1. general information


PragmaGO SA attaches great importance to transparency in operations and respects everyone’s fundamental right to privacy. Ensuring the confidentiality of your data is a priority for us. We make every effort to ensure that the safeguards adopted guarantee the confidentiality and security of your data.

This Privacy Policy is intended to explain how we handle information about you. The phrases and expressions used in this Policy have the following meanings:

  • Personal data – within the meaning of Article 4(1) of the RODO, means any information about an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified directly or indirectly;
  • Processing – within the meaning of Article 4(2) of the RODO means an operation or set of operations performed on personal data or sets of personal data in an automated or non-automated manner, such as collection, recording, organizing, structuring, storing, adapting or modifying, retrieving, viewing, using, disclosing by transmission, dissemination or otherwise making available, matching or linking, limiting, erasing or destroying;
  • RODO – Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation);
  • Controller – within the meaning of Article 4(7) of the RODO, means the controller, i.e. the entity that alone or jointly with others determines the purposes and means of processing personal data. Whenever this Policy refers to the controller, it shall mean PragmaGO SA;

(2) We process personal data of our customers and potential customers for the following purposes and on the basis of the following legal grounds:


2.1 Before entering into a contract, we process your personal data for the following purposes:

TargetLegal basisProcessing period
To take action on your request, i.e. to respond to your inquiries, including for the presentation of individualized terms of cooperation, seeking to conclude a contract In the case of sole proprietors: Article 6(1)(b) of the RODO;
In the case of persons representing and authorized to contact on the part of a potential client: Article 6(1)(f) of the RODO (for the performance of actions taken to conclude a contract with the principal)
the time necessary to establish the terms and conditions of possible future cooperation, until a contract is concluded, or until negotiations for the conclusion of a contract are broken off;
in the case of persons representing and authorized to contact on the part of a potential customer, additionally until an effective objection is made to the processing of such data, whichever event occurs first
Take action at your request, in particular, necessary to process your application for a factoring agreement, assess your creditworthiness using publicly available sources (using automated data processing)In the case of sole proprietors: Article 6(1)(b) RODO
In the case of persons representing and authorized to contact a potential customer: Article 6(1)(f) RODO (for the performance of activities
the time necessary to decide whether to conclude a contract, until a contract is concluded, or until negotiations for the conclusion of a contract are broken off;
in the case of persons representing and authorized to contact on the part of a potential customer, additionally until an effective objection is made to the processing of such data, whichever event occurs first
sending commercial information, including direct marketing of our own products and services and those of the PragmaGO® Group for the purpose of realizing our legitimate interests, whereby conducting marketing contact by us is possible only on the basis of your additional consent to the use of automatic calling systems and telecommunication terminal equipment, i.e. telephone number and e – mail address for the purpose of direct marketing 6(1)(f) RODO;
Article 9 of the Law on Provision of Electronic Services,
Article 398 of the Law – Law of Electronic Communications.
until you object to marketing activities and until you withdraw your consent to receive marketing and information materials electronically, whichever event occurs first
to fulfill the legal obligations incumbent on the controller in the context of the personal data of the customer’s representatives and the customer’s beneficial owners. In particular, the controller, as an obligated institution, for the purpose of applying financial security measures, is authorized to process the information contained in the identity documents of the customer and the person authorized to act on his behalf, and to make copies of them, as well as to analyze transactions carried out in the framework of the customer’s business relations Article 6(1)(c) of the RODO in conjunction with Article 34 of the Anti-Money Laundering and Countering the Financing of Terrorism (AML) Law According to Article 49 of the Law of March 1, 2018 on anti-money laundering and countering the financing of terrorism – obliged institutions shall keep:
a) for a period of 5 years, counting from the date of termination of business relations with the customer or from the date of execution of an occasional transaction;
b) at the request of the GIIF for a further period not exceeding 5 years
Establish, assert or defend against possible claims that may be related to the contracting process, in particular in case of refusal to conclude a contract due to a negative result of a financing risk assessment – for the purpose of realizing our legitimate interests in the form of securing claimsArticle 6(1)(f) RODO for the period of the statute of limitations for claims under the Civil Code

