Privacy Policy

Fulfilling our obligations under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as GDPR), we provide information regarding the processing and protection of your personal data.

The information contained in the Privacy Policy will help you understand what personal data we collect and process, for what purpose it is used, and what rights you have in connection with the protection of your personal data.

WHO IS THE CONTROLLER OF YOUR PERSONAL DATA:

Personal Data Controller is Sundog S.A. with its registered office in Białystok, Warszawska 14/3, 15-063 Bialystok (hereinafter referred to as PDC or Sundog).

HOW YOU CAN CONTACT PDC:

You may contact PDC:

1) by email: contact@sundog.games

2) by post: ul. Warszawska 14/3, 15-063 Białystok.

FOR WHAT PURPOSE AND ON WHAT LEGAL BASIS PDC PROCESSES YOUR PERSONAL DATA AND HOW LONG THEY ARE STORED:

I. Information intended for PDC Clients and Contractors:

If you have a contract with PDC, in particular a sales contract, a cooperation contract, a service contract then PDC processes your data for the purpose, on the legal basis and for the period indicated below:

  
      Purpose of data processing
      Legal basis for data processing
      Period of storage/processing of personal data
    
  Conclusion and execution of the Agreement with PDC 

Article 6(1)(b) GDPRDuration of the Agreement
Pursuing and defending against claims arising from business activities, which is a legitimate interest of data processing by PDCArticle 6(1)(f) GDPR
  A period equal to the statute of limitations for claims for non-performance or improper performance of the contract - as a rule, 6 years and/or 3 years, and a sales contract - as a rule, 2 years
The end of the limitation period is the last day of the calendar year. The aforementioned period may be extended by the time necessary for the final conclusion of the conducted proceedings or the execution of obligations and rights resulting from the issued decision

Fulfillment by PDC of its obligations under the law, in particular those related to bookkeeping and tax records Article 6(1)(c) of the GDPR in connection with Article 74(2) of the Accounting Act and other special regulationsThe period of storage of accounting and tax records under the law, i.e. a period of 5 years, counted from the end of the calendar year in which the tax obligation arose

Purpose of data processing	Legal basis for data processing	Period of storage/processing of personal data
Conclusion and execution of the Agreement with PDC	Article 6(1)(b) GDPR	Duration of the Agreement
Pursuing and defending against claims arising from business activities, which is a legitimate interest of data processing by PDC	Article 6(1)(f) GDPR	A period equal to the statute of limitations for claims for non-performance or improper performance of the contract - as a rule, 6 years and/or 3 years, and a sales contract - as a rule, 2 years The end of the limitation period is the last day of the calendar year. The aforementioned period may be extended by the time necessary for the final conclusion of the conducted proceedings or the execution of obligations and rights resulting from the issued decision
Fulfillment by PDC of its obligations under the law, in particular those related to bookkeeping and tax records	Article 6(1)(c) of the GDPR in connection with Article 74(2) of the Accounting Act and other special regulations	The period of storage of accounting and tax records under the law, i.e. a period of 5 years, counted from the end of the calendar year in which the tax obligation arose

II. Information intended for employees/co-workers of PDC Clients or Contractors:

If you are an employee/co-worker of a Client or Contractor of PDC, e.g. you act as a representative of a Client or Contractor of PDC, as a contact person or a person authorized to perform certain actions on behalf of a Client or Contractor, including actions arising from a contract entered into by the Client or Contractor with PDC then PDC processes your data for the purpose, on the legal basis and for the period indicated below:

  
      Purpose of data processing
      Legal basis for data processing
      Period of storage/processing of personal data
    

  Implementation of the contract entered into by Sundog with the entity on whose behalf you are acting, which is a legitimate legal interest of PDCArticle 6(1)(b), (f) GDPRThe term of the contract for which you act as a representative of Sundog's contractor/customer
Pursuing and defending against claims arising from business activities, which is a legitimate interest of data processing by PDC 

Article 6(1) (f) GDPR
A period equal to the statute of limitations for claims for non-performance or improper performance of a contract - as a rule, 3 years and/or torts
The end of the limitation period is the last day of the calendar year.

The aforementioned period may be extended by the time necessary for the final conclusion of the conducted proceedings or the execution of obligations and rights resulting from the issued decision
Bookkeeping and tax records, if your data were provided in a contract or other documents related to the implementation by PDC of its obligations under the law, in particular tax and accounting regulationsArticle 6(1)(c) of the GDPR in connection with Article 74(2) of the Accounting Act and other special regulationsThe period of storage of accounting and tax records under the law, i.e. a period of 5 years counted from the end of the calendar year in which the tax obligation arose

