PRIVACY POLICY OF THE TRUML PLATFORM

We respect the privacy of users visiting the Truml website (hereinafter: the "Website") and creators publishing their works on it. This privacy policy defines the rules for processing personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).

1. Data Controller

The controller of personal data is:

Rafał Muszer, conducting business activity under the business name Rafał Muszer
NIP (Tax ID): 6351649700
REGON: 240016328
E-mail: redakcja@truml.com
(hereinafter: the "Controller")

2. Types of Data Collected

We collect data to enable the use of the Website (account creation, publication of works, and verification of their authenticity).

Account data: Pseudonym (creator's name), e-mail address, password (encrypted).
Creative work data: Artistic works (texts, photos, graphics), titles, descriptions, tags, and file metadata.
Technical data: IP address, cookies, browser information, and on-site behavior data (server logs).

3. Purposes and Legal Bases for Data Processing

Users' and creators' data are processed for the following purposes:

Account registration and maintenance: Legal basis: performance of a contract (Art. 6(1)(b) GDPR).
Publication of artistic works: Legal basis: performance of a contract and user consent (Art. 6(1)(a) and (b) GDPR).
Contact and handling of notifications: Responding to inquiries via form/e-mail and handling infringement notices (Art. 6(1)(f) GDPR – legitimate interest).
Analytics and security: Improving website performance, analyzing visits, protecting against bots, and verifying compliance with the Terms of Service (Art. 6(1)(f) GDPR – legitimate interest).

4. Publication of Works, Public Data, and AI Verification

Content published by creators (literary works, photographs, graphics) and their pseudonyms are publicly accessible on the Internet.
The creator publishing a work declares that they are its exclusive, human author. A strict ban on publishing content generated by artificial intelligence (AI) applies on the Website.
The Controller reserves the right to analyze submitted texts and files to detect the use of generative artificial intelligence tools. Data processing for this purpose is based on the Controller's legitimate interest (Art. 6(1)(f) GDPR), which consists in protecting the unique character of the Website and eliminating plagiarism and machine-generated content.
The primary place for the public presentation of Works is the individual profile of the User. Posting a Work on the Website does not guarantee its publication on the main page of the Website.

5. Cookies

The Website uses cookies to ensure basic functionality (e.g., maintaining a login session) and for statistical and analytical purposes (e.g., Google Analytics).
The User can manage cookie consents or block them at any time from the settings of their web browser.

6. Data Recipients

Personal data of users are not sold or shared with third parties for marketing purposes. They may only be transferred to trusted processors:

Providers of hosting and technical services on whose servers the Website operates,
Providers of analytical tools (e.g., Google Analytics),
State authorities and law enforcement agencies authorized under applicable legal regulations (in the event that the published work violates the law).

7. User Rights (GDPR)

The User is entitled to the following rights:

Right of access to data: Checking what data we process and receiving a copy thereof.
Right to rectification: Correcting incorrect data.
Right to erasure ("the right to be forgotten"): Closing the account and removing works from the Website.
Right to data portability.
Right to object: Objecting to data processing (especially for purposes resulting from the Controller's legitimate interest).
Right to lodge a complaint: To the supervisory authority (President of the Personal Data Protection Office - PUODO).
Data deletion instruction / Facebook: Withdrawal of consent to data processing and removal of Facebook login integration (the request must be sent to: redakcja@truml.com).

8. Data Retention Period

Creators' profile data and their works are stored for the period of holding an active account on the Website.
Upon account deletion by the Creator, their personal data and Works are removed from the Website immediately. Archival copies may be stored exclusively for the period necessary to defend against potential legal claims (Art. 6(1)(f) GDPR).
The Controller informs that they have no influence on content archived and indexed by external search engines (e.g., Google Cache) during the time when the work was publicly available on the Website.

9. Changes to the Privacy Policy

The Controller reserves the right to introduce changes to the privacy policy, of which users will be notified on the Website. New versions of the document will be published in advance.

Date of last update: September 20, 2026