Version: 1.0 Creation date: June 24, 2026
Governing language: This English text is a translation provided for convenience only. The legally binding version of this Privacy Policy is the Polish-language version. In the event of any discrepancy between this translation and the Polish version, the Polish version shall prevail.
1. Introduction
This Privacy Policy defines the rules for processing information about users of the 1Tracker mobile application (hereinafter: “Application”) and the methods used to protect personal data. The Application is a tool used in B2B (Business-to-Business) relations intended for managing logistics processes and monitoring the execution of field orders.
We respect your privacy. The Application has been designed so that monitoring takes place only to the extent necessary, strictly related to the execution of the order, and under your full control.
2. Role of the Data Controller and Data Processor
For you to know who is responsible for your data, we must distinguish between two roles of the Personal Data Controller:
a) Link sp. z o.o. is the Controller of personal data of its Clients, representatives of these Clients, persons executing the contract, and representatives;
b) The Client of Link sp. z o.o. (Your transport services Orderer or Your Employer) is the Controller of your personal data, deciding on the purposes and methods of processing your data. It is the Client who assigns orders and requires confirmation of their execution. When processing your data, Link sp. z o.o. acts as a data processor of personal data entrusted by the Client of Link sp. z o.o.
Contact with the Personal Data Controller:
a) The Controller Link sp. z o.o. has appointed a Data Protection Officer, whom you can contact via email by sending a message to daneosobowe@linktransport.eu;
b) Contact with the Client Controller should be made using the contact details provided by them.
3. Scope of Collected Data
a) The Controller Link sp. z o.o. DOES NOT collect your identification data, such as first name, last name, email address, or private phone number, through it.
b) The Client, as the Controller of your data in connection with the use of the Application, DOES NOT collect your identification data, such as first name, last name, email address, or private phone number, through it.
Important information about pseudonymization: Although Link sp. z o.o. does not know your identity and will not establish it based on information obtained during the operation of the application, our Client, your Orderer (Controller), may link your Device ID with your person. Therefore, we treat all collected data with the highest security standard appropriate for personal data in accordance with GDPR.
The system operates exclusively on technical and pseudonymized data:
• Technical Identifiers: Unique device identifier (Device ID) or installation identifier (Installation ID).
• Order Identifiers: Order reference numbers (Order ID) assigned by the Client.
• Geolocational Data: Precise geographical coordinates (GPS/GNSS), measurement time, speed, and direction of movement.
• Diagnostic Data: Information about battery status and network connectivity status (necessary to ensure continuity of WorkManager’s operation).
4. Use of Location (Including Background Location)
The functionality of the Application is based on confirming the execution of services in the field (Proof of Service). To enable this, the Application requires access to your device’s location.
Operating principle (Prominent Disclosure): The Application collects location data even when it is closed or not in use (runs in the background), provided that there is an active order in the Application.
Background access (implemented technically, among others, by the WorkManager service) is necessary to:
• Automatically record the route progress without the need to keep the phone screen turned on (battery saving and driving safety).
• Send periodic reports (pings) about the order status (standardly approx. every 15 minutes) to the dispatch system.
• Confirm the moment of reaching the destination (geofencing).
When you are not executing an active order, the Application does not collect location data in the background.
5. Purposes of Processing
a) The Controller Link sp. z o.o. processes personal data for the purposes of:
• performance of contracts with Clients based on Art. 6(1)(b) GDPR;
• performance of contracts with Orderers of transport contracts and cargo recipients, based on Art. 6(1)(b) GDPR;
• monitoring the execution of the order, i.e., verifying the vehicle’s position in real time to optimize logistics;
• obtaining proof of service execution (Proof of Service) in the form of electronic confirmation of presence at the loading/unloading point;
• ensuring the safety of property: Monitoring the cargo during transport, establishing and defending against claims (Art. 6(1)(f) GDPR);
• fulfilling legal obligations imposed on the controller resulting from keeping accounting records (Art. 6(1)(c) GDPR);
• pursuing the legitimate interests of the Controller consisting in ensuring contacts necessary for conducting business, including establishing and maintaining cooperation with the entity on whose behalf the persons act, establishing claims or defending against claims – Art. 6(1)(f) GDPR;
• development and improvement of the Application;
• when processing is necessary to protect the vital interests of the State or other persons.
b) The Client Controller processes your data for the following purposes:
• performance of the contract concluded with you (Art. 6(1)(b) GDPR);
• pursuing the legitimate interests of the Controller consisting in:
– a. monitoring the execution of the order: Verification of the vehicle’s position in real time to optimize logistics,
– b. obtaining proof of service execution (Proof of Service) in the form of electronic confirmation of presence at the loading/unloading point,
– c. ensuring the safety of property: Monitoring the cargo during transport, establishing and defending against claims (Art. 6(1)(f) GDPR);
• fulfilling legal obligations imposed on the controller resulting from keeping accounting records (Art. 6(1)(c) GDPR);
• when processing is necessary to protect the vital interests of the State or other persons.
