privacy policy

We're pleased that you're interested in SUDIDLER. The SUDIDLER places a great value on data protection.

 

Personal data, such as a data subject's name, address, email address, or phone number, must always be processed in compliance with the General Data Protection Regulation (GDPR) and any applicable country-specific data protection rules.

 

We would like to inform the general public about the nature, scope, and purpose of the personal data we collect, use, and process by means of this data protection declaration. Furthermore, data subjects are notified of their rights by this data protection declaration.

This Privacy Policy is built on the principle of transparency, with the concise legal language used to make the provisions more comprehensible.

 

The SUDIDLER, as controller, has put in place a number of technical safeguards to ensure the most complete protection of personal data processed through this App. However, security vulnerabilities in Internet-based data transfers are possible, therefore complete protection cannot be guaranteed.

 

The term Application (hence referred to as "App") will be defined as a software program that is designed to execute a specified function directly for the user or, in some situations, for another application program, for the sake of consistency.

 

1. Defined terms

 

1.1. SUDIDLER Privacy Policy is based on the wording used by European legislators in enacting the General Data Protection Regulation (GDPR). The general public should be able to read and comprehend our Privacy Policy.

 

1.2. The following terminology is used in this Privacy Policy:

 

a) Personal information

 

Any information belonging to an identified or identifiable natural person (“data subject”) is referred to as personal data. An identifiable natural person is one who can be identified, either directly or indirectly, using an identifier such as a name, an identification number, location data, a facial image, an online identifier, or one or more factors specific to that natural person's physical, physiological, genetic, mental, economic, cultural, or social identity.

b) Data subject

Any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing is referred to as a data subject.

c) Processing

Any activity or combination of activities conducted on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, and so on, is referred to as processing.

d) Processing limitations

The labelling of personal data that has been saved with the goal of limiting its future processing is known as restriction of the processing.

 

e) Profiling

Profiling is any type of automated personal data processing that uses personal data to analyze or predict certain aspects of a natural person's work performance, financial situation, health, personal preferences, interests, reliability, behaviour, location, or movements.

 

f) Pseudonymisation

Pseudonymisation is the process of processing personal data so that it can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to a specific data subject.

 

g) The person in charge of the processing, often known as the controller.

 

The controller or person responsible for processing is a natural or legal person, public authority, agency, or other body that determines the purposes and means of processing personal data alone or in collaboration with others; where the purposes and means of processing are determined by European Union or Member State law, the controller or specific criteria for its nomination may be prescribed.

 

h) Processor 

A processor is a natural or legal person, government agency, or other entity that acts on behalf of the controller to process personal data.

 

i) Recipient

A natural or legal person, public authority, agency, or other organization to whom personal data is provided, whether or not it is a third party. Public authorities, on the other hand, that may receive personal data in the course of a specific investigation under European Union or Member State legislation are not considered recipients; the data must be treated in compliance with the applicable data protection standards for the investigation's goals.

 

j) Third party

A third party is a natural or legal person, public authority, agency, or entity that is not the data subject, controller, processor, or those who are entitled to treat personal data under the direct authority of the controller or processor.

 

k) Informed consent

Consent of the data subject is any freely given, explicit, informed, and unequivocal expression of the data subject's desires by which he or she expresses consent to the processing of personal data relating to him or her by a statement or by a clear affirmative action.

 

2. Name and Address of the controller

2.1. The Controller for the purposes of the General Data Protection Regulation (GDPR), and other data protection laws applicable in the Member States of the European Union and other provisions related to data protection, is:

Marcin Matysek

 

2.2. Rights of the data subject

a) Right of confirmation

The European legislator has provided each data subject the right to request confirmation from the controller as to whether or not personal data about him or her is being processed.