2.2. W związku z zawarciem umowy przetwarzamy Państwa dane osobowe w celu:

TargetLegal basisProcessing period
implementation and performance of the contractIn the case of sole proprietors: Article 6(1)(b) of the RODO;
In the case of persons representing and authorized to contact on the part of a potential client: Article 6(1)(f) of the RODO (for the performance of actions taken to execute the concluded contract)
the duration of the contract;
in the case of representative persons on the customer’s side, additionally until the customer raises an effective objection to the processing of such data, whichever event occurs first;
in the case of authorized contact persons on the customer’s side, additionally until the customer raises an effective objection to the processing of such data or loses the authorization to act on the customer’s behalf, whichever event occurs first
The use of advanced AI tools through the use of ChatGPT, Freshworks, Albacross and Optimonk to improve the quality of services provided, improve communication with customers, including a significant reduction in the time it takes to answer questions, analyze data and plan marketing campaigns targeted to customers’ needs.Article 6(1)(f) RODO the duration of the contract;
until you raise an effective objection to the processing of such data, whichever event occurs first;
statistics and analysis – for the duration of the usefulness of the specific statement or until you raise an effective objection to the processing;


automated calling systems i.e. Freshworks tool for the purpose of automating marketing activities based on your consent,

for the purpose of improving the quality of services provided, improving communications, optimizing and automating processes and creating data analysis
use of transmission data such as: data on contacts undertaken with you, analysis of communications, reminders sent, documents sent) for billing purposes with you.
Article 398 of the Act – Electronic Communications Law

Article 6(1)(f) RODO
for the implementation of automated marketing activities until the revocation of consent;
for the purposes of improving the quality of services offered, improving communication automation and development of the process of optimizing services and the creation of data analysis until an effective objection to the processing of such data is raised,
statistics and analysis in anonymized form – for the duration of the usefulness of a particular statement
transmission data until the termination of claims by the service provider
fulfill the legal obligations of the administrator in connection with the obligation to verify the reservation of the PESEL number before concluding a contract with the customerArticle 6(1)(c) RODO in conjunction with Article 105d 1. Banking Law Until the duration of the contract or the statute of limitations on claims
to fulfill the legal obligations incumbent on the controller in the context of the personal data of the customer’s representatives and the customer’s beneficial owners. In particular, the controller, as an obligated institution, for the purpose of applying financial security measures, is authorized to process the information contained in the identity documents of the customer and the person authorized to act on his behalf, and to make copies of them, as well as to analyze transactions carried out in the framework of the customer’s business relations Article 6(1)(c) of the RODO in conjunction with Article 34 of the Anti-Money Laundering and Countering the Financing of Terrorism (AML) Law According to Article 49 of the Law of March 1, 2018 on anti-money laundering and countering the financing of terrorism – obliged institutions shall keep:
a) for a period of 5 years, counting from the date of termination of business relations with the customer or from the date of execution of an occasional transaction;
b) at the request of the GIIF for a further period not exceeding 5 years
Fulfillment of legal obligations incumbent on the administrator under accounting and tax laws in connection with the wording of these laws (financial reporting, tax reporting, GIIF)For sole proprietors: Article 6(1)(c) of the RODO in connection with the wording of tax and accounting laws for the time required by law (the Accounting Act and tax laws), i.e. for a period of 5 years counted from the end of the fiscal year in which the financial document was issued
Risk management and creditworthiness assessment, in particular assessing the risk of non-payment, late payment by recipients, including using automated data processingIn the case of sole proprietors: Article 6(1)(f) of the RODO (for the management of risks related to the financing and execution of the contract) duration
we process personal data of persons providing collateral for factoring agreements for the purpose of securing claims under factoring agreements, i.e. for purposes arising from our legitimate interestsArticle 6(1)(f) RODO for the period of execution of the contract and, in the case of updating a claim secured by a surety on the part of the person providing the surety, until the claim is satisfied
establish, assert or defend against possible claims that may be related to the performance of the contract-for the purpose of pursuing our legitimate interests in the form of securing claimsArticle 6(1)(f) RODO for the period of the statute of limitations for claims under the Civil Code
preparing and conducting compilations, analyses, statistics, reporting i.e. for internal administrative purposes, thus for the realization of the legitimate interest of the data controller in the form of risk analysis Article 6(1)(f) RODO for the time necessary to compile anonymized statistics and analyses or, in the case of non-anonymized statistics and analyses, for the usefulness of a particular compilation or until you raise an effective objection to the processing of your data
establish, assert or defend against possible claims that may be related to the performance of the contract-for the purpose of pursuing our legitimate interests in the form of securing claimsArticle 6(1)(f) RODO for the period of the statute of limitations for claims under the Civil Code
preparing and conducting compilations, analyses, statistics, reporting i.e. for internal administrative purposes, thus for the realization of the legitimate interest of the data controller in the form of risk analysis Article 6(1)(f) RODO pending objections
sending commercial information of our own products and services and those of entities of the PragmaGO® Group – for the realization of our legitimate interests in the form of conducting activities in the field of direct marketing of products and services, whereby conducting marketing contact by us is possible on the basis of your additional consent to the use of automatic calling systems and the use of telecommunication terminal devices: telephone number and e-mail address for contact for the purpose of sending commercial information , including direct marketing.Article 6(1)(f) of the RODO;
Article 9 of the Law on Provision of Electronic Services,
Article 398 of the Law – Law of Electronic Communication
until you make an effective objection to marketing activities or until you withdraw your consent to receive marketing and information materials electronically, whichever event occurs first

