Privacy policy

This Privacy Policy sets out the rules for the processing of personal data within the Seeniorum online service, available at: seeniorum.com, and within the services provided through the Platform.

Seeniorum is an online platform that enables persons seeking care for elderly people to contact, book and settle services provided by independent Caregivers.

Seeniorum is not a medical entity, employment agency, employer of Caregivers, entity providing care to the Senior, or a party to the care services agreement concluded between the Customer and the Caregiver.

Seeniorum processes personal data only to the extent necessary to operate the Platform, handle Accounts, bookings, payments, reports, contact, Caregiver verification, security, handling of requests and compliance with the Administrator’s legal obligations.

Using the Platform means that the person using it has read this Privacy Policy. Using Seeniorum’s services also requires acceptance of the Platform Terms and Conditions.

To the extent permitted by mandatory provisions of law, Seeniorum is not liable for the truthfulness, completeness, accuracy, timeliness or legality of data, information, documents, declarations, photos, video recordings, reports, reviews, messages or other content provided by Customers, Caregivers, Seniors or third parties.

The controller of personal data processed within the Platform is:

In all matters concerning personal data, the Controller may be contacted at: admin@seeniorum.com.

The Controller has not appointed a Data Protection Officer, unless separate information in this respect is published in the future.

Controller means Łukasz Kuca BDB Investments, operating the Seeniorum Platform.

Seeniorum / Platform / Service means the online service available at seeniorum.com, used to find, book and settle care services provided by independent Caregivers.

Customer means a person using the Platform to search for, book or pay for the services of a Caregiver.

Caregiver means an independent person offering care, assistance or support services for Seniors through the Platform.

Senior means the person to whom the care or support service relates, indicated by the Customer or using the Caregiver’s assistance.

Account means an individual Customer or Caregiver panel within the Platform.

Report means information prepared by the Caregiver after performing a visit or service, provided to the Customer through the Platform.

Personal Data means any information relating to an identified or identifiable natural person.

GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council.

Seeniorum acts as a personal data controller to the extent that it independently determines the purposes and means of personal data processing within the Platform.

Customers and Caregivers may be separate, independent data controllers to the extent that they process personal data outside the Platform, in particular in connection with direct contact, performance of care services, maintaining their own documentation, pursuing claims, tax settlements or fulfilling their own legal obligations.

Seeniorum is not liable for personal data processing carried out independently by Customers, Caregivers or third parties outside the Platform, in particular for:

a) unlawful provision of the Senior’s data by the Customer,

b) provision of false or outdated data by the Customer or Caregiver,

c) use of data by the Caregiver outside the Platform,

d) contact between the parties outside the Platform,

e) documentation, notes, photos, recordings or information created independently by the Caregiver or Customer outside Seeniorum tools,

f) privacy breaches committed by the Customer, Caregiver, Senior or third parties.

A person providing personal data of another person, in particular the Senior’s data, declares that they have an appropriate legal basis, consent, authorisation, legitimate interest or another legal title allowing such data to be provided to Seeniorum and the Caregiver.

A person providing personal data of another person undertakes to provide that person with information on the rules of data processing resulting from this Privacy Policy, unless such obligation does not apply under applicable law.

To the maximum extent permitted by law, Seeniorum is not liable for the consequences of personal data being provided by the Customer, Caregiver or third party without an appropriate legal basis.

IP address,

cookie identifiers,

device and browser data,

data on activity within the Service,

technical data stored in server logs,

approximate location resulting from the IP address,

analytical and marketing data, if the person visiting the Service has given appropriate consent.

first name and surname,

e-mail address,

telephone number,

Account login data,

billing data,

booking history,

payment history,

address or location of service provision,

preferences regarding the Caregiver,

content of messages sent through the Platform,

reviews, ratings, requests and complaints,

data concerning the selected Senior, if provided by the Customer,

other data voluntarily provided by the Customer.

first name and surname,

e-mail address,

telephone number,

Account login data,

profile photo,

video recording required in the Caregiver’s profile,

description of experience,

qualifications, certificates, courses, skills and specialisations,

declared availability,

rates and scope of services,

location of service provision,

data necessary to verify the profile,

data concerning settlements and payouts,

bank account number,

booking history,

post-visit reports,

Customer ratings and reviews,

data concerning complaints, disputes, blocks or breaches of the Terms and Conditions,

other data voluntarily provided by the Caregiver.

first name and surname,

age,

address or location of service provision,

telephone number, if provided,

organisational information concerning care,

information about needs, limitations, preferences, daily routine and expected scope of assistance,

information on health condition, mobility, medication, allergies, diseases, disabilities or other special needs, only if voluntarily provided and necessary for organising the service,

information included in post-visit reports,

other information provided by the Customer, Senior or Caregiver.

