Legal
Data Processing
Version of 28 October 2026. 7 sections.
Working draft: some service provider details below (contact email and phone) are still to be completed.
- Service provider
- Sebastian Małucha
- Brand
- ViralMedia
- Address
- ul. Orzechowa 45 lok. 12, 50-540 Wrocław
- Tax ID (NIP)
- 8992491352
- Business ID (REGON)
- 021319283
- hello@hiretorin.com
- Vulnerability reports
- security@hiretorin.com
The data processing terms of TORIN in English.
Polish version: Przetwarzanie danych. In case of discrepancy the Polish version prevails.
§ 1Who is who
For the data of your clients you are the controller and we are the processor. We process it only on your documented instruction, which is your use of the service.
§ 2What we do with this data
We read the ad accounts and profiles you gave us access to, store the results of those reads and prepare content from them. We change nothing on an account without a separate approval.
§ 3Security
We keep access tokens encrypted. Only the people who run the service have access to the server, and every access leaves a trace.
§ 4Subprocessors
The full list, including when data goes to whom, is on the Subprocessors page. We tell you in advance about any intended change to that list (notice period: published here before sales start), and you can object to it (Art. 28(2) GDPR).
§ 5Breaches
We inform you about a personal data breach affecting your clients without undue delay after we become aware of it (Art. 33(2) GDPR), describing what happened, which data it concerns and what we have already done.
§ 6Assistance and audits
We help you answer requests from the people the data is about, provide the information needed to demonstrate compliance and allow audits (Art. 28(3)(e) and (h) GDPR).
§ 7After the contract ends
When the contract ends we hand the data over and delete it from our systems, except what we must keep for accounting.
Working draft, before final legal review. It describes what the system actually does and does not replace a contract.