Cookie Policy

§1. What are cookies?

1. Cookies are small text files saved on the User's device (computer, smartphone, tablet) by the web browser while using a website.
2. Cookies may be session cookies (deleted when the browser is closed) or persistent cookies (stored for a defined period or until manually deleted).
3. In addition to cookies, the website may use similar technologies such as local storage, session storage, tracking pixels and web beacons.

§2. Cookie controller

1. The controller of the first-party cookies set by vougly.app is Windify Digital Services, with its registered office at ul. Płocka 127/16, 87-800 Włocławek, NIP: 8943145650, REGON: 384382857.
2. The Website may also use third-party cookies, installed by external service providers listed in this Policy, solely after the relevant consent has been given.
3. Contact regarding cookies and privacy: hello@vougly.app.

§3. Categories of cookies

The Website uses the following categories of cookies:

Strictly necessary (always active)

Required for the proper functioning of the Website. Their use does not require the User's consent pursuant to art. 173(3) of the Telecommunications Law Act (they are necessary to provide the service). They include:

• Cookie banner preferences, recording the User's choice to accept or reject cookies (the vougly-cookies key in local storage).
• Theme preference (light / dark), recording the selected interface theme (the theme key in local storage).
• Cloudflare (infrastructure, bot protection), the __cf_bm and similar files, set by Cloudflare, the provider of hosting (Cloudflare Pages), CDN as well as protection against bots and DDoS attacks for the vougly.app domain. Provider: Cloudflare, Inc. (USA).

Analytics (optional, with consent)

Used to collect anonymised statistical data about how the Website is used (number of visits, traffic sources, time spent on the site). Installed solely after the User has given consent via the cookie banner. They help us improve our content.

• Google Analytics 4 (identifier G-H319FJRQ28), an analytics tool provided by Google LLC. It measures traffic on the Website, sources of visits and interactions with the site. It sets the _ga, _ga_H319FJRQ28 cookies. We apply Google Consent Mode v2; until consent is given in the cookie banner, the Google Analytics script is loaded in denied mode (analytics_storage: denied) and does not store any identifiers or analytics data. In addition, IP address anonymisation is enabled (anonymize_ip: true).

Performance cookies

Cookies used to measure the Website's performance, loading times and any technical errors. They may be set by the CDN provider (Cloudflare beacon), optionally, in accordance with the User's choice in the cookie banner.

§4. Detailed list of cookies

This list is provided for information purposes. Analytics cookies (Google Analytics 4) are installed solely after the User has given consent in the cookie banner. Should the Controller in the future deploy marketing tools (e.g. Meta or TikTok conversion pixels) or other analytics services, this Policy will be updated accordingly.

§5. Legal basis

1. The rules for storing and accessing cookies on the User's device are governed by art. 173 and 174 of the Act of 16 July 2004, the Telecommunications Law, implementing art. 5(3) of Directive 2002/58/EC (the ePrivacy Directive).
2. Strictly necessary cookies, processed on the basis of art. 173(3) of the Telecommunications Law (necessary to provide the service requested by the User) and art. 6(1)(f) GDPR (the Controller's legitimate interest). They do not require consent.
3. Analytics and marketing cookies, processed solely on the basis of the User's prior, freely given, specific, informed and unambiguous consent (art. 173(2) of the Telecommunications Law and art. 6(1)(a) GDPR), given via the cookie banner displayed on the first visit to the Website. These cookies are not installed before consent is given.
4. The User may withdraw or change their consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

§6. Transfers of data outside the EEA

1. Transfers of data to the USA take place on the basis of the EU-US Data Privacy Framework (European Commission decision of 10 July 2023) or standard contractual clauses (SCCs).
2. The Controller uses only providers that ensure an adequate level of protection of personal data in accordance with the requirements of the GDPR.

§7. The mobile application, data instead of cookies

The Vougly application (iOS / Android) does not use classic cookies, as it does not run in a browser. Instead, the Application processes a limited set of technical data:

• Application installation identifier, an internal, proprietary identifier generated by the Application after installation. It allows the device to be recognised in order to maintain a session and to detect abuse.
• Push notification token, issued by Apple Push Notifications (APNs) or Firebase Cloud Messaging (FCM) and passed to the Controller in order to send transactional notifications.
• Diagnostic logs, information about Application errors and its performance, used to maintain stability.

The Application does not use advertising device identifiers (IDFA on iOS, GAID on Android) for marketing purposes. The Application does not share the User's data with advertising networks or data brokers. Detailed information about the processing of data in the Application can be found in the Privacy Policy.

§8. Managing cookies

1. On the first visit to the Website, a cookie banner is displayed, which allows the User to:

   • accept all cookies ("Accept");
   • reject optional cookies and accept only the strictly necessary ones ("Strictly necessary only").
2. Before the User gives consent, no optional cookies are installed. Analytics and marketing scripts are launched only after consent has been given.

3. To display the banner again and change the choice, simply clear the Vougly cookie preferences:

   • open the developer tools console in your browser (usually the F12 or ⌥⌘I shortcut);
   • in the Console tab enter: localStorage.removeItem('vougly-cookies'); location.reload();
   • the banner will be displayed again and a new choice can be made.

   Alternatively, clear the vougly.app site data in your browser's privacy settings; the effect will be the same.

4. Cookies can also be managed at the browser level:

   • Chrome: Settings → Privacy and security → Cookies
   • Firefox: Settings → Privacy & Security → Cookies
   • Safari: Preferences → Privacy → Manage Website Data
   • Edge: Settings → Privacy and services → Cookies
5. Deleting cookies may result in the loss of certain settings and preferences and the need to give consent again.
6. Blocking strictly necessary cookies may prevent the Website from functioning properly.

§9. The User's rights

In connection with the processing of data through cookies, the User has the following rights under the GDPR:

• Right of access, to obtain information about the data processed (art. 15 GDPR).
• Right to rectification, to correct inaccurate data (art. 16 GDPR).
• Right to erasure, to request the deletion of data (art. 17 GDPR).
• Right to restriction, to restrict processing (art. 18 GDPR).
• Right to data portability, to receive data in a structured format (art. 20 GDPR).
• Right to object, to object to processing based on legitimate interest (art. 21 GDPR).
• Right to withdraw consent, at any time, without affecting the lawfulness of earlier processing (art. 7(3) GDPR). Withdrawing consent is as easy as giving it; simply reopen the cookie banner in accordance with § 8(3).
• Right to lodge a complaint, with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warszawa).

To exercise the above rights, please contact us at hello@vougly.app.

§10. Changes to the Cookie Policy

1. The Controller reserves the right to amend this Cookie Policy at any time, in particular in the event of changes in the law, the addition of new tracking technologies or a change of service providers.
2. Changes take effect upon publication on the Website. In the event of material changes, the User may be asked to give consent to cookies again.
3. We recommend reviewing the content of this Policy regularly; it is available at vougly.app/cookies.

§11. Controller's details

Windify Digital Services
ul. Płocka 127/16, 87-800 Włocławek
NIP: 8943145650 · REGON: 384382857
Contact: hello@vougly.app