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This English translation is provided for convenience only. The legally binding version of this document is the Polish version.

Privacy Policy (GDPR)

Last updated: 27 October 2026 · Version: 1.0

This Privacy Policy applies to the ViaSanto app for iOS and Android devices and its Web Version (the “Application”), as well as to the viasanto.com website. It sets out what personal data is collected and how, for what purposes it is processed, to whom it is entrusted, how long it is kept, and how the User can withdraw consent or request deletion of the data. Capitalised terms used in this document have the meanings given to them in the Terms of Service (section II).

I. Data controller

The controller of the Users’ personal data is Marcelina Goździewska-Ćwirlej, running a sole proprietorship under the business name “ViaSanto Marcelina Goździewska-Ćwirlej”, ul. Sikorskiego 15/8, 64-920 Piła, Poland, NIP (tax ID) 7642700903 (the “Controller”). In personal data protection matters the Controller can be contacted at contact@viasanto.com. The Controller has not appointed a data protection officer; all matters concerning personal data should be sent to the above address.

II. Scope, purposes and legal bases of data processing

Personal data is obtained:

  • a) directly from the User, in particular when the Account is created, when content is published and in correspondence with the Service Provider;
  • b) from Apple or Google, if the User signs in through those services (email address and, with the User’s consent, also first name and surname), and in connection with purchases (the transaction status provided by the store);
  • c) in connection with the use of the Application, in particular the record of prayers said and the device identifier used to send notifications (notification token).

The scope of the data, the purposes and the legal bases of processing are as follows:

  1. Account data: email address, Username (nickname), first name and surname (if provided by Apple or Google at sign-in), Account ID, password (stored only as a cryptographic hash), sign-in method, chosen avatar and patron saint.
    • Purpose: providing the service, handling sign-in (including via Apple and Google), maintaining the Account, communication about the Account and replying to the User’s correspondence.
    • Legal basis: performance of a contract (Article 6(1)(b) GDPR).
  2. User Content: Posts, Intentions, Comments, Reactions, Messages in the chats of Communities and Prayer Groups, photos and videos (profile photo and cover photo, photos and videos in Posts and Messages), profile description, chosen parish, bug reports and ideas.
    • Purpose: making the Application’s community features work. User Content is visible to other Users in accordance with the User’s privacy settings and the settings of the given Community or Prayer Group.
    • Legal basis: performance of a contract (Article 6(1)(b) GDPR).
  3. Technical data and device identifiers: session identifiers, push notification token (Firebase Cloud Messaging on Android, Apple Push Notification service on iOS), information about the system, Application version and device language, as well as crash reports (type and cause of the error, technical trace, device model), stored on our server for 90 days.
    • Purpose: proper operation of the Application, security, delivery of notifications.
    • Legal basis: the Controller’s legitimate interest (Article 6(1)(f) GDPR).
  4. Purchase data (purchase history): product identifier (Diamond Pack, monthly or annual Subscription), transaction identifier and token assigned by the store, the store (App Store or Google Play), purchase date, Subscription period and status, refund information, Diamond balance and history. The Controller does not receive the details of the User’s card or any other means of payment; payment is handled solely by the store operator.
    • Purpose: fulfilling the purchase (granting Diamonds and Premium access), restoring purchases on other devices, maintaining the Account, handling complaints and refunds, preventing fraud and abuse, fulfilling legal obligations.
    • Legal basis: performance of a contract (Article 6(1)(b) GDPR); for accounting and tax obligations: legal obligation (Article 6(1)(c) GDPR); for preventing abuse and establishing, exercising or defending claims: the Controller’s legitimate interest (Article 6(1)(f) GDPR).
  5. Special category data (religious beliefs): information about prayers said and passages of Sacred Scripture read, Prayer Goals, the prayer log, the Streak (days of prayer), Prayer Points, progress and achievements, Intentions, and membership of Communities, Prayer Groups and parishes (interactions with the Application).
    • Purpose: the essence of the service, namely recording prayer and progress and enabling participation in Communities.
    • Legal basis: the User’s explicit consent (Article 9(2)(a) GDPR), which the Application asks for when it is first launched (the “Before you start” screen). Consent can be withdrawn, but this involves deleting the Account, because processing this data is necessary for the Application to work.
  6. Moderation and community safety: content reports (with a preserved excerpt of the reported content), User blocks, Moderators’ decisions and the log of actions of the ViaSanto Assistant, the automated chat Moderator (e.g. a welcome, moving a report to the proper Channel, removing a Message that breaks the rules, with a short reason). The ViaSanto Assistant runs on the Controller’s server; the content of Messages is not passed to external providers. If an external provider (e.g. of an artificial intelligence model) is ever enabled for its operation, the Controller will update this Privacy Policy before that happens.
    • Purpose: enforcing the Terms of Service, protecting Users from prohibited content, handling reports and appeals.
    • Legal basis: the Controller’s legitimate interest (Article 6(1)(f) GDPR) and obligations under the Digital Services Act (Article 6(1)(c) GDPR).
  7. Usage statistics: pseudonymous data on the use of the Application’s screens and features (interactions with the Application, a pseudonymous identifier), without the content of Intentions, notes or searches. The Controller uses first-party analytics only, without external analytics or advertising tools.
    • Purpose: improving the Application and compiling statistics.
    • Legal basis: the User’s voluntary “Usage statistics” consent (on the consent screen: “Consent to usage statistics”; in Settings: “Usage statistics (analytics)”), Article 6(1)(a) GDPR. The consent is off by default; data is collected only once it has been given.
  8. “News and messages from ViaSanto”: email address, push notification token and the record of the consent given.
    • Purpose: sending information about new features, reading plans and ViaSanto events (push notifications or email). The Controller does not send advertising of other entities.
    • Legal basis: the User’s voluntary “News and messages from ViaSanto” consent (in Settings: “Marketing communications”), Article 6(1)(a) GDPR in conjunction with Article 398 of the Polish Electronic Communications Law.

