# DPA Annex A — description of processing

**Service Provider / Operator:** Brillnet Piotr Adamski, ul. Henryka Sienkiewicza 73/6, 90-057 Łódź, Polska, NIP 7321779060, REGON 101551294

**Service contact:** [kontakt@wm-admin.pl](mailto:kontakt@wm-admin.pl)

**Privacy and breach contact:** [privacy@brillnet-app.com](mailto:privacy@brillnet-app.com)

**Website:** [wm-admin.pl](https://wm-admin.pl/?lang=en)

**Version:** 2026-10-12-beta.2

This is an informational translation. The Polish version is binding.

## 1. Subject matter and duration

- **Subject matter:** hosting and operating a Community in WM Administrator.
- **Duration:** from Community activation until data deletion after the Agreement ends, including the export and backup expiry periods described in the DPA.
- **Frequency:** continuous or initiated by Users and integrations.
- **Scale:** depends on the number of Communities, units, Users and documents specified in the Plan.

## 2. Nature of operations

Collection, recording, organisation, structuring, storage, retrieval, consultation, matching, restriction, calculations and reporting, communication to authorised recipients, export, copying and deletion. Integrations send data only on instruction and within the scope configured by the Customer.

## 3. Purposes

Maintaining registers of communities, units and rights; calculating charges and balances; handling financial and technical documents, cases, defects, meetings, votes, resolutions, suppliers and orders; communication; reporting and audit; migration, export, security and support.

## 4. Categories of individuals

- unit owners and co-owners;
- residents, tenants and other occupants;
- authorised agents and representatives;
- board and committee members;
- property manager's employees and associates;
- accountants, technicians, administrators and auditors;
- suppliers, contractors and their representatives;
- people submitting cases and participants in meetings and votes;
- debtors and creditors connected with Community settlements.

## 5. Categories of data

| Category | Examples and restrictions |
|---|---|
| identification | first name, surname, identifier, role; PESEL only where the Customer demonstrates necessity and a legal basis |
| contact | correspondence address, email, telephone |
| unit and legal title | unit number/address, share, owner/tenant status, dates and authority documents |
| financial and settlement | charges, payments, balances, debt, settlement account; no full payment card details |
| accounting and tax | invoices, account allocation, counterparty details, optical character recognition (OCR) results, KSeF/JPK files prepared by the Customer |
| management and governance | resolutions, votes, minutes, powers of attorney, attendance |
| technical and operational | requests, photographs, reports, damage, access to a unit |
| communication | messages, notifications, form content, delivery history |
| suppliers and orders | offers, contracts, contact persons, assessments and settlements |
| security and audit | User, time, operation, change, correlation, limited network data |
| special categories | may occur incidentally in documents or cases; the Customer must demonstrate necessity and a legal basis and restrict access |
| convictions and offences | not an intended feature; entering such data requires a separate basis and Customer safeguards |

## 6. Specific instructions

1. OCR does not automatically post accounting entries; an authorised User approves the result.
2. KSeF/JPK require authority, correct configuration and human approval.
3. Brillnet does not initiate bank transfers or make decisions on debt, resolutions, rights to units or benefits.
4. The Customer sets retention periods according to the [retention matrix](/retencja?lang=en).
5. Special categories of data should not be entered in general-purpose fields or support requests unless necessary.


> Contact details and domains in this presentation were updated on 2026-09-08. The original document and previous acceptances remain unchanged.