Data concerning health, disability, mobility limitations, medication, allergies or special needs of the Senior may constitute special categories of personal data.

The Controller processes such data only where it has been voluntarily provided and where it is necessary to organise the service, ensure the Senior’s safety, provide the Caregiver with relevant information or handle a request.

The Customer should provide only such Senior data as is genuinely necessary to perform the service. Seeniorum does not require the provision of excessive medical information or medical documentation, unless a specific Platform functionality expressly requires this and there is an appropriate legal basis.

Seeniorum is not a medical entity and does not maintain medical records of Seniors.

The Controller may conduct a Caregiver verification process in order to increase the security of the Platform, reduce the risk of abuse and enable Customers to make more informed decisions.

The scope of verification may include in particular:

a) confirmation of contact details,

b) analysis of information provided in the Caregiver form,

c) verification of the photo and video recording,

d) analysis of declared experience,

e) analysis of submitted certificates, confirmations, references or other documents, if voluntarily provided by the Caregiver,

f) assessment of the profile’s compliance with the Platform Terms and Conditions.

The Controller does not guarantee that the verification process will detect every false piece of information, every concealment, every risk or every circumstance concerning the Caregiver.

The status “Verified”, “Verified+” or a similar designation means only that the Caregiver has passed a verification process specified by Seeniorum on the basis of data available to the Controller at the time of verification. Such status does not constitute a guarantee of quality, safety, honesty, qualifications, experience, availability or proper performance of services by the Caregiver.

To the extent permitted by law, the Controller does not record or process data concerning criminal convictions or offences beyond the necessary scope permitted by law. If the processing of such data requires a specific legal basis, the Controller may refuse to accept the document, delete it or limit the scope of its processing.

The Caregiver is responsible for the truthfulness, completeness and timeliness of data, documents, declarations, photos and recordings provided during the registration and verification process.

Providing data is voluntary, but in many cases necessary to create an Account, use the Platform, make a booking, act as a Caregiver, make a payment, receive a payout or obtain a response to a request.

Failure to provide data required by the Platform may prevent the use of selected functions, conclusion of a contract, making a booking, payout of funds or Caregiver verification.

Providing excessive data, in particular detailed medical data of the Senior, should be limited to information genuinely necessary to organise the service.

directly from the data subject,

from the Customer who provides the Senior’s data,

from the Caregiver who provides information in the profile, report or communication,

from the content of requests, messages, forms and complaints,

from payment systems,

from the technical tools of the Platform,

from publicly available sources, where justified by verification, security, protection against abuse or pursuing claims,

from entities providing services to the Controller.

Personal data may be transferred to the following categories of recipients:

a) Caregivers – to the extent necessary to carry out the booking and service,

b) Customers – with regard to Caregiver data, profile, availability, reports and information on service performance,

c) Seniors – if contact with the Senior is necessary to perform the service,

d) hosting, server infrastructure and IT service providers, in particular Amazon Web Services,

e) payment system providers, payment operators and banks, in particular Stripe,

f) e-mail, newsletter and marketing communication tool providers, in particular MailerLite,

g) SMS and notification tool providers, in particular SMSAPI,

h) analytical tool providers, in particular Google Analytics, if the person visiting the Service has given appropriate consent,

i) advertising and marketing tool providers, if the person visiting the Service has given appropriate consent,

j) accounting offices, accountants, tax advisers, lawyers and debt collection entities,

k) entities handling complaints, security, fraud prevention and technical support,

l) public authorities, courts, prosecutors, the Police, tax authorities or other authorised entities, if required by law,

m) other entities where necessary for the performance of a contract, protection of the Controller’s rights or compliance with legal obligations.

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

Entities processing data on behalf of the Controller act on the basis of appropriate data processing agreements, where required by law.

