Privacy Policy

Version 2 of 12 October 2026

This is a translation; the Polish version prevails.

1. Who the controller is

The controller of the data described in this policy is LURIP Michał Kozioł, a sole trader entered in the Polish Central Register and Information on Economic Activity (CEIDG), ul. Zabierzowska 23P/1, 32-005 Niepołomice, Poland, tax identification number (NIP) 6832154544. Matters concerning personal data can be addressed by e-mail to [email protected] or by post to LURIP’s address. LURIP has not appointed a data protection officer.

2. The two roles of LURIP

1. LURIP as controller. LURIP decides on the processing of data of persons who create accounts in Loftsplit, of Customers, of visitors to loftsplit.com and of persons who write to LURIP. The rest of this policy concerns that data.
2. LURIP as processor. Data that a property owner enters into their Organisation in Loftsplit (tenant data, contracts, readings, payments, settlements) is processed by the owner as controller, and LURIP processes it only on the owner’s behalf, under the data processing agreement. A tenant who wishes to exercise their rights should contact the owner of the property. If such a request reaches LURIP, LURIP will pass it on to the owner and help the owner fulfil it. In the same way, LURIP sends e-mails to tenants on the Customer’s behalf (settlements, reminders, links to the portal) and keeps a log of their sending. The counters of tenant portal login attempts and the protection of traffic by Cloudflare are security measures that LURIP applies as processor (Article 32 GDPR).

3. Purposes, legal bases and periods of processing

Loftsplit account and provision of the service

• Data: full name, e-mail address, password hash (bcrypt; LURIP does not know passwords), language, date of last login, membership of Organisations and role, two-step login settings (encrypted key and hashes of backup codes). The data is provided by the User; LURIP receives the e-mail address and role of a person invited to an Organisation from the Owner who sends the invitation.
• Purpose and legal basis: conclusion and performance of the contract with the Customer (Article 6(1)(b) GDPR). Where a User acts on behalf of the Customer, for example as an employee or an accounting firm, the legal basis is the legitimate interest of the Customer and LURIP in performing the contract (Article 6(1)(f) GDPR).
• Period: until the User deletes the account (the account is deleted immediately) or until deletion of the last Organisation to which the account has access.

Subscription, invoices and payments

• Data: Organisation data (name, country), calculated subscription fees, e-mail addresses of Owners, customer, subscription and transaction identifiers and invoice numbers, which Paddle assigns, and Paddle’s payment notifications (they may contain an e-mail address and invoice data).
• Purpose and legal basis: calculating fees and handling payments (Article 6(1)(b) GDPR), tax and accounting obligations (Article 6(1)(c) GDPR), pursuing claims for payment (Article 6(1)(f) GDPR). The subscription is sold and invoiced by Paddle, which processes payment data and invoice data as a separate controller under its own privacy policy.
• Period: fees for 5 years from the end of the year in which they were calculated, after which they are deleted automatically; notifications sent by Paddle about payments for 30 days after they are processed; data for pursuing claims until the limitation period expires.

Security and accountability

• Data: history of data changes in the Organisation (who, when, and the values before and after the change), a log of LURIP staff actions in the operator panel, hashes of e-mail addresses and IP addresses in the counters of login and registration attempts.
• Purpose and legal basis: protecting accounts against takeover, detecting abuse and demonstrating who made a change (Article 6(1)(f) GDPR and, for entrusted data, also Article 32 GDPR).
• Period: login attempt counters are deleted after one hour; the change history exists as long as the Organisation, and when a tenant is anonymised, the tenant’s data is removed from it. One-time links (invitations, password reset, portal login) are deleted one day after use or expiry. The log of LURIP staff actions is kept for as long as LURIP provides the Loftsplit services.

E-mails sent by Loftsplit

• Data: recipient address, subject, delivery status and number of attempts; the content of the message until it is sent.
• Purpose and legal basis: delivering messages requested by the User or the Customer (invitations, password reset, order confirmations, subscription reminders) and investigating delivery problems (Article 6(1)(b) and (f) GDPR). Messages to tenants are described in section 2(2).
• Period: the content is deleted once sending is complete, the address and subject after 30 days.

Correspondence with LURIP

• Data: e-mail address, full name and other data given in a message sent to addresses in the loftsplit.com domain (e.g. hello@, support@, rodo@, faktury@).
• Purpose and legal basis: replying to and handling the matter, including technical support and applications for the pilot (Article 6(1)(f) GDPR), and, for requests concerning personal data, a legal obligation (Article 6(1)(c) GDPR).
• Period: for the time needed to handle the matter, and then until the limitation period for any claims expires.

Reports from the panel

• Data: the content of the report (a problem, suggestion or question), the attached file or screenshot, the panel page from which the report was sent, the panel version, the browser (User-Agent), the window size, the language, the author and the Organisation, as well as the LURIP staff note and the reply to the report.
• Purpose and legal basis: handling the report and improving the Application (Article 6(1)(f) GDPR). The report goes to the operator panel and by e-mail to LURIP’s technical support mailbox. A screenshot may show tenant data; LURIP processes that data on the Customer’s behalf, under the data processing agreement. Before sending, the panel warns about this and asks the User to cover data that LURIP does not need.
• Period: until the Organisation is deleted; after the account is deleted, the report remains without the author’s data. The copy in the technical support mailbox is kept like correspondence with LURIP.