2.3 After the expiration of the contract, we also process your data for the following purposes:

TargetLegal basisProcessing period
Preparing and conducting compilations, analyses, statistics, reporting (internal administrative purposes), i.e. for the realization of our legitimate interests in the form of risk analysis Article 6(1)(f) RODO for the time necessary to compile anonymized statistics and analyses or, in the case of non-anonymized statistics and analyses, for the usefulness of a particular compilation or until you raise an effective objection to the processing of your data
to fulfill the legal obligations incumbent on the controller in the context of the personal data of the customer’s representatives and the customer’s beneficial owners. In particular, the controller, as an obligated institution, for the purpose of applying financial security measures, is authorized to process the information contained in the identity documents of the customer and the person authorized to act on his behalf, and to make copies of them, as well as to analyze transactions carried out in the framework of the customer’s business relations Article 6(1)(c) of the RODO in conjunction with Article 34 of the Anti-Money Laundering and Countering the Financing of Terrorism (AML) Law Pursuant to Article 49 of the Law of March 1, 2018 on Anti-Money Laundering and Countering the Financing of Terrorism – obliged institutions shall keep:
a) for a period of 5 years, counting from the date of termination of business relations with the customer or from the date of execution of an occasional transaction;
b) at the request of the GIIF for a further period not exceeding 5 years.
sending commercial information of our own products and services and those of entities of the PragmaGO® Group – for the realization of our legitimate interests in the form of carrying out activities in the field of direct marketing of products and services, whereby conducting marketing contact by us is possible on the basis of consent granted by you for the use of transmission data, automatic calling systems and the use of telecommunication terminal devices: telephone number and e-mail address for contact for marketing purposes6(1)(f) RODO;
Article 9 of the Law on Provision of Electronic Services,
Article 398 of the Law – Law of Electronic Communications.
until you object to marketing activities or withdraw your consent to receive marketing and information materials electronically, whichever event occurs first

