Privacy Policy

1. Who we are

The controller of your personal data is MFPM Intelligence Sp. z o.o. (company name change from Splot Store Sp. z o.o. pending registration in the National Court Register), Nowy Świat 60/22, 00-357 Warsaw, Poland; KRS 0001236093, NIP (VAT ID) PL5253086543, REGON 544536268 ("Keelra", "we"). For any data matter, contact us at hello@keelra.com.

2. Who this policy covers

This policy covers two groups of people, and the sections below state where the two differ:

• Prospects: people we contact with B2B outreach about Keelra services, whose data we did not collect from them directly (Art. 14 GDPR applies).
• Platform users and clients: people who sign up for or use the Keelra platform, book an audit call, or email us (Art. 13 GDPR applies).

Data that clients process inside their Keelra workflows (for example their own customers' documents) is processed by Keelra as a processor under a Data Processing Agreement, not under this policy. The client remains the controller of that data.

3. Where prospect data comes from

We obtain prospect data from publicly available business sources (company websites, professional profiles, business registries) and from B2B data providers such as Apollo. We process only business contact details obtained in a business context, never private addresses collected outside one.

4. What data we process

• Prospects: name, business email address, job title, company name, company details (industry, size, website), and the history of our correspondence with you.
• Platform users and clients: account data (name, email, company), billing data, service configuration, and usage and audit logs generated by the platform.
• Website visitors: aggregated, cookie-free analytics about page visits. We do not build individual visitor profiles.

5. Purposes and legal bases

• B2B outreach and marketing to prospects: our legitimate interest in promoting our services to businesses (Art. 6(1)(f) GDPR). You can object at any time and we stop immediately.
• Providing the platform and delivering services to clients: performance of a contract (Art. 6(1)(b) GDPR).
• Invoicing, accounting, and tax obligations: legal obligation (Art. 6(1)(c) GDPR).
• Security, abuse prevention, and audit logging: our legitimate interest in keeping the service safe (Art. 6(1)(f) GDPR).

6. How long we keep data

• Prospects: if you object or opt out, we delete your data from our outreach lists immediately and keep only the minimum needed to honor the opt-out. If you never respond, we delete your data no later than 12 months after our last contact attempt.
• Clients: for the duration of the contract, and afterwards for the statutory retention periods that apply to accounting and tax records and for the limitation periods of legal claims.

7. Recipients and subprocessors

We share personal data only with service providers that host or support our infrastructure, under data processing terms. The current list, including what each provider processes and where, is published at keelra.com/subprocessors.

8. International transfers

Our primary infrastructure runs in the EU. Where a provider processes data outside the European Economic Area, the transfer is safeguarded by the EU Standard Contractual Clauses and supplementary measures where needed.

9. Your rights

Under Articles 15 to 21 GDPR you have the right to:

• access your data and receive a copy,
• rectify inaccurate data,
• have your data erased,
• restrict processing,
• receive your data in a portable format,
• object to processing based on legitimate interest. For direct marketing the objection is absolute: one email to hello@keelra.com or one click on the opt-out link in any message ends all outreach, unconditionally.

To exercise any of these rights, email hello@keelra.com. We respond within one month.

10. Complaints

You can lodge a complaint with the President of the Personal Data Protection Office in Poland (PUODO, uodo.gov.pl) or with the supervisory authority in your own EU member state.

11. Contact

All privacy matters: hello@keelra.com.