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Privacy Policy

# PRIVACY POLICY

**Last updated: 30 August 2026**

## 1. General provisions

This Privacy Policy explains how **billogy.solutions**, operating the Billogy service and the website available at **https://www.billogy.solutions/** ("Billogy", "we", "us", or "our"), collects, uses, stores and protects personal data.

We respect the privacy of our users, business customers, prospective customers and other individuals whose personal data we process.

We process personal data in accordance with:

* Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR");
* applicable Polish data protection legislation;
* applicable electronic communications and telecommunications regulations;
* other applicable laws concerning privacy and personal data protection.

This Privacy Policy applies primarily to personal data processed through the Billogy website, contact forms, sales and business communication, and related interactions with Billogy.

Where Billogy processes personal data on behalf of a business customer as part of the Billogy service, such processing is governed additionally by the applicable **Data Processing Agreement ("DPA")** and the customer's instructions.

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# 2. Data Controller

The controller of personal data processed through the Billogy website and in connection with our commercial activities is:

Not registered yet
**[FULL LEGAL COMPANY NAME]**
**[LEGAL FORM, e.g. sp. z o.o.]**
**[REGISTERED ADDRESS]**
**[POSTAL CODE, CITY, POLAND]**
NIP: **[NIP]**
REGON: **[REGON]**
KRS: **[KRS, if applicable]**


For privacy-related matters, you may contact us at:


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# 3. What is Billogy?

Billogy is a passive revenue control and reconciliation platform designed for telecom, ISP, data center and usage-based infrastructure operators.

The platform can connect in a read-only manner to selected network, provisioning, CRM, billing and usage systems in order to identify discrepancies such as unbilled services, incorrect plans, rating differences, orphaned infrastructure and other revenue leakage.

Depending on the deployment, Billogy may process technical and operational identifiers such as subscriber identifiers, circuit identifiers, IP addresses, MAC addresses, timestamps, service information, network events and billing-related records.

The processing performed within a customer's environment may involve personal data controlled by that customer. In such circumstances, the customer generally remains the **data controller**, while Billogy acts as a **data processor** to the extent specified in the applicable DPA.

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# 4. Categories of personal data we may process

Depending on how you interact with Billogy, we may process the following categories of personal data:

### 4.1 Contact and business information

When you contact us or submit a business inquiry, we may process:

* first and last name;
* business email address;
* telephone number;
* company name;
* job title or professional role;
* information contained in your communication;
* information concerning your organization and its technical environment.

Our website's revenue audit form may request information such as your name, work email, company/organization, number of subscribers or monitored circuits, billing and CRM stack, network equipment/core and information concerning suspected discrepancies.

### 4.2 Technical information

When you use our website or services, we may process technical information such as:

* IP address;
* browser type and version;
* operating system;
* device information;
* date and time of access;
* requested pages and resources;
* referring URL;
* technical logs and diagnostic information;
* security and authentication information.

### 4.3 Service and infrastructure data

Where Billogy is deployed for a customer, the data processed may include:

* subscriber or customer identifiers;
* circuit identifiers;
* IP addresses;
* MAC addresses;
* VLAN or port identifiers;
* service and plan information;
* network provisioning information;
* RADIUS/AAA records;
* usage or telemetry information;
* billing line information;
* timestamps;
* CRM and operational records;
* reconciliation results and exception records.

The exact scope depends on the customer's configuration and the systems connected to Billogy.

Billogy is designed to minimize the amount of personal data processed and may use pseudonymized or otherwise minimized identifiers where technically feasible.

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# 5. Purposes of processing

We may process personal data for the following purposes:

### 5.1 Responding to inquiries

We process contact information and the content of inquiries in order to:

* respond to requests;
* provide information about Billogy;
* arrange demonstrations;
* perform preliminary revenue leakage assessments;
* communicate with prospective customers;
* prepare commercial proposals.

### 5.2 Providing and operating our services

Where you or your organization uses Billogy, we may process data to:

* provide the contracted service;
* perform reconciliation and revenue assurance;
* identify discrepancies between network, operational and billing systems;
* generate reports and exception records;
* provide technical support;
* maintain and secure the service;
* diagnose technical problems.