Providing data is voluntary but necessary to create an Account and to use the community features and purchases. Without an Account the Application can be used in Guest Mode; progress is then saved only on the User’s device. The Application accesses the camera, microphone and photos only when the User decides to add a photo or video. The Application does not collect the User’s location or contacts, does not show ads, does not track the User across other apps and websites, does not sell data and does not share it with other companies for their own purposes. The Controller does not take decisions concerning the User based solely on automated processing that would produce legal effects concerning the User or similarly significantly affect the User (Article 22 GDPR). An appeal against the automatic removal of a Message is available and is reviewed by a person (Terms of Service, section VI.9).

III. Recipients of data and transfers outside the EEA

  1. The main infrastructure (database) provider is OVHcloud (OVH SAS, 2 rue Kellermann, 59100 Roubaix, France). Users’ data is stored on secured servers located in the European Union.
  2. When signing in through third-party services (Apple, Google) and when push notifications are delivered (Firebase Cloud Messaging on Android, Apple Push Notification service on iOS), the necessary data may be transferred to entities established outside the European Economic Area (EEA), in particular in the USA (Apple Inc., Google LLC). This always takes place on the basis of mechanisms approved by the European Commission, such as the EU-US Data Privacy Framework or standard contractual clauses.
  3. For purchases in the Application, Apple (App Store) and Google (Google Play) act as store operators and separate controllers of payment data, under their own privacy policies. To verify a purchase, the Controller sends the transaction identifier to the App Store Server API or the Google Play Developer API and receives the purchase status in response.
  4. Entities processing data on behalf of the Controller (the infrastructure provider, notification delivery services, the email provider for correspondence with the Controller) act under data processing agreements (Article 28 GDPR) or the data protection terms of those services and provide protection of data that is the same as or equivalent to that described in this Policy. They may process data only on the Controller’s instructions and for the purpose of providing their services to the Controller.
  5. User Content is visible to other Users in accordance with the User’s privacy settings and the settings of the Community or Prayer Group. The Controller may also disclose data to public authorities where required by law.

IV. Data security

Connections between the Application and the server are encrypted (HTTPS/TLS). Access to data in the database is restricted by permission rules at the level of individual records: each User has access only to their own data and to content that other Users have shared with them. Passwords are stored only as cryptographic hashes. Administrative access to the servers is limited to persons authorised by the Controller, to the extent necessary to maintain the service.

V. Data retention

Data is kept for as long as the Account exists. After a request to delete the Account and the expiry of the Grace Period (30 days), the Account data is permanently deleted, including the profile, User Content (Posts, Intentions, Comments, Messages, photos and videos), the prayer log, Diamond balance and history, purchase data and notification tokens. During the Grace Period the User can cancel the deletion by sending an email to contact@viasanto.com from the address linked to the Account (details: Account Deletion). Communities and Prayer Groups founded by the User remain for their other members, but without any link to the User’s Account.

After the Account is deleted, the Controller keeps only a narrow set of data necessary to defend against claims (Account ID, a cryptographic hash of the email address, the record of consents given and documents accepted, the date and reason for deletion) for 6 years, as well as data whose further retention is required by law. Content reports and the log of moderation decisions are kept for 2 years (after the Account is deleted, without any link to it), and the log of the ViaSanto Assistant’s actions for 90 days. Cancelled Account deletion requests are deleted one year after cancellation.

Usage statistics data (if the User has given consent) is deleted or anonymised after 13 months and deleted when the Account is deleted. After consent is withdrawn, further collection stops and events not yet sent are deleted from the device. The transaction history also remains with the store operator, under its privacy policy.

In Guest Mode, data is stored only on the device. Progress is kept for 24 hours, after which it is deleted from the device; the data also disappears when the Application’s data is cleared.

VI. Rights of the User

The User has the right to request access to their data, its rectification, erasure (the “right to be forgotten”), restriction of processing and data portability (the data can be exported directly in the Application), and the right to withdraw consent at any time. The User also has the right to object to processing based on legitimate interest (Article 21 GDPR) and the right to lodge a complaint with the President of the Polish Personal Data Protection Office (PUODO), ul. Stawki 2, 00-193 Warsaw, Poland, or with the data protection authority in the country where the User lives.

  • Data export: Settings (gear icon in the top right corner of the screen) → the “Profile” tab (person icon on the bottom bar) → the “ACCOUNT” section → “Account” → the “YOUR DATA” section → “Download my data” (JSON file).
  • Deleting the Account and data: on the same screen, in the “DELETE ACCOUNT” section → “Delete account”, or by email to contact@viasanto.com; details are given in the Account Deletion document.
  • Withdrawing consents: the “Usage statistics” and “News and messages from ViaSanto” consents: Settings → the “Consents and terms” tab (book icon on the bottom bar) → “Consents”; the consent to the processing of special category data (Article 9 GDPR): by deleting the Account. Withdrawing consent does not affect the lawfulness of processing carried out before its withdrawal.
  • Other requests: by email to contact@viasanto.com. The Controller replies without undue delay, and no later than within one month.

VII. Age, changes and language versions

The Application is intended for persons who are at least 16 years old. The Controller does not knowingly collect data of younger persons; if the Controller learns that an Account has been created by a person under 16, the Controller will delete that Account. The Controller informs Users of material changes to this Policy in the Application. This Privacy Policy is available in Polish, English and Spanish; the Polish version is binding.