Privacy and data

LOKINFO Privacy Policy

Last updated: 18 October 2026.

This policy covers LOKINFO for Android and iOS, lokinfo.pl, communications with the publisher and access to the demonstration at demo.lokinfo.pl. It explains the data needed to operate the service and how to exercise your rights.

1. Publisher and privacy contact

LOKINFO is published by LEXCOM Paweł Mastalerz. LEXCOM is the controller of data relating to its own website, correspondence and handling enquiries. For privacy matters, contact us by email, telephone or post:

Identify LOKINFO and describe your enquiry. Do not send your password, one-time code or access token.

2. Housing organisation data

Resident, property and accounting information comes from the organisation granting your access or its source system. That organisation determines property access rights, the information made available and how its records are maintained. Its contact details are shown in the app.

This policy does not replace the privacy information supplied by your organisation. Responsibilities of LEXCOM and the organisation depend on the deployment and data handling arrangements. Where work is performed on the organisation’s behalf, requests concerning its records require that organisation’s involvement. If you do not know whom to contact, LEXCOM can help identify the appropriate route.

3. What data does the service handle?

• App access: your login and authentication data needed to verify access, account and organisation identifiers, and assigned properties. The password entered at sign-in is not saved as a plain-text password in your phone’s app settings.
• Information provided by the organisation: your name, property addresses, balances and their dates, charges and payments, monthly charge items, utility settlements, meter readings and announcements, subject to availability and your access rights.
• Feature use: announcement read status, language and appearance settings, the selected organisation and notification preferences.
• Technical access and notification data: session and phone association identifiers, push tokens, notification language and opt-ins, and technical operation dates and outcomes. A push token enables notification delivery; it is not a telephone number.
• Website and contact: IP address, request time and URL, browser details, and information you provide in correspondence or a conversation. Technical log contents also depend on hosting configuration.

4. What is stored on your phone and server?

The app stores secured access credentials in system storage and settings needed for convenient use. Downloaded financial data and announcements are used to display current screens; the app does not build a permanent archive for offline browsing. Internet access is required to retrieve up-to-date information.

The LOKINFO server retains records needed to verify and renew access, associate users with organisations and properties, associate phones, handle push notifications and maintain announcement read status. Storage on your phone does not replace these server records. Disconnecting LOKINFO access is separate from an account and records held in the organisation’s system.

The current version does not require access to contacts, photos, microphone or location. It contains no advertising or marketing analytics tools. We do not sell residents’ data or use them for behavioural advertising.

5. Purposes and legal bases

Data support access to information for authorised residents, maintaining and revoking access, delivering selected notifications, responding to enquiries and protecting the service against misuse.

For LEXCOM’s own activities, the applicable basis is performance of a contract or steps before entering into one at the person’s request (GDPR Article 6(1)(b)), a legal obligation (point (c)), or legitimate interests in responding, protecting access and establishing or defending claims (point (f)). Where a process relies on consent, it may be withdrawn without affecting the lawfulness of earlier processing. Your organisation specifies the bases for processing resident records.

Providing data in correspondence is voluntary; without a reply address we may be unable to handle your enquiry. Sign-in data and assignments are needed to access protected information. Notifications are optional.

6. Notifications and reminders

Notifications are enabled in the app and your phone’s system settings. Underpayment reminders have a separate switch and depend on the organisation offering the feature and on current data. Turning off the main notification setting in LOKINFO also stops financial reminders.

Notification handling involves a device token, preferences and technical registration or delivery confirmations. Lock-screen messages use neutral wording. They do not include an underpayment amount, property address or full announcement text. Details open inside the app after access is checked. An automatic reminder is not a debt collection decision or bank confirmation; the app does not use it to make decisions producing legal effects for a resident.

Disabling notifications does not delete your account or the organisation’s records and does not prevent reading information in the app. System permission is a phone permission and does not replace the organisation’s legal basis for processing data.