Purpose of data processing	Legal basis for data processing	Period of storage/processing of personal data
Implementation of the contract entered into by Sundog with the entity on whose behalf you are acting, which is a legitimate legal interest of PDC	Article 6(1)(b), (f) GDPR	The term of the contract for which you act as a representative of Sundog's contractor/customer
Pursuing and defending against claims arising from business activities, which is a legitimate interest of data processing by PDC	Article 6(1) (f) GDPR	A period equal to the statute of limitations for claims for non-performance or improper performance of a contract - as a rule, 3 years and/or torts The end of the limitation period is the last day of the calendar year. The aforementioned period may be extended by the time necessary for the final conclusion of the conducted proceedings or the execution of obligations and rights resulting from the issued decision
Bookkeeping and tax records, if your data were provided in a contract or other documents related to the implementation by PDC of its obligations under the law, in particular tax and accounting regulations	Article 6(1)(c) of the GDPR in connection with Article 74(2) of the Accounting Act and other special regulations	The period of storage of accounting and tax records under the law, i.e. a period of 5 years counted from the end of the calendar year in which the tax obligation arose

III. Information intended for persons interested in PDC's offer:

If you are interested in PDC's offerings or the entity on whose behalf or for whose benefit you are acting is interested in PDC's offerings then PDC will process your data for the purpose, on the legal basis and for the period indicated below:

  
      Purpose of data processing
      Legal basis for data processing
      Period of storage/processing of personal data
    

  Presenting the requested offer and conducting correspondence/discussions related to the presented offer
Article 6(1)(b) GDPR - taking action prior to entering into a contract at your request or at the request of the entity on whose behalf or for whose benefit you are acting. 
Article 6(1)(f) GDPR - PDC's legitimate interest, which is to provide the offer you have requested


1) The period necessary to present an offer and conduct correspondence/conversations related to the presented offer, but no longer than until the withdrawal of consent to the processing of personal data or the submission of an effective objection to the processing of data for this purpose (in the case of processing of personal data on the basis of Article 6(1)(f) GDPR);
2) The period necessary to take action on the request prior to entering into a contract (in case of data processing on the basis of Article 6(1)(b) GDPR)
 
Pursuing and defending against claims arising from business activities, which is a legitimate interest of data processing by PDC
Article 6(1)(f) GDPR

The period necessary to assert and defend against claims, taking into account the periods of limitation specified in generally applicable laws

Purpose of data processing	Legal basis for data processing	Period of storage/processing of personal data
Presenting the requested offer and conducting correspondence/discussions related to the presented offer	Article 6(1)(b) GDPR - taking action prior to entering into a contract at your request or at the request of the entity on whose behalf or for whose benefit you are acting. Article 6(1)(f) GDPR - PDC's legitimate interest, which is to provide the offer you have requested	1) The period necessary to present an offer and conduct correspondence/conversations related to the presented offer, but no longer than until the withdrawal of consent to the processing of personal data or the submission of an effective objection to the processing of data for this purpose (in the case of processing of personal data on the basis of Article 6(1)(f) GDPR); 2) The period necessary to take action on the request prior to entering into a contract (in case of data processing on the basis of Article 6(1)(b) GDPR)
Pursuing and defending against claims arising from business activities, which is a legitimate interest of data processing by PDC	Article 6(1)(f) GDPR	The period necessary to assert and defend against claims, taking into account the periods of limitation specified in generally applicable laws

IV. Information intended for persons who contact PDC by email

If you contact PDC or persons acting on behalf of PDC by email then PDC processes your data for the purpose, on the legal basis and for the period indicated below:

  
      Purpose of data processing/th>
      Legal basis for data processing
      Period of storage/processing of personal data
    
  Contact in connection with an inquiry/request submitted by email or contact form.   
Article 6(1)(b) - performance of a contract or taking action prior to entering into a contract at your request or at the request of the entity on whose behalf or for whose benefit you are acting.

Article 6(1)(f) GDPR - PDC's legitimate interest, which is to respond to your inquiry/request

1) The period necessary to conduct correspondence/conversations related to the inquiry/request, but no longer than until the withdrawal of consent to the processing of personal data or the submission of an effective objection to the processing of data for this purpose (in the case of processing of personal data on the basis of Article 6(1)(f) GDPR);

2) The period necessary to perform activities related to the performance of a contract or to a request prior to the conclusion of a contract (in the case of processing of data on the basis of Article 6(1)(b) GDPR)

Pursuing and defending against claims arising from business activities, which is a legitimate interest of data processing by PDCArticle 6(1)(f) GDPRThe period necessary to assert and defend against claims, taking into account the periods of limitation specified in generally applicable laws.

Purpose of data processing/th>	Legal basis for data processing	Period of storage/processing of personal data
Contact in connection with an inquiry/request submitted by email or contact form.	Article 6(1)(b) - performance of a contract or taking action prior to entering into a contract at your request or at the request of the entity on whose behalf or for whose benefit you are acting. Article 6(1)(f) GDPR - PDC's legitimate interest, which is to respond to your inquiry/request	1) The period necessary to conduct correspondence/conversations related to the inquiry/request, but no longer than until the withdrawal of consent to the processing of personal data or the submission of an effective objection to the processing of data for this purpose (in the case of processing of personal data on the basis of Article 6(1)(f) GDPR); 2) The period necessary to perform activities related to the performance of a contract or to a request prior to the conclusion of a contract (in the case of processing of data on the basis of Article 6(1)(b) GDPR)
Pursuing and defending against claims arising from business activities, which is a legitimate interest of data processing by PDC	Article 6(1)(f) GDPR	The period necessary to assert and defend against claims, taking into account the periods of limitation specified in generally applicable laws.