 

b) Right of access

Each data subject should have the right granted by the European legislature to receive free information and a copy of his or her personal data held by the controller at any time. Furthermore, the data subject has access to the following information under European directives and regulations:

• the processing's goals; the types of personal data involved;
• recipients or categories of recipients, including recipients in non-EU countries or foreign organizations, to whom personal data has been or will be given;
• if possible, the anticipated time for which the personal data will be held, or if that is not possible, the criteria used to establish that period; if not possible, the criteria used to decide that period;
• the existence of a right to seek from the controller the rectification or deletion of personal data affecting the data subject, as well as the restriction or opposition to such processing;
• the possibility of filing a complaint with a supervisory authority;
• If the data subject's personal data isn't gathered directly from them, any available information about their source should be included.
• the existence of automated decision-making, including profiling, as defined in Article 22(1) and (4) of the GDPR, and, at a minimum, meaningful information about the logic involved, as well as the significance and expected repercussions of such processing for the data subject
•  

c) Right to rectification

Each data subject has the right provided by the European legislature to have inaccurate personal data about him or her rectified by the controller without undue delay. The data subject has the right to have incomplete personal data completed, including by giving a supplementary statement, taking into account the purposes of the processing.

 

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to have personal data concerning him or her erased without undue delay from the controller, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

With respect to the purposes for which they were collected or otherwise processed, personal data is no longer required.

Where the processing is based on point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR and there is no other lawful ground for the processing, the data subject withdraws consent.

The data subject objects to processing under Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to processing under Article 21(2) of the GDPR and there are no overriding legitimate grounds for the processing.

Personal data has been processed in an unauthorized manner.

Personal data must be destroyed in order to comply with a legal requirement imposed by European Union or Member State law on the controller.

The personal information was collected in compliance with the GDPR's Article 8(1) principles.

Where the controller has made personal data public and is required by Article 17(1) to erase the personal data, the controller shall take reasonable steps, including technical measures, to notify other controllers processing the personal data that the data subject has requested the erasure of any links to, or copies or replications of, the personal data.

 

e) Right of restriction of processing

When one of the following applies, each data subject has the right provided by the European legislature to demand from the controller a restriction of processing:

The data subject argues the accuracy of the personal data for a time that allows the controller to verify the accuracy of the personal data.

The processing is unlawful, and the data subject opposes the erasure of his or her personal data and instead wants that their use be restricted.

The controller no longer requires the personal data for processing purposes, but the data subject does for the purposes of establishing, exercising or defending legal rights.

The data subject has objected to processing under Article 21(1) of the GDPR, pending verification of whether the controller's legitimate reasons outweigh the data subject's.

If one of the aforementioned conditions is met, and a data subject wishes to request that SUDIDLER restrict the processing of personal data held by it, he or she may contact the controller at any time. The processing will be restricted by the controller of SUDIDLER.

 

f) Right to data portability

The European legislator has granted each data subject the right to receive personal data about him or her. As a result, he or she shall have the right to transmit this data to another controller without interference from the controller to whom the personal data was provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out in accordance with Article 6(1) of the GDPR, and the

Furthermore, in exercising his or her right to data portability under Article 20(1) of the GDPR, the data subject has the right to have personal data transmitted directly from one controller to another, if technically feasible and not infringing on others' rights and freedoms.

 

g) Right to object

Each data subject shall have the right provided by the European legislature to object, at any time, to the processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR, on grounds relevant to his or her particular situation. This is true for profiling based on these requirements as well.

In the event of an objection, SUDIDLER will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing that override the data subject's interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims.

 

h) Automated individual decision-making, including profiling

Each data subject has the right granted by the European legislator not to be subjected to a decision based solely on automated processing, including profiling, that has legal consequences for him or her, or similarly significantly affects him or her, as long as the decision (1) is not required for the data subject to enter into or perform a contract with the data controller.

 

i) Right to withdraw data protection consent

The European legislator has provided each data subject with the right to withdraw his or her consent to the processing of his or her personal data at a time.

If the data subject wishes to exercise his or her right to withdraw permission, he or she may do so at any time by contacting SUDIDLER controller.

 

3. Type of Personal Data Processed

Name, Last name and other Contact Details 

When you create an account to log in to SUDIDLER we may ask for your personal information such as name, last name, contact details (email), password creation and payment details where applicable. 

SUDIDLER could process such data only with your explicit consent and in compliance with the current legislation. SUDIDLER, therefore, underlines the importance of receiving your explicit consent for the processing of this data.