TargetLegal basisProcessing period
responding to an inquiry directed by you using the contact information provided by Zadarma, or via the contact form located on pragmago.plrealization of our legitimate interest in the form of responding to an inquiry addressed to us, thus on the basis of Article 6 (1) (f) RODO d until your question is answered or you successfully object to the processing of your personal data
to conduct marketing of our own products and services using the data obtained through the contact form, whereby for the use of telecommunications terminal equipment for the communication channels provided by you, we need your consent.realization of our legitimate interest in the form of conducting direct marketing activities of our own products and services, thus Article 6(1)(f) of the RODO,
Article 398 of the Electronic Communications Act
until you make an effective objection to marketing activities or withdraw your consent to receive marketing and information materials electronically, whichever event occurs first
creation of analyses, statistics and compilations that will serve to improve the effectiveness of our marketing activities and build our business strategy – the vast majority of such statistics are created on the basis of non-personal data or anonymized data. In some cases, personal data collected through cookies may be used where personal data will be used for this purpose, their processing will be based on the necessity of realizing our legitimate interest in the form of carrying out analytical and statistical activities aimed at the development of the PragmaGO® Group, thus on the basis of Article 6(1)(f) RODO until an effective objection is raised
establish, assert or defend against possible claims that may arise in connection with your use of the site or in connection with the distribution of marketing and information materials realization of our legitimate interest in the form of securing claims, thus on the basis of Article 6(1)(f) RODO for the period of time prescribed by law for the limitation of claims

In addition, due to the wording of the judgment of the Court of Justice of the European Union of July 29, 2019. (Fashion ID GmbH & Co.KG v. Verbraucherzentrale NRW eV, reference C-40/17) PragmaGO SA informs that Facebook is the co-administrator of the personal data of people using the Facebook plug-in posted on PragmaGO SA.

PragmaGO SA, as part of its cooperation with Facebook, partly obtains personal data directly from PragmaGO SA users, and partly from users’ profiles on the Facebook social network.

  • To the extent that PragmaGO SA obtains data directly from users, the provision of personal data is completely voluntary, and failure to provide such data has no effect on the user. The user can use the PragmaGO SA website without providing any personal data and remaining anonymous at all times (in a situation where the user only browses the PragmaGO SA website, without interacting with the Facebook plug-in).
  • To the extent that PragmaGO SA obtains user data from user profiles on the Facebook social network, user data will be disclosed in the form of anonymous statistical summaries prepared by Facebook.
TargetLegal basisProcessing period
creation of analyses, statistics and compilations that will serve to improve the effectiveness of our marketing activities and build our business strategy – the vast majority of such statistics are created on the basis of non-personal data or anonymized data. In some cases, personal data collected through cookies may be used where personal data will be used for this purpose, their processing will be based on the necessity of realizing our legitimate interest in the form of carrying out analytical and statistical activities aimed at the development of the PragmaGO® Group, thus on the basis of Article 6(1)(f) RODO until an effective objection is raised

PragmaGO SA also informs that in connection with the operation of the Facebook social network, user profiling may occur, i.e. the creation of a profile containing information about the user’s interests or certain characteristics. Some functions provided by Facebook allow compiling personal data of users and creating statistics and summaries from them, which PragmaGO SA may later use in order to adjust the content provided to users accordingly. At the same time, we would like to inform you that decisions based on the profiles created will not be made in an automated manner.

4 What data do we obtain in the operation of the site and how do we use it?


We may collect data pertaining to you by means of forms posted on pragmago.pl and by storing cookies (so-called “cookies”) in your terminal devices, as well as by collecting web server logs by the web hosting operator PragmaGO.tech Sp. z o.o. operating at https://pragmago.tech. We may also obtain your personal information if you write through Zadarma, or by using the contact information provided on our website and this Privacy Policy.

5 Who can access your data?


PragmaGO SA shares your personal data with: business partners, entities providing IT, postal, courier, HR and payroll, marketing, legal, archiving, accounting services. Recipients of your personal data may be other PragmaGO Group companies: Brutto sp. z o.o., Pragma Faktor Sp. z o.o., Monevia sp. z o.o., as well as entities to which we subcontract tasks requiring processing of personal data in the field of IT services (PragmaGO.tech sp. z o.o., StrongPC) and legal services (Pragma Adwokaci Bukowska Celary Feder Sp. k, Kancelaria Radców Prawnych Wysocki Zawiejski Sp. p.), as well as companies providing information on payment credibility (Biuro Informacji Kredytowej SA, Biuro Informacji Gospodarczej InfoMonitor SA), entities providing services of access to information concerning you (in terms of obtaining information and history of operations for the indicated bank accounts – Kontomatik UAB with its seat in Vilnius and Kontomatik Sp. z o.o.), providing identity verification tools (Autopay SA), Internet payment operators – (PayPro S.A.) or insurance service providers (Euler Hermes SA, KUKE S.A.) or providers of tools to track your activity – Albacross Nordic AB) you will find more about Albacross processing at the link https://www.optimonk.hu/adatkezelesi-tajekoztato-az-optimonk-alkalmazassal-kapcsolatban/ and providers of tools to optimize customer service, communication, marketing automation using modern tools with AI, these include: OptiMonk https://www.optimonk.hu/adatkezelesi-tajekoztato-az-optimonk-alkalmazassal-kapcsolatban/, Freshworks https://www.freshworks.com/privacy/ PragmaGO SA informs you about the exact identity of the recipients in specific information clauses addressed to you in connection with the services you use.