Processing is in the legitimate interest of the Application Provider, except where such interest is overridden by your interests or fundamental rights and freedoms.
Exclusions: Your location data is never used for advertising or marketing purposes, nor is it sold or shared with third parties other than those specified in Section 7 of this Policy, including the Orderer of transport contracts and the recipient of the transported cargo.
6. Your Control and Privacy (Protective Mechanisms)
We have implemented advanced technical mechanisms that guarantee you full control over the tracking process:
A. Auto-Stop (Automatic Stop)
Tracking is strictly linked to the lifecycle of the order. Upon receipt of information from the Client about the completion of the order (status “Completed” / “Delivered”), background tracking systems are automatically deactivated. The Application enters a sleep state and does not record your location.
B. Kill Switch (Manual Turn-Off – “Right to be Offline”)
We understand that private situations or breaks may occur during work. The Application has a built-in, easily accessible “Stop Tracking” / “Go Offline” button in the main interface. Using this function results in an immediate, software-forced cessation of GPS data collection, regardless of the order status. You have the technical ability to be “invisible” at any time.
C. Activity Indicator
Whenever the Application uses location in the background, your device’s operating system displays a corresponding notification in the status bar. You can be sure when monitoring is active.
7. Data Sharing
Data from the Application may be shared with the following categories of recipients:
• Your Contractor (Client of “LINK” sp. z o.o.): The entity for which you perform the transport service – to confirm its execution.
• End recipient of the goods: To a limited extent (e.g., status “In transit”), for delivery scheduling.
• IT infrastructure and IT solution providers: Trusted technological partners (e.g., cloud service providers, hosting providers) who process data on our behalf based on data processing agreements, guaranteeing their security.
• Employees of the Application Provider: To perform their official duties. Sharing occurs only to the extent necessary, i.e., to enable the proper functioning of the application and execution of the transport agreement. Every employee of the Application Provider is bound by confidentiality.
• If required by law, court order, or other legal proceedings, for example to law enforcement or other government authorities, to establish or exercise our rights, or in connection with a transaction such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
8. Data Retention Period
a) The Controller Link sp. z o.o. processes personal data indicated in Section 2(a) for the period necessary to execute and settle the existing cooperation with the Client, the Orderer of the transport contract, or to establish cooperation in the future, as well as until the expiry of periods resulting from applicable law (i.e., until the expiry of the limitation period for tax liabilities related to accounting documentation), which may be extended in appropriate cases by the limitation period for civil claims.
b) Location data associated with a specific order, for which the Client is the Controller, is stored for the period necessary to:
• Complete and settle the order.
• Resolve potential complaints regarding the transport service (in accordance with the limitation periods for claims in transport contracts).
• Data processed to pursue a legitimate interest will be processed until that purpose ceases, the limitation period for civil claims or tax liabilities expires, or until an effective objection is lodged.
After this period, the data is permanently deleted or fully anonymized (links with Device ID are removed), making it impossible to assign them to a specific device.
9. User Rights (GDPR)
In connection with data processing, you have the following rights:
• Right to access data (route history).
• Right to rectification of data.
• Right to erasure of data (“the right to be forgotten”).
• Right to restriction of processing.
• Right to object.
How to exercise your rights? Since the Controller of your data is your Orderer (the company that assigned the order), please direct all requests regarding the exercise of the above rights directly to them. As the Application Provider, we provide the Controller with technical tools to export or delete your data at their request.
10. Contact
For technical matters regarding the operation of the Application or privacy mechanisms, you can contact us at:
• Email: link@linktransport.eu; daneosobowe@linktransport.eu
• Address: ul. Wał Miedzeszyński 606, 03-994 Warsaw
11. Governing Law and Jurisdiction
The governing law for this Privacy Policy is Polish law (including the Personal Data Protection Act) and Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR).
Disputes arising from this Privacy Policy will be resolved by the court having jurisdiction over “LINK” sp. z o.o.
Regardless of the language into which this Privacy Policy is translated, the Polish language version is the binding version.