Privacy and Cookie Policy

This Privacy Policy describes the rules for processing the personal data of users of the SEO BOOK website, available at https://seo-book.app, and the SEO BOOK OS application.

1. Data controller

The controller of personal data is:

SEO BOOK APP
Hoxton Mix – 66 Paul Street, London EC2A 4NA

Contact for matters concerning personal data protection:
hello@seo-book.app

Hereinafter referred to as the “Controller” or “SEO BOOK”.

If the Controller appoints a Data Protection Officer, their contact details will be published here.

2. What data we may process

Depending on how you use SEO BOOK, we may process the following categories of data:

Account data

In particular:

• email address;
• account identifier;
• authentication data necessary to sign in;
• information about the selected Plan;
• account status;
• history of Plan activations and changes.

Data relating to SEO projects

In particular:

• domains added for monitoring;
• keywords;
• project settings;
• search engine ranking data;
• competitor data;
• audit results;
• monitoring history;
• generated reports.

As a general rule, this information does not necessarily constitute personal data. However, if the User enters information into the system that allows a natural person to be identified, it will be processed to the extent necessary to provide the Service.

Payment data

SEO BOOK may receive, among other things:

• the buyer’s email address;
• transaction identifier;
• name of the purchased Plan;
• payment status;
• subscription period;
• information about cancellations or refunds.

SEO BOOK does not necessarily receive full payment card details.

Payments are handled by Fungies, which acts as the Merchant of Record and the formal seller for the transaction. Depending on the transaction, this role is performed by Fungies Europe PSA or Fungies Inc., as indicated at checkout and on the sales document.

Technical data

When you use the website, the following may be recorded automatically:

• IP address;
• date and time of connection;
• device type;
• operating system;
• web browser;
• information about application errors;
• security logs;
• session identifiers.

This data is used primarily to ensure the security and proper operation of the system.

Data provided when contacting us

If you contact us, we may process:

• your email address;
• the name provided in your message;
• the content of your message;
• data contained in attachments;
• information relating to a technical support request.

3. Purposes and legal bases for processing

Creating and managing an Account

We process data to:

• create an Account;
• enable sign-in;
• provide access to SEO BOOK;
• deliver the selected Plan;
• administer PILOT 90.

The legal basis is Article 6(1)(b) GDPR — performance of a contract or steps taken before entering into a contract.

SEO monitoring and provision of the Service

Data may be processed to:

• check keyword rankings;
• maintain a history of results;
• perform audits;
• analyse competitors;
• generate reports;
• provide other SEO BOOK features.

The legal basis is Article 6(1)(b) GDPR.

Payments and subscriptions

Transaction-related data is processed to:

• activate a Plan;
• confirm payment;
• manage subscriptions;
• handle cancellations;
• handle refunds and complaints.

The legal basis may be:

• Article 6(1)(b) GDPR — performance of a contract;
• Article 6(1)(c) GDPR — compliance with a legal obligation;
• Article 6(1)(f) GDPR — the legitimate interest in establishing and defending legal claims.

As the Merchant of Record, Fungies also processes customer data under its own rules arising from its privacy policy and its payment-processing obligations.

Handling requests and enquiries

We process data to:

• answer questions;
• address technical issues;
• review complaints;
• conduct correspondence.

The legal basis may be Article 6(1)(b) or (f) GDPR.

The Controller’s legitimate interest is to provide user support and maintain records of correspondence.

Security

We may use technical data and logs to:

• protect Users’ Accounts;
• detect abuse;
• prevent attacks;
• diagnose failures;
• secure the infrastructure.

The legal basis is Article 6(1)(f) GDPR.

The Controller’s legitimate interest is to protect the website, users and data against abuse.

Pursuing and defending legal claims

Data may also be retained to the extent necessary to:

• establish legal claims;
• pursue legal claims;
• defend against legal claims.

The legal basis is Article 6(1)(f) GDPR.

Marketing

If SEO BOOK introduces a newsletter or other marketing communications, data will be used only on an appropriate legal basis, in particular after obtaining any required consent.

Consent may be withdrawn at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

4. AI features

SEO BOOK may provide features that use artificial intelligence.

Data and content submitted to these features may be transferred to external AI model or infrastructure providers only to the extent necessary to perform the requested operation.

Users should avoid entering the following into prompts unless necessary:

• special categories of personal data;
• medical data;
• identity document numbers;
• financial data;
• passwords;
• other confidential information relating to third parties.

The list of specific AI providers should be added to this Policy before any production features requiring the transfer of personal data to those providers are launched.

5. Who we may share data with

Data may be shared with entities supporting the operation of SEO BOOK, such as:

• hosting and server infrastructure providers;
• email service providers;
• technical service operators;
• security service providers;
• providers of APIs used by the system;
• AI service providers;
• entities providing legal or accounting assistance;
• competent public authorities, where disclosure is required by law.

Fungies may also be a recipient of data in connection with payments.

