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Last updated: 12 June 2026
This Privacy Policy explains how data is processed while using the Wayfinder Easy-Way navigation app in facilities such as hospitals, shopping malls, office buildings and airports. The app has been designed in line with the principle of data minimisation, so the scope of the information processed is limited to the necessary minimum. This English version is provided for convenience only; in the event of any discrepancy, the Polish version of this document prevails.
1.1. Facility Owner or Manager. Each facility using the app has its own data controller, namely its owner or manager, for example a hospital, shopping mall or airport. The controller is responsible for data related to map content, room descriptions and any personal data included in the published information, such as the names of employees or doctors shown on room labels. The facility’s controller contact details are available in the app footer or on the information boards within the facility.
1.2. Technical operator: DOT DOT sp. z o.o. (Easy-Way). DOT DOT sp. z o.o., with its registered office at ul. Ludwika 17, 40-176 Katowice, Poland, KRS 0001246224, Tax ID (NIP) 9542909898, owner of the Easy-Way.io brand, is responsible for the technical operation of the app. The company acts as a processor on behalf of the facility’s owner or manager and is not the controller of the content they publish. As regards the technical data necessary for the app to work, described in § 2.1, the Operator acts as the data controller. The Operator has appointed a Data Protection Officer, Tomasz Budzyński. For data protection matters, you can contact us at [email protected]. General questions about the app can be directed to [email protected].
1.3. Precedence of a separate agreement. Easy-Way provides services to facility owners and managers on the basis of separate agreements. The provisions of this Policy apply to the extent that the parties have not agreed on other data processing rules in a signed Data Processing Agreement (DPA). Where such an agreement has been concluded, its provisions take precedence over this Policy.
The app does not require logging in, creating an account or providing data that identifies the user.
2.1. Technical data. To ensure the proper operation of the app, technical data may be processed automatically, such as the IP address necessary to establish a connection, the type of web browser, the device’s operating system, the screen resolution and orientation and the device language. This data is not used to identify users.
2.2. Navigation data. For statistical purposes, we may analyse anonymous and aggregated information about how the app is used, in particular the most frequently searched locations, popular routes and time spent in the app. This data does not allow a specific person to be identified.
2.3. Data entered by the user. The app may process phrases entered into the search box and accessibility-related settings. This data is processed locally or used only after anonymisation. Accessibility preferences are stored on the user’s device and are not used to identify them.
2.4. Data we do not collect. Wayfinder Easy-Way does not collect names, national ID numbers (PESEL), email addresses, phone numbers, precise GPS location, biometric data, patient card numbers or medical data, subject to the situations described in point 2.5.
2.5. Healthcare facilities. In some cases, choosing a particular navigation destination, for example an oncology ward or an emergency department, could indirectly suggest information about the user’s health. To mitigate this risk, the app does not store search history in a way that allows it to be linked to a specific person, does not create user profiles and, as far as possible, processes data locally on the user’s device.
3.1. Data is processed to provide navigation services, including displaying maps and plotting routes. The legal basis is the controller’s legitimate interest under Article 6(1)(f) GDPR.
3.2. Data may be processed to ensure the security of the app, detect abuse and protect against attacks. The legal basis is Article 6(1)(f) GDPR.
3.3. Data may be used to optimise the operation of the app and improve performance and user experience. The legal basis is Article 6(1)(f) GDPR.
3.4. Anonymous statistical data may be processed as part of analytics on app usage, carried out using the Plausible tool that works without cookies. The legal basis is Article 6(1)(f) GDPR, while preserving the user’s right to object.
3.5. Data related to accessibility features may be processed to ensure convenient use of the app for people with different needs. The legal basis is Article 6(1)(f) GDPR.
4.1. The Operator uses external providers that support the operation of the app, in particular hosting, content delivery network and analytics providers.
4.2. Data related to hosting the app is processed on Hetzner infrastructure located within the European Union.
4.3. Cloudflare services are used to ensure efficient content delivery. Any data transfers take place in accordance with applicable law and appropriate safeguards.
4.4. Statistics on app usage are gathered using the Plausible tool, whose infrastructure is located within the European Union. The solution works without cookies and without persistent user identifiers.
4.5. The current list of processors cooperating with the Operator is available at List of Subprocessors.
5.1. Data contained in technical logs is kept for up to 30 days.
5.2. Data related to security incidents may be kept for up to 12 months.
5.3. Statistical data, once anonymised, may be kept indefinitely, as it no longer constitutes personal data.
5.4. Analytics data is kept for up to 14 months.
5.5. Accessibility preferences stored on the user’s device remain available until the user deletes them.
6.1. You have the right to access your data in accordance with Article 15 GDPR. Due to the anonymous nature of most of the information processed, identifying data attributed to a specific person may not be possible.
6.2. You have the right to request the erasure of data in accordance with Article 17 GDPR. Most technical data is deleted automatically after the periods indicated in § 5.
6.3. You have the right to object to the processing of data for analytics purposes in accordance with Article 21 GDPR.
6.4. You have the right to data portability in accordance with Article 20 GDPR, although the ability to exercise this right may be limited due to the anonymous nature of the information processed.
6.5. You have the right to lodge a complaint with the President of the Personal Data Protection Office, with its registered office at ul. Stawki 2, 00-193 Warsaw, Poland.
6.6. Requests to exercise your rights can be sent to [email protected]. Responses are provided within 30 days.
7.1. Easy-Way applies appropriate technical and organisational measures to protect data in accordance with the requirements of Article 32 GDPR.
7.2. Connections to the app are encrypted, and data is stored using appropriate security mechanisms.
7.3. Data related to individual facilities is stored separately, so a user’s activity in one facility is not combined with their activity in another.
7.4. Technical logs are deleted regularly, and the security of the infrastructure is subject to periodic reviews and tests.
8.1. The app uses only cookies strictly necessary for its proper operation.
8.2. Detailed information on cookies can be found in the separate Wayfinder Easy-Way Cookie Policy.
9.1. The app is designed in line with good digital accessibility practices.
9.2. Detailed information on accessibility is described in the Accessibility Statement available at Wayfinder Accessibility Statement.
9.3. Accessibility issues can be reported at [email protected].
10.1. For technical matters relating to the operation of the app, you can contact us at [email protected].
10.2. For matters relating to maps, labels and information published in the app, please contact the controller of the relevant facility.
10.3. For matters relating to the protection of personal data, please contact us at [email protected].
10.4. Complaints to the supervisory authority can be directed to the President of the Personal Data Protection Office.
11.1. Users will be informed of material changes to the Privacy Policy through a notice or banner in the app at least 14 days before the changes take effect.
11.2. The current version of the Privacy Policy is available at Wayfinder Privacy Policy.