės 9, Vilnius, Lithuania, email: [email protected].
2. Roles: Controller and Processor
The Provider acts as an independent controller for account, identity, billing, security, support, and service administration data.
For Customer Data entered or uploaded by organizations and their users for operational use within the Service, the Provider acts as a processor on behalf of the relevant customer organization. In those cases, the customer organization is the controller for that Customer Data.
3. Categories of Personal Data
Depending on how the Service is used, the Provider may process the following categories of personal data:
- Account and organization data, such as organization name, representative name, email address, phone, address, city, country, postal code, language, timezone, and related setup details.
- Authentication and identity data, such as login identifiers, user roles, authentication events, password reset events, and session/security metadata.
- Operational Customer Data entered by organizations, such as user profiles, tasks, schedules, comments, contacts, invoices, chat messages, attachments, equipment records, time entries, distance entries, expense records, notifications, and related business workflow data.
- Support and communications data, such as emails sent to the Provider and correspondence about support or legal/privacy matters.
- Security and technical data, such as IP addresses, rate-limit records, application logs, access logs, error logs, and basic service administration metadata.
- Preference and essential cookie data, such as locale preference and authentication/session-related data required to operate the Service.
4. Purposes and Legal Bases
When the Provider acts as controller, personal data is processed only as necessary for the operation of the Service and related administration. The Provider does not use Customer Data for advertising, marketing profiling, or AI model training.
- To create and manage accounts and organizations, authenticate users, and provide the Service: performance of a contract or steps prior to entering into a contract.
- To secure the Service, prevent abuse, enforce rate limits, investigate incidents, and maintain logs: legitimate interests in security, service integrity, and abuse prevention.
- To communicate about account, support, operational, or legal matters: performance of a contract and legitimate interests in operating the Service.
- To comply with legal obligations, respond to lawful requests, and maintain required records: compliance with legal obligations.
- To process Customer Data for customer organizations: processing on behalf of the customer under the applicable contract and DPA.
5. Cookies and Similar Technologies
The Service uses only cookies and similar technologies that are necessary for operation or clearly user-requested features, such as authentication/session handling and the locale preference cookie used to remember the selected language.
Google reCAPTCHA is used on signup and may set or access technical data as part of abuse prevention and bot protection.
The Service does not currently use advertising cookies or non-essential analytics cookies. The Provider does not currently operate third-party visitor analytics on the public website.
The cookies and similar technologies currently used by the Service are required for login, security, language selection, and abuse prevention.
Any future non-essential tracking would be disclosed before activation and, where required, would rely on consent.
6. Recipients and Processors
Personal data may be processed by the Provider and by service providers acting on the Provider’s behalf, only where necessary for hosting, storage, security, and operation of the Service.
- Hetzner: hosting infrastructure for the web application, database, and self-hosted operational components in Europe.
- Backblaze B2: file and attachment storage in Europe.
- Google reCAPTCHA: anti-bot protection on signup.
- Self-hosted operational tools on Provider-controlled infrastructure, including basic Docker logs, Prometheus, and Grafana.
7. International Transfers
The Provider primarily stores service data in Europe. However, Google reCAPTCHA may involve processing or transfer of limited technical/personal data to the United States or other countries outside the EEA.
Where such transfers occur, the Provider relies on the safeguards and lawful transfer mechanisms made available by the relevant provider at the time of transfer, such as Standard Contractual Clauses or other valid mechanisms under applicable data protection law.
8. Retention
Personal data is retained only for as long as necessary for the relevant purpose, legal obligation, or customer relationship.
- Active and suspended account and organization data: retained while the organization account remains active or suspended and for any limited post-termination period reasonably necessary for payment collection, refunds, disputes, legal obligations, security investigations, or deletion processing.
- On successful individual account deletion: the sign-in identity and credentials are deleted, the email-address reservation is released, and device push-notification tokens are removed immediately.
- Within 90 days after individual account deletion: the member’s name, phone number, and profile picture are anonymized from the retained account record.
- Organization-controlled work records, including tasks, survey logs, control points, time and expense entries, chat messages, and files, remain with the organization for operational and lawful record-keeping purposes. Audit and billing records may be retained for as long as applicable law requires.
- Organization deletion: after an owner requests deletion, organization data remains in a 7-day grace period, after which deletion is finalized.
- Provider-initiated suspension or termination for non-payment, material breach, security, or legal reasons: related data may be retained for a limited cure or dispute period before final deletion, subject to applicable law and the Service deletion process.
- Backups: deleted data may remain in rolling backups for up to an additional 7 days after final deletion.
- Application, access, IP, and rate-limit logs: retained for approximately 1 month.
- Support emails and related correspondence: retained for 1 year after the relevant support exchange, unless longer retention is legally required.
9. Data Subject Rights
Where the Provider acts as controller, you may request access, rectification, deletion, restriction, objection, or portability, where applicable, by contacting [email protected].
Where the Provider acts as processor for Customer Data, requests about that Customer Data should in most cases be directed first to the relevant customer organization, which acts as controller for those records.
You also have the right to lodge a complaint with the State Data Protection Inspectorate of Lithuania (VDAI).
10. Security
The Provider applies reasonable technical and organizational measures designed to protect personal data, including encryption in transit (SSL/TLS), role-based access controls, authentication through Keycloak and JWT-based sessions, logging and monitoring, and weekly database backups.
No system can be guaranteed perfectly secure. Customers are also responsible for managing their own user access, credentials, and lawful data use inside the Service.
11. Changes to this Policy
This Privacy Policy may be updated from time to time. If material changes are made, the Provider will use reasonable efforts to provide at least one month of advance notice where practicable, except where immediate changes are required for legal, security, or urgent operational reasons.
Where the Provider gives notice about material changes to the Terms of Service, Privacy Policy, or DPA, the Provider may send that notice to the organization registration email used at signup and will make the current legal documents available in English and Lithuanian.
Contact for privacy requests: [email protected]
If the English and Lithuanian versions differ, the Lithuanian version prevails.