Privacy Policy
Last Updated: November 18, 2025
1. Introduction
This Privacy Policy explains how Marcin Zaremski, a self-employed individual operating under NIP PL6762604679, with registered address at Plac Na Groblach 14/2, 31-101 Kraków, Poland ("we," "us," or "our") collects, uses, and protects your personal information when you use GpxOverlay (the "Service").
We are committed to protecting your privacy and handling your data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).
2. Data Controller
The data controller for your personal information is:
Marcin Zaremski
Plac Na Groblach 14/2
31-101 Kraków, Poland
NIP: PL6762604679
3. Information We Collect
3.1 Information You Provide
- Email Address: Collected when you download generated videos or make a purchase
- GPX Files: Activity data files you upload to generate overlay videos
- Payment Information: Processed by LemonSqueezy (our payment processor) - we do not directly collect or store payment card details
3.2 Automatically Collected Information
- Usage Analytics: Non-personal analytics data collected through SimpleAnalytics, a GDPR-compliant analytics service that does not use cookies or track personal information
3.3 Information We Do NOT Collect
- We do not collect passwords (no authentication system)
- We do not collect names, addresses, or phone numbers
- We do not collect video files (only GPX files)
- We do not use cookies for tracking
- We do not collect IP addresses or device identifiers (handled by SimpleAnalytics in a privacy-friendly manner)
4. How We Use Your Information
4.1 Email Addresses
- To identify your account and associate it with Pro access purchases
- We do NOT send marketing emails, newsletters, or promotional materials
- We do NOT use your email for communication unless responding to your direct inquiries
4.2 GPX Files
- To generate overlay videos with stats, maps, and gauges
- For debugging and technical troubleshooting purposes
- For service improvement and maintenance
4.3 Generated Videos
- To provide you with downloadable overlay videos
- For quality assurance and technical support
4.4 Analytics Data
- To understand Service usage patterns
- To improve Service performance and features
- To monitor Service availability
5. Legal Basis for Processing (GDPR)
We process your personal data under the following legal bases:
- Contract Performance: Processing necessary to provide the Service you've requested
- Legitimate Interests: Processing for debugging, service improvement, and fraud prevention
- Consent: For using your generated videos for marketing purposes - consent is given by using the Service and can be withdrawn at any time
6. Data Storage and Security
6.1 Where We Store Your Data
Your data is stored using the following infrastructure providers:
- Heroku: Server hosting
- Google Cloud Platform (GCP) Storage: File storage for GPX files and generated videos
- Supabase: PostgreSQL database for email addresses and account data
These providers may process data in the United States or other jurisdictions outside the European Economic Area (EEA). All international data transfers are protected by appropriate safeguards, including Standard Contractual Clauses approved by the European Commission and/or adequacy decisions where applicable. Our infrastructure providers are contractually obligated to maintain these safeguards and comply with applicable data protection laws.
6.2 Data Retention
- GPX Files: Stored for up to 1 year from upload date, then automatically deleted
- Generated Videos: Stored for up to 1 year from generation date, then automatically deleted
- Email Addresses: Retained as long as your account exists or as required by law
6.3 Data Security
We implement reasonable technical and organizational measures to protect your data, including:
- Secure data transmission protocols
- Access controls to infrastructure
- Regular security assessments
However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.
7. Data Sharing and Disclosure
7.1 Third-Party Service Providers
We share your data with the following service providers:
- LemonSqueezy: Payment processing (they act as merchant of record)
- Heroku: Server hosting and infrastructure
- Google Cloud Platform: File storage
- Supabase: Database services
- SimpleAnalytics: Privacy-friendly analytics (no personal data shared)
These providers process data on our behalf and are contractually obligated to protect your data.
7.2 Legal Requirements
We may disclose your information if required by law, court order, or government regulation, or to:
- Protect our legal rights
- Enforce our Terms and Conditions
- Prevent fraud or security threats
7.3 Business Transfers
In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity.
7.4 Marketing Use of Generated Videos
By using the Service to generate overlay videos, you grant us consent to use your generated videos for marketing and promotional purposes. This consent includes the right to display your videos on our website, social media, and other promotional materials.
You retain full ownership of your generated videos and may use them for any purpose.
Withdrawing Marketing Consent: You may withdraw this consent at any time by contacting us via email (contact details in Section 13). Upon receiving your withdrawal request, we will immediately cease using your videos in any new marketing materials. Please note that videos already published in existing marketing materials may remain visible until those materials are updated or removed.
8. Your Rights (GDPR)
You have all rights under the GDPR, including the right to access, rectify, or erase your personal data, and the right to object to processing. To exercise these rights, please contact us using the details in section 13.
9. International Data Transfers
Your data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States, where our infrastructure providers (Heroku, Google Cloud Platform, Supabase) operate data centers.
We ensure appropriate safeguards are in place for all international data transfers:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Adequacy decisions by the European Commission where available
- Contractual obligations requiring our infrastructure providers to maintain these safeguards and comply with applicable data protection laws
These safeguards ensure that your data receives an adequate level of protection regardless of where it is processed.
10. Children's Privacy
We do not knowingly collect personal information from children under 13 (or the minimum age in your jurisdiction). If you believe we have collected information from a child, please contact us immediately.
11. SimpleAnalytics and Cookies
We use SimpleAnalytics, a GDPR-compliant analytics service that:
- Does NOT use cookies
- Does NOT track personal information
- Does NOT collect IP addresses in an identifiable format
- Processes only non-personal, aggregated data
We do not use any tracking cookies or advertising cookies on our Service.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Changes are effective immediately upon posting to our website. We will not provide individual notice of changes.
It is your responsibility to review this Privacy Policy periodically. Your continued use of the Service after changes constitutes acceptance of the updated Privacy Policy.
13. Contact Information
For privacy-related questions, to exercise your rights, or to contact our data protection officer, please reach us at:
Marcin Zaremski
Plac Na Groblach 14/2
31-101 Kraków, Poland
NIP: PL6762604679
Please allow reasonable time for us to respond to your requests.
If you are located in the EU/EEA, you have the right to lodge a complaint with your local data protection authority. In Poland, this is:
Urząd Ochrony Danych Osobowych (UODO)
ul. Stawki 2
00-193 Warsaw, Poland
Website: uodo.gov.pl
By using GpxOverlay, you acknowledge that you have read and understood this Privacy Policy.