### 5.3 Security and fraud prevention

We may process technical information and logs to:

* protect our systems;
* detect unauthorized access;
* prevent abuse;
* investigate security incidents;
* maintain service integrity and availability.

### 5.4 Business administration

We may process personal data for:

* contract management;
* invoicing and accounting;
* legal and regulatory compliance;
* maintaining business records;
* exercising or defending legal claims.

### 5.5 Marketing and business development

Where permitted by applicable law, we may use business contact information to:

* communicate information about Billogy;
* send product or service updates;
* provide relevant business communications;
* conduct B2B marketing activities.

Where consent is required, we will obtain it before sending the relevant marketing communications.

You may withdraw marketing consent at any time.

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# 6. Legal bases for processing

Depending on the circumstances, we process personal data on the following legal bases under Article 6(1) GDPR:

### Article 6(1)(a) — consent

Where you have provided consent to a specific processing activity, such as certain forms of electronic marketing.

You may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

### Article 6(1)(b) — performance of a contract

Where processing is necessary to enter into or perform a contract with you or your organization.

### Article 6(1)(c) — legal obligation

Where processing is necessary for compliance with a legal obligation applicable to us.

### Article 6(1)(f) — legitimate interests

Where processing is necessary for our legitimate interests, including:

* operating and securing our website and services;
* responding to business inquiries;
* managing customer relationships;
* improving our services;
* preventing fraud and abuse;
* maintaining business records;
* establishing, exercising or defending legal claims.

We balance these interests against the rights and freedoms of individuals.

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# 7. Processing data on behalf of our customers

A key characteristic of Billogy is that the service may process operational and technical information originating from a customer's network, CRM, provisioning and billing systems.

In these circumstances, Billogy may act as a **processor** within the meaning of Article 28 GDPR.

The customer determines:

* which systems are connected;
* which categories of data are transferred;
* the purposes of processing;
* retention requirements;
* authorized users;
* applicable processing instructions.

Billogy processes such data only in accordance with the customer's documented instructions and the applicable contractual arrangements.

Where required, the parties enter into a Data Processing Agreement ("DPA") containing the information required by Article 28 GDPR.

This Privacy Policy does not replace such a DPA.

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# 8. Data minimization

Billogy is designed as a read-only control and reconciliation layer.

Where technically and operationally feasible, we seek to:

* minimize the amount of personal data processed;
* use technical identifiers instead of direct personal identifiers;
* use pseudonymization or anonymization where appropriate;
* avoid unnecessary access to sensitive financial information;
* restrict access to authorized personnel;
* retain data only for as long as necessary.

For example, reconciliation may be performed using subscriber identifiers, circuit identifiers, MAC addresses or other technical identifiers without requiring the storage of unnecessary personal information.

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# 9. Automated processing and profiling

Billogy uses automated matching and reconciliation mechanisms to identify discrepancies between technical, operational and billing records.

These mechanisms may correlate identifiers, timestamps, service parameters and billing records in order to identify potential revenue leakage.

Such processing is designed primarily for operational reconciliation and revenue assurance.

Billogy does **not** intend to make decisions producing legal or similarly significant effects on individuals based solely on automated processing within the meaning of Article 22 GDPR.

Where a customer configures Billogy to take automated actions affecting individuals, the customer remains responsible for ensuring that such processing complies with applicable data protection law and the relevant contractual arrangements.

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# 10. Data retention

We retain personal data only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

Retention periods may depend on the nature of the data and the purpose of processing.

For example:

* business inquiry data may be retained for the period necessary to handle the inquiry and subsequent business relationship;
* customer and contract records may be retained for the duration of the contractual relationship and thereafter for the period required for legal, accounting or claims-related purposes;
* technical and security logs may be retained for a limited period necessary for security, troubleshooting and auditing;
* customer service data processed on behalf of a customer is retained in accordance with the customer's instructions and the applicable DPA.

After the applicable retention period expires, data is securely deleted or anonymized.

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# 11. Data recipients

Personal data may be accessible to:

* authorized Billogy employees and contractors;
* hosting and infrastructure providers;
* software and IT service providers;
* communication and email service providers;
* security and monitoring providers;
* accounting, legal and professional advisers;
* public authorities where required by law.