Your data may also be transferred to entities authorized to access them in accordance with generally applicable laws (e.g. the police).

Recipients of the data may be located in a country outside the European Economic Area (EEA), in which case, however, the Administrator will ensure that an adequate level of safeguards is in place so as to protect the data subject. The transfer of data to countries outside the EEA may be related to, for example.

  • actions taken on social networks and the use of plug-ins and other tools from these sites (including Facebook, Twitter, Linkedin, YouTube),
  • Using analytical and anonymized user behavior tracking tools, in particular, such as Google Analytics, Lucky Orange.

6 Voluntariness of providing data


Provision of your personal data may be a contractual requirement (i.e. necessary to enter into an agreement with PragmaGO SA or to establish and implement cooperation), may be a statutory requirement (i.e. necessary to implement legal obligations, such as those under the Anti-Money Laundering and Countering the Financing of Terrorism (AML) Act). If you do not provide the required personal data, it may not be possible or will be very difficult to start cooperation with you.

For the rest, your provision of personal data is voluntary, failure to do so may prevent the fulfillment of the above purposes, in particular, contact with you.

7 What rights do you have in relation to data processing?


  • The right to access the content of your data – Article 15 RODO. As a data subject, you may request access to information about data processing and a copy of your data.
  • Right to rectification of data – Article 16 RODO. As a data subject, you may request that your data be corrected or updated.
  • Right to erasure – Article 17 of the RODO. As a person whose data is processed, you may request deletion of your data in situations provided by law. The deletion will not be possible, among other things, in the situation of a claim, or during the period when PragmaGO® is obliged to process the data due to, for example, tax regulations.
  • Right to Restrict Processing of Data – Article 18 RODO. As a data subject, you may request the suspension of data operations under the conditions and for the time provided by law.
  • Right to data portability – Article 20 RODO. As a data subject, you may request that your data be transferred to another specifically designated Controller.
  • The right to object to the processing of your data – Article 21 RODO. As a person whose data is processed, you may object to the processing of your data at any time. PragmaGO SA, as the Administrator, after considering the request, may refuse to exercise the right, if there are legal grounds for processing the data and they override the interests of the requester, or in cases where by law you are not entitled to object to the processing of personal data.
  • The right to withdraw consent previously given for the processing of data for marketing purposes and for a specific contact path, however, withdrawal of consent does not affect the validity and lawfulness of processing performed before withdrawal of consent.
  • The right to lodge a complaint with the President of the Office for Personal Data Protection if you consider that the processing of your Personal Data violates the provisions of the RODO.

8 Automated decision-making


PragmaGO SA, as a Data Controller, makes partially automated decisions that have an effect on you as a data subject in the case of creditworthiness assessment, credit risk, risk management, including the risk of late repayment.

Evaluation of financial capacity for the purpose of concluding a contract – is carried out on the basis of information provided by you in the application for concluding a contract and financial documents, and is carried out on the basis of a set of rules and algorithms necessary for examining creditworthiness. Data is also obtained from publicly available sources, such as CEIDG, business information offices, BIK. Among other things, the following are taken into account:

  • amount of financial commitment,
  • payment culture,
  • period of operation,
  • Debt in other financial institutions.

The effect of assessing financial capability by automated means is to issue a decision regarding consent to enter into a contract, the terms of a contract, changes to the scope of a contract based on an assessment of payment culture, or refusal to enter into a contract. We do not use profiling, i.e. final decisions are made by our employees.

