1. Definitions

1.1 “Company”, “we”, or “us” refers to L-TEK Sp. z o.o., a limited liability company incorporated under the laws of Poland, with its registered office at Dzwonek 24, 34-100 Gorzeń Dolny.

1.2 “Game” refers to the mobile application L-TEK Rhythm Hub.

1.3 “User” or “you” refers to any individual who accesses or utilizes the Game.

1.4 “Mat” refers to the interactive hardware device used in conjunction with the Game, uniquely identified by its serial number.

1.5 “Personal Data” means any information relating to an identified or identifiable natural person.

2. Data Controller

2.1 The Company is the Data Controller of Personal Data processed pursuant to this Privacy Policy. All inquiries regarding data protection may be directed to our support team at [email protected].

3. Categories of Data Collected

3.1 Upon the initial connection of your Mat to the Game, we automatically collect and store the serial number of the Mat.

3.2 We do not collect or store any other identifiers or Personal Data, including but not limited to names, email addresses, IP addresses, geolocation data, or device identifiers.

3.3 The Game is not intended for children under the age of 13. We do not knowingly collect Personal Data from anyone under the age of 13.

4. Purposes of Processing and Legal Basis

4.1 We process the Mat serial number exclusively for the following purposes:

  • To verify the authenticity and proper registration of your Mat;
  • To ensure compatibility and provide ongoing access to the Game.

4.2 The legal basis for processing the serial number is our legitimate interest in protecting against unauthorized hardware usage and maintaining service integrity, as contemplated under Article 6(1)(f) of the GDPR. This legitimate interest has been duly balanced against the rights and freedoms of data subjects and does not override their interests.

5. Third-Party Processors and International Transfers

5.1 Android Verification: To validate the Mat serial number on Android devices, we transmit the serial number to Amazon Web Services (AWS). No additional Personal Data is shared or retained by AWS.

5.2 iOS In-App Purchases: All purchase transactions on iOS are processed exclusively by Apple Inc. via its In-App Purchase API. We do not receive, process, or store payment transaction data or receipts.

5.3 Because AWS is located outside the European Economic Area (EEA), we rely on the European Commission’s Standard Contractual Clauses (SCCs) adopted under Article 46(2)(c) of the GDPR to ensure an adequate level of protection for Personal Data transferred.

6. Data Retention

6.1 We retain the Mat serial number for the entire duration of your use of the Game and thereafter for a period of up to 10 years, unless you request its earlier deletion as described in Section 8.

7. Data Security

7.1 We implement technical and organizational measures commensurate with the risk, including encryption of the serial number in transit (via TLS/HTTPS) and at rest (using AES-256).

7.2 Access to stored data is restricted to authorized personnel on a need-to-know basis.

8. Your Rights

8.1 You have the right to access, rectify, erase, or restrict processing of your Personal Data, the right to object to processing, and the right to lodge a complaint with a supervisory authority.

8.2 To exercise any of these rights, please submit your request to [email protected]. We will respond in accordance with applicable law.

9. Cookies and Similar Technologies

9.1 The Game does not utilize cookies, local storage, web beacons, or similar tracking technologies on any platform.

10. Changes to This Privacy Policy

10.1 We reserve the right to modify this Privacy Policy at any time. In the event of material changes, we will provide notice via an in-app notification. Continued use of the Game following such notice shall constitute your acceptance of the amended Policy.

11. Contact Information

For any questions or concerns regarding this Privacy Policy, please contact our support team at [email protected].

12. Governing Law

12.1 This Privacy Policy shall be governed by and construed in accordance with the laws of Poland. Any disputes arising out of or relating to this Policy shall be subject to the exclusive jurisdiction of Polish courts.

13. Language

13.1 In case of discrepancies between different language versions of this Policy, the English version shall prevail.