Service providers are required to process personal data only for specified purposes and under appropriate confidentiality and data protection obligations.

Where Billogy processes customer data as a processor, additional subprocessors may be used in accordance with the applicable DPA.

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# 12. International data transfers

Some service providers used by Billogy may process data outside the European Economic Area ("EEA").

Where personal data is transferred outside the EEA, we use an appropriate legal mechanism under GDPR, such as:

* an adequacy decision of the European Commission;
* Standard Contractual Clauses approved by the European Commission;
* another lawful transfer mechanism recognized under applicable data protection law.

Where applicable, we assess additional safeguards required for international transfers.

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# 13. Cookies and similar technologies

The Billogy website may use cookies and similar technologies required for:

* proper operation of the website;
* security;
* maintaining user sessions;
* remembering selected preferences;
* measuring website performance;
* understanding website usage;
* improving the website.

Strictly necessary cookies may be used without consent where permitted by applicable law.

Where cookies or similar technologies require consent, they will be activated only after obtaining the required consent.

You may manage cookies through your browser settings and, where available, through the cookie consent mechanism provided on the website.

Disabling certain cookies may affect the functionality of the website.

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# 14. Third-party services

The Billogy website is operated using technology provided by **Odoo**.

Depending on the configuration of the website and services, third-party providers may process technical or personal data on our behalf.

Such providers may include hosting, infrastructure, communications, analytics, security and other technology providers.

We select service providers with regard to their ability to provide appropriate technical and organizational safeguards.

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# 15. Security

We implement appropriate technical and organizational measures designed to protect personal data against:

* unauthorized access;
* accidental loss;
* destruction;
* alteration;
* unauthorized disclosure;
* other unlawful or unauthorized processing.

Depending on the service configuration, security measures may include:

* encryption in transit;
* access controls;
* authentication mechanisms;
* least-privilege access;
* logging and monitoring;
* network security controls;
* backups and recovery procedures;
* separation of customer environments where applicable;
* controlled administrative access.

No internet-based system can guarantee absolute security. We therefore continuously review and improve our security measures.

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# 16. Your rights under GDPR

Subject to applicable legal conditions and limitations, you have the right to:

1. obtain confirmation as to whether we process your personal data;
2. access your personal data;
3. request rectification of inaccurate or incomplete data;
4. request erasure of your personal data;
5. request restriction of processing;
6. object to processing based on legitimate interests;
7. object to direct marketing;
8. receive personal data in a structured, commonly used and machine-readable format where the right to data portability applies;
9. withdraw consent at any time where processing is based on consent;
10. lodge a complaint with a supervisory authority.

Requests concerning your rights should be sent to:


We may need to verify your identity before processing certain requests.

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# 17. Right to lodge a complaint

You have the right to lodge a complaint with the supervisory authority responsible for data protection.

For individuals in Poland, the supervisory authority is:

**Prezes Urzędu Ochrony Danych Osobowych (UODO)**

You may contact the authority using the contact details published on its official website.

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# 18. Direct marketing

We may contact business representatives regarding Billogy, its services and related business information where such communication is permitted by applicable law.

Where consent is required, we will request it.

You may object to direct marketing at any time by contacting:


You may also use an unsubscribe mechanism included in electronic marketing communications, where available.

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# 19. Children's privacy

Billogy is a business-to-business service and is not intended for children.

We do not knowingly collect personal data from children for the purpose of providing our business services.

If you believe that a child has provided personal data to us without appropriate authorization, please contact us at:


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# 20. Links to other websites

The Billogy website may contain links to third-party websites or services.

We are not responsible for the privacy practices, security or content of third-party websites.

We recommend reviewing the privacy policies of such websites before providing them with personal data.

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# 21. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect:

* changes to our services;
* changes to applicable law;
* changes to technology;
* changes to our data processing practices.

The latest version will be published on the Billogy website.

The "Last updated" date at the beginning of this Privacy Policy indicates when it was most recently revised.

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# 22. Contact

If you have questions regarding this Privacy Policy or the processing of your personal data, please contact us:

**[FULL LEGAL COMPANY NAME]**
**[REGISTERED ADDRESS]**


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**Last updated: 30 August 2026**