Independent service providers such as Stripe, Amazon Web Services, MailerLite, SMSAPI or Google may in certain cases also act as independent data controllers. In such scope, they process data in accordance with their own terms and privacy policies.

The Customer acknowledges that making a booking requires the selected Caregiver to receive data necessary to perform the service, in particular contact details, address or location of service provision, scope of the service and information concerning the Senior.

The Caregiver acknowledges that their profile, photo, video recording, description, experience, availability, rates, ratings and other profile information may be visible to Customers and, in part, also publicly within the Service.

Seeniorum is not liable for further use of data by the Customer or Caregiver outside the Platform if that person acts as an independent data controller or processes data in breach of the Terms and Conditions or law.

It is prohibited to use data obtained from the Platform to bypass the Platform, contact outside the Platform in order to avoid commission, acquire Customers or Caregivers outside Seeniorum, conduct marketing activities without consent, spam, harass, profile, discriminate or perform other actions contrary to law.

The Customer is responsible for the legality, truthfulness, completeness and timeliness of data provided to the Platform, in particular Senior data.

The Caregiver is responsible for the legality, truthfulness, completeness and timeliness of data provided to the Platform, in particular profile data, videos, photos, qualifications, experience, certificates, availability, rates and reports.

The Senior or a person acting on their behalf is responsible for the truthfulness and completeness of information provided to the Customer, Caregiver or Seeniorum.

Seeniorum may delete, restrict visibility, block or suspend the processing of data, content, documents, photos, videos, reports or reviews if there is a suspicion of a breach of law, the Terms and Conditions, third-party rights, Platform security or the Controller’s interest.

To the maximum extent permitted by law, a person who has provided data unlawfully, false data, data of a third party without a legal basis or data infringing third-party rights shall be liable to the Controller for the consequences of such action.

Data is stored for the period necessary to achieve the purposes for which it was collected.

Account data is stored for the duration of the Account, and after its deletion for the period necessary to secure or pursue claims, comply with legal obligations, make settlements, prevent abuse and protect the Controller.

Data related to bookings, payments, reports, complaints and settlements may be stored until the expiry of limitation periods for claims and for the period required by tax and accounting regulations.

Data processed on the basis of consent is stored until consent is withdrawn, unless there is another basis for further processing.

Marketing data is stored until consent is withdrawn, an objection is lodged or the marketing purpose ceases.

Technical data and logs may be stored for the period necessary to ensure security, analytics, fraud detection and proper operation of the Platform.

Caregiver verification data is stored for the period necessary to conduct verification, handle the Account, protect against abuse, demonstrate the course of verification and pursue or defend claims.

The Controller may store a limited scope of data after Account deletion if this is necessary to:

a) comply with a legal obligation,

b) pursue or defend claims,

c) demonstrate the history of bookings, payments or complaints,

d) prevent abuse,

e) protect the rights of the Controller, Customers, Seniors or Caregivers.

the right of access to data,

the right to obtain a copy of data,

the right to rectify data,

the right to erase data,

the right to restrict processing,

the right to data portability,

the right to object to data processing,

the right to withdraw consent at any time,

the right to lodge a complaint with the President of the Personal Data Protection Office.

If data is processed on the basis of consent, consent may be withdrawn at any time.

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

Withdrawal of consent may prevent the use of certain Platform functions if the data covered by consent is necessary to provide a given service.

The data subject has the right to object to data processing based on the Controller’s legitimate interest.

The Controller may refuse to uphold the objection if there are compelling legitimate grounds for further processing of data overriding the interests, rights and freedoms of the data subject, or if the data is necessary for the establishment, exercise or defence of claims.

The Controller may use tools supporting the display, sorting, recommendation or filtering of Caregiver profiles, in particular by location, availability, ratings, price, experience or compatibility with Customer preferences.

Such activities may constitute profiling within the meaning of the GDPR, but they do not produce legal effects or similarly significant effects on the Customer or Caregiver based solely on automated decision-making.

The Controller does not guarantee that the order of displaying Caregivers, designations, filters, ratings, recommendations or search results will be objectively best, complete, up-to-date or appropriate for a specific Senior. They are an element of the Platform’s operation and are auxiliary in nature.

The Platform may use cookies and similar technologies, such as pixels, tags, device identifiers, local storage and session storage.