7. Providers, recipients and processing outside the EEA

To the extent needed to provide the service, data may be accessible to authorised LEXCOM personnel, authorised people at your organisation, and hosting, email and notification providers. The demonstration infrastructure uses LH.pl hosting. Notification delivery involves Expo Push Service (650 Industries, Inc.), Apple Push Notification service on iOS and Google’s Firebase Cloud Messaging on Android. Data may also be disclosed to competent authorities where required by law.

Notification providers operate internationally; their services may involve processing outside the European Economic Area, including in the United States. This does not mean sending them the organisation’s entire financial records. See the Expo policy, Apple policy and Firebase privacy information. Contact LEXCOM and your organisation for information about recipients, processing locations and safeguards applicable to your deployment.

8. Retention and deletion

• Your phone: saved access and settings remain until changed or successfully cleared in the app. If disconnection is incomplete, a minimal secured task may remain so the operation can be retried.
• Active access and notifications: technical data are used while the association is active and as needed to verify or revoke access. Confirmed phone revocation invalidates its access and disables its notifications; the current implementation also removes the stored token used to send notifications for that association. This does not remove every technical trace.
• Technical maintenance: the current backend provides for removing revoked access records after 30 days and announcement delivery records after 30 days from creation. Financial reminder history covers the current and two preceding months to limit duplicate sends. Deletion occurs during maintenance, rather than exactly when a period expires. These rules do not specify retention of the entire database, logs or backups.
• Organisation records: retained for periods determined by its purposes, legal obligations and accounting arrangements. Disconnecting a phone does not shorten those periods.
• Correspondence and rights requests: data are needed until the matter is closed. Subsequent retention is limited to what is justified to demonstrate request handling, fulfil a legal obligation, or establish or defend claims, until that basis no longer applies.
• Logs and backups: may contain data needed to investigate an incident or restore operation. Clearing a phone does not delete logs or backups. When handling a request, we explain whether data remain in this scope, why, and which deletion period or criterion applies.

9. Security

The server checks access to app data. We use encrypted HTTPS connections and secured system credential storage on the phone. Backend authentication data are protected according to their type, including hashing, and the push delivery token is stored encrypted. Features are limited by account permissions. Do not share sign-in credentials; report a lost phone or suspected account compromise to your organisation or LEXCOM.

10. Your rights and request handling

Subject to GDPR conditions, you have rights of access, rectification, erasure, restriction and, where applicable, portability. You may object to processing based on legitimate interests and withdraw consent where a process relies on it. Erasure rights do not override record retention obligations or other people’s rights.

Send requests to biuro@lexcom.pl or your organisation. Identity checks are proportionate to the risk and request scope; we do not require your password. GDPR rights requests should receive a response without undue delay, generally within one month of receipt. In legally permitted cases, this may be extended by two further months, with reasons communicated within the first month. The response deadline does not mean every request to erase all data will be granted automatically.

You may complain to the President of Poland’s Personal Data Protection Office (UODO) or another competent EU supervisory authority. You do not need LEXCOM’s permission to do so.

11. Website, demonstration and policy updates

The current lokinfo.pl front has no contact form, advertising, marketing analytics or externally hosted fonts. It sets no cookies of its own and does not persist interactive presentation choices in browser storage. The presentation uses fictional data and does not sign you into an actual resident account. The separate demonstration panel at demo.lokinfo.pl uses session cookies needed for sign-in and security. Do not enter real residents’ data into the public demonstration.

In the current Demo, example property and accounting data are stored in the LOKINFO database. When using a shared demonstration account in the app, property data are fictional, but your phone’s token and technical connection data are real and subject to the practices described above. Announcement read status on a shared account may be shared with other testers.

In the current Demo, example property and accounting data are stored in the LOKINFO database. When using a shared demonstration account in the app, property data are fictional, but your phone’s token and technical connection data are real and subject to the practices described above. Announcement read status on a shared account may be shared with other testers.

Email links open your email application; telephone links use your device’s call handling. External sites and services apply their own policies. The Polish policy is available at lokinfo.pl/privacy/, also linked from app settings; the English version is at lokinfo.pl/en/privacy/. See also LOKINFO access and data removal. We update this policy and its date when processing changes.