9. Information system


10. source of data – the information applies to personal data obtained by means other than from the data subject


Your personal data may come from an entrepreneur with whom you have a contractual relationship or in relation to whom you are a beneficial owner, a statutory representative, a principal in the case of a power of attorney granted, another party to a contract with the Company, and from publicly available sources, in particular, databases and registers: PESEL, National Court Register (KRS), Central Register and Information on Business Activity (CEIDG), REGON, Register of Personal Identity Cards, BIK, CEIDG, business information bureau.

11. information about cookies


  1. Cookies (so-called “cookies”) are IT data, in particular text files, which are stored on the website user’s terminal equipment and are intended for use on the website. Cookies usually contain the name of the website they come from, the time they are stored on the end device and a unique number.
  2. The entity placing cookies on the website user’s end device and accessing them is the website operator, indicated in point 9 of this Privacy Policy.
  3. All domains of the PragmaGO website use cookies, which allow us to personalize the display of the website’s pages, handle logins and other website operations, as well as handle advertisements and monitor the activity of website users. Thanks to this technology, we are also able to constantly work on improving the quality of our service.
  4. PragmaGO uses the CookieYes tool to manage user consents.
  5. The site uses two main types of cookies: “session” (session cookies) and “permanent” (persistent cookies). “Session” cookies are temporary files that are stored on the user’s terminal device until the user logs out, leaves the website or shuts down the software (web browser). “Permanent” cookies are stored on the User’s end device for the time specified in the parameters of the cookies or until the User deletes them.
  6. Cookies used by the service, we divide into:
    • Essential: they are critical to the basic functions of the site and the site will not function as intended without them. These cookies do not store any personally identifiable information.
    • Functional: Functional cookies help perform certain functions, such as sharing site content on social media platforms, collecting feedback and other third-party functions.
    • Analytical: Analytical cookies are used to understand how users interact with the site. These cookies help provide information on metrics of number of visitors, rejection rate, source of traffic, etc.
    • Performance: Performance cookies are used to understand and analyze key performance indicators of the site to help provide a better user experience for visitors.
    • Advertising: Advertising cookies are used to deliver personalized ads to users based on the pages they have previously visited and to analyze the effectiveness of the advertising campaign.
    • Uncategorized: Other Uncategorized cookies are those that are analyzed and not yet classified in any category.
  7. An overview of the service domains that use cookies:
    • pragmago.pl
    • online.pragmago.pl
    • partner.pragmago.pl
    • app.pragmago.pl
    • pragmago.com

12. server logs


  1. Information about some retained users is subject to logging in the server layer. This data is used solely for the purpose of administering the site and to ensure the most efficient operation of the hosting services provided.
  2. The resources viewed are identified by URLs. In addition, the record may be subject to:
    • time of arrival of inquiry,
    • time to send a response,
    • the name of the client’s station – identification carried out by the HTTPS protocol,
    • information about the errors that occurred during the execution of HTTPS transactions,
    • URL address of the page previously visited by the user (referer link) – in case the access to the Website was through a link,
    • information about the user’s browser,
    • IP address information.
  3. The above data is not associated with specific browsers.
  4. The above data is used only for server administration purposes.

13. cookie management


The user, using the functions offered by our website, can make choices about the use of particular categories of cookies – giving informed and voluntary consent in this regard. In addition, the user can change these settings at any time using the tools provided for this purpose.

In relation to personal data collected through cookie technology, you have the rights indicated in the section “What rights do you have in relation to data processing?”.

You may also, in addition to the website’s consent handling function, block the placement of cookies on your device at any time, you may then need to manually adjust some preferences each time you visit the website. This may also affect the functioning of our website or even block it.

You can also delete all cookies that are already on your device by clearing your browser’s browsing history. This will delete all cookies from all sites visited. Note, however, that the User may also lose some stored information (e.g. saved login data, site preferences).

Most browsers allow you to view and manage, block and delete cookies on websites. While you can manage your own cookie permissions, you must remember that by deleting cookies, all preferences you have set may be lost, including the ability to opt out of cookies.