Cookies may be used in particular to:

a) ensure operation of the Platform,

b) maintain login sessions,

c) remember the settings of the person using the Platform,

d) support security,

e) keep statistics and analytics,

f) measure the effectiveness of marketing activities,

g) personalise content,

h) conduct remarketing, if the person visiting the Service has given appropriate consent.

The Platform may use the following categories of cookies:

a) necessary cookies – required for the proper operation of the Service,

b) analytical cookies – used to analyse use of the Platform,

c) functional cookies – remembering the preferences of the person using the Platform,

d) marketing cookies – used for advertising, remarketing and campaign measurement.

The Platform uses or may use Google Analytics, which makes it possible to analyse how the Service is used, the number of visits, traffic sources, behaviour of persons visiting the Service and the effectiveness of marketing activities.

Google Analytics may use cookies and similar technologies. Analytical data may include, in particular, IP address, device data, browser data, operating system, time of visit, visited subpages, source of entry to the website and interactions with the Service.

Necessary cookies may be used without the consent of the person visiting the Service if they are necessary for the operation of the Service or provision of a service requested by that person.

Analytical, marketing and other technically non-essential cookies will be used in accordance with applicable law, in particular after obtaining appropriate consent, where required.

The person visiting the Service may manage cookie consents using the cookie banner, privacy settings panel or browser settings.

Restricting or blocking certain cookies may affect the operation of selected Platform functions.

A detailed list of cookies, providers, purposes and retention periods should be available in the consent management panel or in a separate Cookie Policy.

The Platform may use external tools, in particular:

a) Amazon Web Services – hosting, server infrastructure, data storage, security and Platform maintenance,

b) Stripe – handling Customer payments, settlements, refunds, payouts and prevention of payment fraud,

c) MailerLite – handling newsletters, e-mail messages, mailing automations and marketing communication,

d) SMSAPI – handling SMS messages, codes, notifications and transactional communications,

e) Google Analytics – web analytics, statistics, traffic measurement and analysis of Platform use,

f) tools for handling forms, requests, complaints and technical support,

g) security tools, error monitoring and fraud protection,

h) tools for maps, location and searching services by place of care provision,

i) tools for storing files, photos, video recordings and reports.

External tool providers may process data as processors, independent controllers or joint controllers, depending on the nature of the given service.

Seeniorum is not liable for privacy policies, terms, practices or actions of independent external providers acting as independent data controllers.

To the extent that external providers act as processors processing data on behalf of the Controller, the Controller concludes appropriate data processing agreements with them, where required by law.

Data may be transferred outside the European Economic Area if the use of certain technical, analytical, marketing, hosting, communication or payment tools involves such transfer.

In particular, data transfers outside the European Economic Area may occur in connection with the use of services such as Amazon Web Services, Stripe, Google Analytics, MailerLite or other technology providers, if their infrastructure, subcontractors or data processing centres are located outside the European Economic Area.

In the event of data transfers outside the European Economic Area, the Controller applies mechanisms required by law, in particular adequacy decisions, standard contractual clauses or other instruments provided for under the GDPR.

If the person visiting the Service consents to the use of external tools, they acknowledge that some of these tools may involve the transfer of data outside the European Economic Area.

The Controller is not liable for data transfers carried out independently by external providers acting as independent data controllers, unless such liability results from mandatory provisions of law.

The Controller applies technical and organisational measures aimed at protecting personal data against accidental or unlawful destruction, loss, modification, unauthorised disclosure or access.

Security measures may include in particular:

a) access control to systems,

b) encryption of data transmission,

c) passwords and authentication mechanisms,

d) backups,

e) monitoring of technical events,

f) limiting access to data only to authorised persons,

g) data processing agreements with service providers,

h) incident response procedures.

The Controller does not guarantee complete data security in the case of events beyond the Controller’s control, in particular failures of external providers, cyberattacks, actions of third parties, force majeure, errors of the Customer or Caregiver, disclosure of login or password to a third party, or use of the Platform on an unsecured device.

The Customer and Caregiver are obliged to protect their login, password, device and access to their e-mail account. Seeniorum is not liable for the consequences of access data being disclosed to third parties by the Customer or Caregiver.

Passwords should be stored in a secured form in accordance with current technical standards.