Fungies states that its services may be provided by Fungies Europe PSA in Poland and Fungies Inc. in the United States.

Data is transferred only to the extent necessary to achieve the specific purpose.

6. Transfers of data outside the EEA

Some providers used by SEO BOOK may be based outside the European Economic Area.

Where personal data is transferred outside the EEA, the Controller applies the mechanisms provided for by the GDPR, as appropriate to the circumstances, in particular:

• a European Commission adequacy decision;
• standard contractual clauses;
• other safeguards provided for in Article 46 GDPR.

The GDPR also requires users to be informed about transfers to third countries and the safeguards applied.

7. How long we retain data

Account data is retained for as long as you use SEO BOOK.

After you stop using the Service, data may be retained for the period necessary to:

• comply with legal obligations;
• settle transactions;
• review complaints;
• establish, pursue or defend legal claims;
• ensure system security.

Project data is retained for at least the period arising from the active Plan and the data history rules applicable to that Plan.

Technical logs and security data are retained for as long as necessary for system security and diagnostics.

Data processed on the basis of consent is processed until consent is withdrawn or the purpose of processing ceases to apply. A minimal amount of data may be retained further to demonstrate the validity of consent previously given.

8. Is providing data mandatory?

Providing the data required during registration is voluntary, but necessary to create an Account and use SEO BOOK.

Failure to provide the required data may prevent us from providing the Service.

Providing data for marketing purposes is voluntary and does not affect your ability to use either paid or free SEO BOOK features.

9. Your rights

Depending on the legal basis and circumstances of processing, the data subject has the right to:

• access their data;
• obtain a copy of their data;
• have their data rectified;
• have their data erased;
• restrict processing;
• data portability;
• object to processing;
• withdraw consent at any time.

Requests may be sent to:
hello@seo-book.app

As a general rule, the GDPR requires a response to a request without undue delay and no later than within one month. In more complex cases, this period may be extended in accordance with Article 12 GDPR.

10. Right to lodge a complaint

If you believe that data is being processed unlawfully, you may lodge a complaint with the competent supervisory authority.

In Poland, this is:
President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych)
Personal Data Protection Office (Urząd Ochrony Danych Osobowych)

Exercising your right to lodge a complaint does not prevent you from contacting us first at:
hello@seo-book.app

11. Profiling and automated decision-making

SEO BOOK may automatically analyse:

• ranking changes;
• trends;
• audit results;
• competitor data;
• project history.

These analyses are used to present SEO data, recommendations and priorities.

We do not use them to make decisions concerning the User that produce legal effects or similarly significantly affect the User within the meaning of Article 22 GDPR.

If this type of processing is introduced in the future, the Privacy Policy will be updated accordingly.

12. Cookies and similar technologies

SEO BOOK may use cookies and similar technologies.

Necessary cookies may be used, among other things, to:

• maintain sessions;
• enable sign-in;
• secure Accounts;
• store basic user settings;
• ensure the proper operation of the website.

Cookies or other technologies that are not necessary for the website to operate, in particular analytics or marketing technologies, should only be activated after the required consent has been obtained.

Article 399 of the Polish Electronic Communications Law governs the storage of information on, and access to information in, a user’s device.

A detailed list of cookies will be set out in a separate SEO BOOK Cookie Policy.

13. External tools

SEO BOOK may use third-party services needed for the application to function.

Each such entity may process data in accordance with its role and the agreements entered into.

If an external service acts as a processor, the processing should be covered by an appropriate agreement in accordance with Article 28 GDPR.

Where a third party independently determines the purposes and means of processing, it may act as a separate data controller.

14. Security

SEO BOOK applies appropriate technical and organisational measures to protect data against:

• accidental loss;
• unauthorised access;
• disclosure;
• alteration;
• destruction;
• other unlawful processing.

The scope of safeguards is adapted to the nature of the data, the risks and the technological capabilities currently available.

15. Third-party data

If a User enters other individuals’ personal data into SEO BOOK, they should have an appropriate legal basis for processing and transferring that data.

Users should not use SEO BOOK to collect individuals’ data without authorisation.

16. Minors

SEO BOOK is a service primarily intended for businesses, SEO specialists, website owners and other professional users.

The Service is not directed at children.

17. Links to other websites

SEO BOOK may contain links to external websites.

Once you follow a link to an external website, the rules for data processing are determined by that website’s operator.

The SEO BOOK Controller is not responsible for the privacy policies of independent external websites.

18. Changes to the Privacy Policy

This Policy may be updated, in particular in connection with:

• changes in the law;
• changes to SEO BOOK features;
• the introduction of new providers;
• infrastructure changes;
• the introduction of new payment methods or analytics tools.

The current version of the Policy is published on the SEO BOOK website.

If a change materially affects the way data is processed, users may additionally be notified through their Account or by email.

19. Contact

For matters relating to privacy and personal data:
hello@seo-book.app