Navigation Data and Cookies

During normal operation, the computer systems and software that run the Application acquire some Personal Data whose transmission is inherent in the use of Internet communication protocols. This information is not gathered by SUDIDLER to be associated with known data subjects, but it may, by its very nature, allow data subjects to be identified through processing and association with data kept by third parties.

The IP addresses or domain names of the computers used by users connecting to the SUDIDLER Application, the addresses of the requested services in URI (Uniform Resource Identifier) notation, the time of the request, the method used in submitting a request to the server, the size of the file obtained in response, and the numerical code indicating the status are all included in this category of data.

A cookie is a short file placed on a user's computer that is designed to hold a limited bit of data specific to a single client and website and may be retrieved by the web server or the client computer. When you visit a website, a cookie may be used to track your browser's activity and offer you a more consistent, efficient experience.

We may use cookies to track website usages, such as the number of visits to a certain page, visitors' entry and exit points, and details of activities and searches conducted with associated data. We may use cookies to maintain track of your transaction from one page to the next if you make a purchase. The cookie does not include any personal information and is not used for any other reason.

On our websites and mobile apps, we may employ third-party web analytics providers (such as Google, Facebook, affiliate tracking etc.). Cookies and web beacons are used by the analytics providers who manage these services to help us understand how visitors use our websites and apps.

Our websites may also contain links to websites operated by third parties over whom we have no control. We are not responsible for the privacy practices or content of such websites, and we recommend that you read the privacy policies of any third-party websites you visit that are linked to us.

 

Personal Data Processing of Children below the age of 18 Years

Only those over the age of 18 are permitted to use the Application.

Users under the age of 18 who access SUDIDLER should be reminded that they can only do so under the supervision and guidance of their parents.

 

Purposes of the Personal Data Processing

We will process your Personal Data for the following purposes:

• Proceeding with the registration of an account.
• Billing process.

 

Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

• AdMob by Google

AdMob by Google is provided by Google Inc.

You can opt-out from the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en

For more information on how Google uses the collected information, please visit the "How Google uses data when you use our partners' sites or app" page: http://www.google.com/policies/privacy/partners/ or visit the Privacy Policy of Google: http://www.google.com/policies/privacy/

• Unity Ads

Unity Ads is provided by Unity Technologies.

You can opt-out from Unity Ads service by following the instructions as described by Unity Technologies on their Privacy Policy page: https://unity3d.com/legal/privacy-policy

For more information about Unity Technologies, please visit Unity Technologies Privacy Policy: https://unity3d.com/legal/privacy-policy

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• Apple Store In-App Payments

Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

• Google Play In-App Payments

Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/

Lawful Basis for Processing Personal Data

For SUDIDLER to comply with the applicable legal responsibilities, the submission of Personal Data and the related processing for reasons relating to Legal Compliance is required.

When you provide your Personal Data to SUDIDLER, we are required to process it in accordance with applicable laws, which may include storing and communicating it to the appropriate authorities for tax, customs, or other purposes.

 

Personal Data Sharing

SUDIDLER will manage the Personal Data for the objectives of application development and management and is permitted to process them for the aforementioned reasons. Regardless of whether or not they have acquired an adequate legal duty, all employees or agents of SUDIDLER are bound by confidentiality.

Third parties appointed as Data Processors will have access to personal data when they process data on behalf of SUDIDLER (for example, suppliers with whom it is necessary to interact for provision of the service such as hosting providers, platform providers for sending e-mails or suppliers who perform technical maintenance activities including the maintenance of network equipment and electronic communications networks).

 

Privacy Policy Amendments

This Privacy Policy was published on (19.XI.2021). Due to changes in the applicable legislation, SUDIDLER reserves the right to modify or simply update its content, in part or all. SUDIDLER will be able to notify you of these modifications as soon as they are implemented, and they will take effect once they are published on the Application. SUDIDLER welcomes you to return to this part on a frequent basis to familiarize yourself with the most recent and updated version of the Privacy Policy, so that you are always informed about the Personal Data gathered and how SUDIDLER uses it.