The Customer and Caregiver should use a strong password, not disclose it to third parties and immediately inform the Controller of any suspected unauthorised access to the Account.

The Controller may temporarily block the Account if there is a suspicion of a security breach, Account takeover, abuse, bypassing the Platform or breach of the Terms and Conditions.

Reviews, ratings and reports should be lawful, truthful, factual and not infringe personal rights or the privacy of other persons.

It is prohibited to include in reviews, ratings and reports excessive data, data of third parties without a legal basis, special category data without justification, offensive, defamatory, discriminatory or unlawful content.

Seeniorum may moderate, delete, hide or restrict the visibility of reviews, ratings, reports or parts thereof if they violate law, the Terms and Conditions, good practices, third-party rights, Platform security or the Controller’s interest.

Seeniorum is not liable for the content of reviews, ratings and reports provided by Customers or Caregivers, unless such liability results from mandatory provisions of law.

The Caregiver acknowledges that the video recording may be an element of the Caregiver’s profile and may be used to increase profile credibility, present the Caregiver to Customers and support the Caregiver selection process.

The Caregiver should include in the recording only their own image and statements. It is prohibited to include in the recording the image, voice, personal data or information about third parties without an appropriate legal basis.

The Caregiver declares that they hold full rights to the submitted recording and that the recording does not infringe third-party rights.

The Controller may refuse to publish, delete or restrict the visibility of the video recording if it violates law, the Terms and Conditions, third-party rights, security rules or Platform standards.

The Platform is intended for adults.

The Controller does not direct services to children and does not intend to knowingly collect children’s data, unless this is necessary in connection with a specific request, legal obligation, family contact or another exceptional situation.

Minors should not create an Account or use the Platform without the required legal basis and consent of their legal representative.

The Platform may contain links to websites, applications, payment systems, social media profiles or external services.

Seeniorum is not responsible for the privacy rules, cookies, security, content, terms or actions of external websites, applications or providers acting outside the Controller’s control.

Before using an external service, the person using the Platform should read its privacy policy and terms.

Seeniorum may maintain profiles on social media, in particular on platforms such as Facebook, Instagram, LinkedIn, TikTok, YouTube or others.

Use of Seeniorum’s social media profiles may involve data processing by the operators of those portals in accordance with their own privacy policies.

Seeniorum is not liable for data processing by social media operators if they act as independent data controllers.

If a personal data breach is identified, the Controller takes actions required by law.

If the breach may result in a risk to the rights or freedoms of natural persons, the Controller will make appropriate notifications to the supervisory authority or data subjects in accordance with the GDPR.

The Customer, Caregiver or any other person using the Platform should immediately inform the Controller of any suspected Account security breach, unauthorised access, password loss, erroneous data disclosure or other incident.

To the maximum extent permitted by law, Seeniorum is not liable for:

a) provision by the Customer, Caregiver or third party of false, outdated, incomplete or unlawful data,

b) provision of Senior data without the required consent, authorisation or legal basis,

c) use of data by the Customer or Caregiver outside the Platform,

d) acts or omissions of independent Caregivers, Customers, Seniors or third parties,

e) consequences of contact between the Customer and the Caregiver outside the Platform,

f) content of messages, reports, reviews, ratings, recordings, photos, documents and declarations provided by Customers, Caregivers or third parties,

g) privacy breaches committed by the Customer, Caregiver, Senior or third party,

h) loss of confidentiality of data resulting from disclosure of a password, telephone, computer, e-mail account or Account access to third parties,

i) actions of external providers acting as independent data controllers,

j) failures, cyberattacks, technical interruptions, force majeure or other events beyond the Controller’s control.

No provision of this Privacy Policy excludes or limits the Controller’s liability to the extent that such exclusion or limitation would be impermissible under mandatory provisions of law.

The limitations of liability set out in this Privacy Policy should be interpreted to the broadest extent permitted by law.

The Controller may change the Privacy Policy in particular in the event of:

a) changes in law,

b) changes in Platform functionality,

c) changes in providers of technical, payment, analytical or marketing services,

d) changes in the scope of processed data,

e) changes in the Platform’s operating model,

f) the need to clarify security, privacy or liability rules.

The current version of the Privacy Policy is published in the Service.

In the case of material changes, the Controller may inform Customers and Caregivers through the Platform, by e-mail or through another available communication channel.