V. Information intended for PDC shareholders and their representatives:

If you are a shareholder of Sundog or you represent them then PDC will process your data for the purpose, on the legal basis and for the period indicated below:

  
      Purpose of data processing

      Legal basis for data processing
      Period of storage/processing of personal data
    
  Fulfillment of obligations and rights related to the ownership of PDC shares  

Article 6(1)(b) of the GDPR
PDC shareholding period

Pursuing and defending against claims arising from business activities, which is a legitimate interest of data processing by PDC

Article 6(1)(f) GDPR

The period necessary to assert and defend against claims, taking into account the periods of limitation specified in generally applicable laws

Implementation of obligations under the law, in particular the Code of Commercial Companies 

Article 6(1)(c) of the GDPR in connection with other specific provisions

The period required by the relevant laws for the retention of records related to corporate affairs

Purpose of data processing	Legal basis for data processing	Period of storage/processing of personal data
Fulfillment of obligations and rights related to the ownership of PDC shares	Article 6(1)(b) of the GDPR	PDC shareholding period
Pursuing and defending against claims arising from business activities, which is a legitimate interest of data processing by PDC	Article 6(1)(f) GDPR	The period necessary to assert and defend against claims, taking into account the periods of limitation specified in generally applicable laws
Implementation of obligations under the law, in particular the Code of Commercial Companies	Article 6(1)(c) of the GDPR in connection with other specific provisions	The period required by the relevant laws for the retention of records related to corporate affairs

WHERE DOES PDC OBTAIN YOUR PERSONAL DATA FROM?

In most cases, PDC obtains your personal data directly from you. In certain situations, PDC may obtain your data:

From the entity on whose behalf or for whose benefit you are acting (applies in particular to employees/co-workers of PDC's Clients or Contractors); the data provided are most often your name, surname, official position, e-mail address, telephone number;
From publicly available sources, including business registries such as KRS and CEiDG.

DO YOU HAVE TO PROVIDE YOUR DATA?

  
  Customers and Contractors

Your provision of data is voluntary, but is necessary for the conclusion and execution of the contract. Refusal to provide the data may result in the inability to conclude a contract or its execution. 
Employees/co-workers of the Client or Contractor/representatives of the Client or Contractor/contact persons/persons performing activities on behalf of the Client or Contractor PDC
If you provide personal data directly to PDC, the provision of such data is voluntary, but necessary for PDC to perform a contract on behalf of the entity on whose behalf you are acting. If you do not provide the data, the execution of the contract may be hindered.
Persons interested in PDC's offer 
Provision of your data is voluntary, but necessary to present you with an offer and conduct communications/discussions related to the presented offer. Failure to provide data will result in the inability to present an offer.

Persons contacting via e-mail 
Provision of your data necessary to answer and respond to the application/question is a condition for obtaining a response. Failure to provide data will result in the inability to respond to your application/question.

Shareholders and shareholder representatives

The provision of your personal data is voluntary, but necessary for the realization of the rights and obligations of the shareholder. If you fail to provide the data, it will be impossible for the shareholder to realize these rights and for PDC to fulfill these obligations.

WHO MAY HAVE ACCESS TO YOUR PERSONAL DATA:

Your personal data may be accessed by:

Persons authorized by PDC to process your personal data at PDC's direction;
Entities entrusted by PDC with the processing of your personal data, including:

providers of technical and organizational services
providers of legal and advisory services, including for the assertion of claims related to PDC's business activities and defense against claims;

other entities, persons or bodies - to the extent and under the terms of the law,

with the proviso, that sharing of your data with the aforementioned entities is carried out in accordance with the applicable laws and with full compliance with the rules related to their security.

WHAT RIGHTS YOU HAVE IN CONNECTION WITH THE PROCESSING OF PERSONAL DATA BY PDC:

In connection with the processing of your personal data by PDC, you have the following rights:

the right to access your personal data (Article 15 GDPR);
the right to rectify your personal data (Article 16 GDPR);
the right to request erasure in the cases specified in Article 17(1), subject to the exceptions specified in the provision of Article 17(3) of the GDPR;
the right to request restriction of data processing in the cases specified in Article 18 GDPR;
the right to data portability in the cases specified in the provisions of Article 20 GDPR;
the right to withdraw consent to the processing of personal data, provided that the processing is based on consent;
the right to lodge a complaint with a data protection authority (i.e., the President of the Office for Personal Data Protection) in the event that you believe that the PDC has violated data protection regulations.

In addition, due to the fact that your personal data will be processed by PDC for purposes arising from PDC's legitimate interests, you have the right to object to the processing of your personal data for the aforementioned purposes for reasons related to your particular situation.