Privacy Policy
Last updated: January 31, 2026
1. Data Controller
T-55 Marcin Kulawinek
Jednoosobowa działalność gospodarcza
ul. Melisowa 50
51-180 Wrocław, Poland
NIP: 8272123778
Email: privacy@magini.io
The controller is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data.
2. Data We Collect
2.1 Account Data
When you create an account, we collect:
- Email address
- Name (optional)
- Company name (optional)
- Password (stored as a secure hash)
2.2 API Usage Data
When you use our API, we log:
- API requests (endpoint, timestamp, response status)
- Message metadata (recipient channel, delivery status — not message content)
- IP address of API calls
2.3 Payment Data
Payments are processed by our Merchant of Record:
Paddle.com Market Limited
Judd House, 18-29 Mora Street, London, EC1V 8BT, United Kingdom
Paddle handles all payment processing, invoicing, VAT, and tax compliance. We do not store your credit card details. See Paddle's Privacy Policy.
2.4 Website Analytics
We do not use third-party analytics services (Google Analytics, Meta Pixel, etc.). We do not track you across the web. Basic server logs (IP, user agent, timestamp) are retained for security purposes only.
3. Legal Basis for Processing (GDPR Art. 6)
| Data | Legal Basis |
|---|---|
| Account data | Contract performance (Art. 6(1)(b)) |
| API usage logs | Contract performance, Legitimate interest (Art. 6(1)(b), (f)) |
| Payment data | Contract performance, Legal obligation (Art. 6(1)(b), (c)) |
| Server logs | Legitimate interest — security (Art. 6(1)(f)) |
4. Data Processors & Sub-processors
We use the following third-party services to operate Magini.io:
| Processor | Purpose | Location |
|---|---|---|
| Hetzner Online GmbH | Server hosting | Germany 🇩🇪 |
| OVH SAS | Server hosting | France 🇫🇷 |
| Paddle.com Market Ltd | Payment processing (MoR) | UK 🇬🇧 (adequate) |
No US-based processors. Your data never leaves the EU/EEA or countries with an EU adequacy decision.
5. Data Retention
- Account data: Retained until you delete your account, plus 30 days for backup recovery.
- API logs: Retained for 90 days, then automatically deleted.
- Invoices & payment records: Retained for 10 years (German tax law, AO §147).
- Server logs: Retained for 7 days, then automatically deleted.
6. Your Rights (GDPR Art. 15–22)
You have the right to:
- Access — Request a copy of your personal data
- Rectification — Correct inaccurate data
- Erasure ("Right to be forgotten") — Request deletion of your data
- Restriction — Limit how we process your data
- Portability — Receive your data in a machine-readable format
- Object — Object to processing based on legitimate interest
- Withdraw consent — Where processing is based on consent
To exercise any of these rights, contact us at privacy@magini.io. We will respond within 30 days.
7. Right to Lodge a Complaint
If you believe we have violated your data protection rights, you have the right to lodge a complaint with a supervisory authority. For Poland:
8. Cookies
We use only strictly necessary cookies for:
- Session management (if logged in)
- Language preference
We do not use advertising cookies, tracking cookies, or third-party cookies. No cookie consent banner is required under GDPR for strictly necessary cookies.
9. Data Security
We implement appropriate technical and organizational measures:
- TLS 1.3 encryption for all data in transit
- Encrypted storage for sensitive data at rest
- Regular security updates and patching
- Access controls and audit logging
- Servers located exclusively in EU data centers
10. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes by email or by posting a notice on our website. The "Last updated" date at the top of this page indicates when it was last revised.
11. Contact Us
For any questions about this Privacy Policy or our data practices:
T-55 Marcin Kulawinek — Data Protection
Email: privacy@magini.io
Note: This privacy policy template is for informational purposes and does not constitute legal advice. We recommend having this policy reviewed by a qualified data protection lawyer before going live.