1. Who is the controller of your data?

The controller of your personal data is FUNDACJA ROZWOJU PRZEDSIĘBIORCZOŚCI „TWÓJ STARTUP”, with its registered office in Warsaw (registered office address: ul. Żurawia 6/12, lok. 766, 00-503 Warszawa).

This Privacy Policy applies to the services of the Foundation provided through the organised part of the enterprise Steamlynx Games, contact details: telephone number +48571521600, e-mail address: commatica2025@gmail.com, carried out by Evgeny Zabavnikov.

2. Why do we process your Data?

A. In connection with the services provided through Steamlynx Games, consisting in providing educational services through an online platform. That is, for the purpose of entering into or performing the agreement (Article 6(1)(b) of the Regulation), your data will be stored until the agreement has been performed.

B. Fulfilling all legal obligations incumbent upon us in connection with the cooperation undertaken (Article 6(1)(c) of the Regulation); this purpose is related to the legal obligations to retain certain documents for the period specified by law, e.g.:

  • the Accounting Act of 29 September 1994 (Journal of Laws of 2017, item 1858);
  • the Act of 29 August 1997 – Tax Ordinance (Journal of Laws of 1997 No. 137, item 926);
  • the Act of 1 March 2018 on Counteracting Money Laundering and Financing of Terrorism (Journal of Laws of 2018, item 723).

C. For the purpose of potentially establishing, pursuing or defending against claims, which constitutes our legitimate interest (the legal basis under Article 6(1)(f) of the Regulation). The data will be processed until the claims become time-barred.

D. In the event of consent being given, your data will be processed within the scope and for the purpose specified in the consent given (the legal basis under Article 6(1)(a)). The data will be processed until the consent is withdrawn.

3. What data is subject to processing?

In order to enter into an agreement, we require the provision of data in the agreement / order form (if you do not provide such data, we will not enter into the agreement / execute the order). Additionally, we may request optional data which does not affect the conclusion of the agreement (if we do not receive such data, we will not be able, for example, to call the contact telephone number).

During the term of the agreement, while providing services, we obtain other data concerning you. The appearance of your personal data in our possession is a consequence of the operation of the services which you use.

4. To whom will the data be disclosed?

A. Public authorities, to the extent that they do not receive the data as part of specific proceedings on the basis of law, e.g. in connection with counteracting money laundering;

B. Entities that process your personal data on behalf of the Foundation on the basis of a data processing agreement concluded with the Foundation (so-called processors). These will include, among others: Beneficiaries of the Foundation, IT specialists, archiving companies, hosting companies;

C. External data controllers (so-called Joint Controllers to whom data is disclosed), e.g. legal advisers and attorneys-at-law, entities providing courier or postal services, entities acquiring receivables – in the event that you fail to pay our invoices on time;

D. Entities located outside the EEA, but only where this is necessary and with an appropriate level of protection ensured, primarily through:

  • Cooperation with entities in countries in respect of which an appropriate decision of the European Commission has been issued;
  • Application of standard contractual clauses issued by the European Commission.

The Controller always informs about the intention to transfer personal data outside the EEA at the stage of collecting such data.

5. Is the Data subject to profiling?

We inform you that your data will not be subject to profiling, i.e. automated analysis of your data and the preparation of predictions concerning your preferences or future behaviour (profiling means, for example, in the case of marketing profiling, determining which offer you may be most interested in based on your previous choices).

6. What rights do you have?

A. The right of access to the personal data processed by us (Article 15 of the Regulation),

B. The right to rectify the data provided, including correcting such data (Article 16 of the Regulation),

C. The right to erasure of personal data from our systems, the so-called “right to be forgotten” – if, in your opinion, there are no grounds for us to process your data, you may request that we erase it (Article 17 of the Regulation),

D. The right to restriction of processing of personal data – you may request that we restrict the processing of personal data exclusively to its storage or to carrying out actions agreed with you, if we have incorrect data concerning you or process it without a legal basis; or you do not want us to erase it because you need it for the establishment, exercise or defence of claims; or for the duration of an objection submitted by you against the processing of data (Article 18 of the Regulation),

E. The right to data portability – you have the right to receive from us, in a structured, commonly used and machine-readable format (e.g. “.csv” format), personal data concerning you which is in our possession on the basis of an agreement or consent given. This right shall apply where we hold the data in electronic form – if the data is held only in paper form, you will not be able to exercise this right. You may instruct us to transmit such data directly to another entity (Article 20 of the Regulation),

F. The right to withdraw consent to the processing of personal data – at any time you have the right to withdraw consent to the processing of personal data which we process on the basis of consent – Article 7(3) of the Regulation. Withdrawal of consent shall not affect the lawfulness of processing carried out on the basis of consent before its withdrawal. Consent may be withdrawn by sending an e-mail to: commatica2025@gmail.com

G. The right to object – you may object to the processing of your personal data if the basis for the use of such data is our legitimate interest – Article 21 of the Regulation. In such a situation, after considering your request, we will no longer be able to process the personal data covered by the objection on that basis, unless we demonstrate the existence of legitimate grounds for the processing which override your interests, rights and freedoms.

H. If, in your opinion, the processing of your data violates the provisions of the Regulation, you have the right to lodge a complaint with the supervisory authority, i.e. the President of the Personal Data Protection Office.

7. Contact

If you require additional information relating to the protection of personal data or wish to exercise your rights, please contact us at the following e-mail address:

rodo@twojstartup.pl

(C) Steamlynx 2026. Fundacja Rozwoju Przedsiębiorczości "TwójStartUp" ul. Żurawia 6/12 lok 766, 00-503 Warszawa