VortexVR Application Privacy Policy

Last updated: September 21, 2026

1. General information

This privacy policy applies to the VortexVR application (hereinafter: the Application), which enables analysis, monitoring, and management of advertising campaigns in the Google Ads system on behalf of Vortex Consulting Przemysław Daniel Wardzynski (hereinafter: the Operator or Administrator).

2. Data controller

The controller of personal data processed in connection with the use of the Application is:

Vortex Consulting Przemysław Daniel Wardzynski
ul. Paczkowska 42, 04-693 Warszawa, Poland
Tax ID (NIP): 5262261767
Business registry (REGON): 386084236
Email: support@vortexvr.pl
Phone: (+48) 516 530 153

3. Scope and purpose of data processing

The Application accesses data from the Google Ads system for the following purposes:

1. Analysis of the effectiveness of advertising campaigns running on Google Ads accounts owned by the Operator and accounts to which the Operator has obtained authorized access;
2. Optimization of campaign structure, budgets, bidding strategies, and product feeds;
3. Automation of analytical and reporting tasks;
4. Generation of internal reports for the purpose of conducting the Operator's e-commerce activities.

The Application does not collect personal data of natural persons other than users authorizing access to Google Ads accounts. The Application does not use data for marketing purposes and does not share it with third parties.

4. Legal basis for processing

The legal basis for data processing is:

• Art. 6(1)(b) GDPR, processing is necessary for the performance of a contract or to take steps at the request of the data subject;
• Art. 6(1)(f) GDPR, the legitimate interest of the Administrator related to conducting and optimizing business activities.

5. Data recipients

Data processed by the Application may be shared with the following categories of recipients:

1. Google LLC and Google Ireland Limited, as the operator of the Google Ads system;
2. Authorized employees, associates, and subcontractors of the Operator, to the extent necessary for the execution of analytical tasks;
3. State authorities, if required by law.

Data is not transferred outside the European Economic Area, except for transfers resulting from the use of Google services, which take place on the basis of the European Commission's standard contractual clauses.

6. Data retention period

Data is processed for a period:

1. Necessary for the fulfillment of the purposes for which it was collected;
2. Required by law (e.g., accounting and bookkeeping regulations);
3. Not longer than the duration of authorization to access the Google Ads account.

After the processing period ends, data is deleted or anonymized.

7. User rights

Persons whose data is processed have the right to:

1. Access their data;
2. Rectify their data;
3. Erase their data;
4. Restrict processing;
5. Data portability;
6. Object to processing;
7. Withdraw consent at any time, if processing is based on consent;
8. Lodge a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warszawa, Poland).

8. Data security

The Application applies technical and organizational security measures to protect personal data being processed against unauthorized access, loss, destruction, or modification, including:

1. Encryption of data transmission (SSL/TLS);
2. Two-factor authentication for access to administrative systems;
3. Regular backups and software updates;
4. Restricting access to data to authorized persons only.

9. Use of Google Ads API

The Application uses the Google Ads API in accordance with the terms set out by Google in:

1. Google API Services User Data Policy: https://developers.google.com/terms/api-services-user-data-policy
2. Google Ads API Terms of Service: https://developers.google.com/google-ads/api/docs/policy

The Application uses access to the Google Ads API solely for the purposes described in point 3 of this policy. Data obtained from the Google Ads API is not used to train artificial intelligence models and is not shared with third parties without the express consent of the Administrator.

10. Changes to the privacy policy

The Administrator reserves the right to make changes to this privacy policy. Users will be informed of any changes by publishing a new version on the website.

11. Contact

For questions regarding this privacy policy or the manner of processing personal data, please contact us at:

Email: support@vortexvr.pl
Phone: (+48) 516 530 153
Address: Vortex Consulting Przemysław Daniel Wardzynski, ul. Paczkowska 42, 04-693 Warszawa, Poland