The loftsplit.com website

• The website does not use analytics or tracking tools and does not load resources from other services. The loftsplit.com coming-soon page sets one cookie, lang, with the language chosen with the switch (section 7); the full website does not set cookies. The utility bill split calculator does all calculations in the browser; the data entered is not sent to LURIP.
• The website hosting provider (Cloudflare) processes the IP address and technical request data in order to deliver the website and protect it against attacks (Article 6(1)(f) GDPR). LURIP does not record this data.

Verification of the sign-up and password reset forms

• The account sign-up and password reset forms in the Application are protected by Cloudflare Turnstile, which tells people apart from programs that submit forms automatically. Cloudflare processes the IP address and browser signals of the person filling in the form, and the Loftsplit server passes a one-time token and the IP address to Cloudflare for checking; the content of the form is not sent to Cloudflare.
• Purpose and legal basis: protecting accounts and the Application against abuse (Article 6(1)(f) GDPR).
• Period: LURIP does not keep the result of the verification; Cloudflare processes the data under its own privacy policy.

Social media profiles

When someone follows the Loftsplit profile or writes to it on a social media service, LURIP processes their profile name and the content of the message in order to reply and run the profile (Article 6(1)(f) GDPR). LURIP keeps message data for the time needed to handle the message, and the profile names of followers for as long as they follow the profile. The operator of the service is responsible for the data collected by the service itself, under its own privacy policy.

4. To whom LURIP discloses data

LURIP discloses data only where this is needed for the purposes described above. During the pilot, the Application servers, database and backups run on LURIP’s own hardware in Poland; when the Application moves to the Scaleway cloud (Paris), LURIP will update this list.

Data may be disclosed to public authorities where an obligation arises from the law.

5. Transfers of data outside the European Economic Area

Application data is stored in Poland. Application traffic passes through the Cloudflare network. Cloudflare may process data in the United States. The basis for the transfer is the European Commission’s decision on the EU–US Data Privacy Framework, in which Cloudflare participates, and, additionally, the standard contractual clauses approved by the Commission. Paddle processes data in the United Kingdom, for which the European Commission has found an adequate level of data protection; Paddle describes onward transfers in its privacy policy. A copy of the safeguards can be obtained by writing to [email protected].

6. Rights of data subjects

Every person has the right to:

• access their data and obtain a copy of it;
• rectification of the data;
• erasure of the data;
• restriction of processing;
• portability of data processed on the basis of a contract;
• object to processing based on legitimate interest;
• lodge a complaint with the President of the Personal Data Protection Office (Prezes UODO, ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl).

Right to object. Where LURIP processes data on the basis of legitimate interest (Article 6(1)(f) GDPR), anyone may object at any time, on grounds relating to their particular situation, by writing to [email protected]. LURIP then stops processing that data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of that person, or grounds for the establishment, exercise or defence of legal claims.

A User exercises some of these rights directly in the Application: changing their name, language and password, exporting the Organisation’s data and deleting the account on the “Account” page. Other requests can be sent to [email protected]; LURIP responds within one month.

Providing data at registration is voluntary, but an account cannot be created without it. LURIP does not make decisions based solely on automated processing and does not profile Users.

7. Cookies and browser storage

The Application does not set cookies. The loftsplit.com coming-soon page sets one cookie, lang, only when a visitor chooses a language with the switch; it keeps the chosen language for a year so that the page opens in that language. The full loftsplit.com website does not set cookies. The Application stores in browser storage (localStorage and sessionStorage) only information needed for it to work, as requested by the User or the Tenant:

The Cloudflare Turnstile widget on the sign-up and password reset forms works under Cloudflare’s terms (section 3). On the payment pages, the Application loads Paddle’s script from Paddle’s servers (cdn.paddle.com), which opens the payment window; Paddle processes the IP address and the data entered in that window as a separate controller (section 3) and may store its own information needed for the payment in the browser. Storing the information described in the table is necessary to provide the service requested by the User or the Tenant, and storing the lang cookie is necessary to show the page in the language the visitor chose, so it does not require consent (Article 399(3)(2) of the Electronic Communications Law of 12 July 2024 (ustawa – Prawo komunikacji elektronicznej), Journal of Laws (Dz.U.) 2024, item 1221). It can be deleted in the browser settings; the User then has to log in again.

8. Security

The main safeguards are: encrypted connections (TLS), separation of Organisation data in the database (Row Level Security), passwords stored as a bcrypt hash and checked against a list of breached passwords, two-step login, a history of data changes, logs without personal data, daily encrypted backups and servers in Poland. The full description is in the data processing agreement.

9. Changes to the policy

LURIP informs Users of changes that concern them by e-mail or in the Application. The date of the current version is given at the top of this page.