Privacy Policy

This Privacy Policy explains how Komondor ("we," "us," or "our") collects, uses, discloses, and protects personal data when you use our web application (komondor.app).

We are committed to respecting privacy rights and adhering to applicable data protection legislation, including the General Data Protection Regulation (GDPR) (EU 2016/679).

1. Roles Under Data Protection Law

• For Account Holders (Instructors): Komondor acts as a Data Controller regarding your account registration, contact details, and payment information.
• For Group Participant Data: When Instructors input details about their students, athletes, or participants (e.g., names, attendance records, payment status), the Instructor acts as the Data Controller, and Komondor acts as a Data Processor processing that data strictly on the Instructor's behalf to deliver the Service.

2. Information We Collect

A. Information You Provide Directly

• Account Data: Name, email address, password hash, and business/organization name upon registration.
• Participant Data: Names, attendance records, group names, and payment status tracking entered into the system by the Instructor.
• Payment Information: Transaction metadata processing details (handled via third-party payment processors; full credit card details are never stored directly on our servers).

B. Information Collected Automatically

• Device & Usage Technical Data: IP address, browser type, operating system version, access timestamps, and usage patterns required for operating the Progressive Web App (PWA) and ensuring security.

3. Legal Basis for Processing (GDPR)

We process personal data based on the following legal grounds:

• Contract Performance: Processing necessary to fulfill our service agreement with you (e.g., operating your Komondor account).
• Legitimate Interests: Improving application performance, detecting fraud, maintaining system integrity, and supporting users.
• Legal Obligation: Retaining tax/billing invoices or complying with legal requests.
• Consent: Where explicitly required (e.g., non-essential cookies or direct marketing communications).

4. How We Use Information

We use the collected information exclusively to:

• Provide, maintain, and update the Komondor application.
• Authenticate user access and manage user subscriptions.
• Offer customer support and resolve technical issues.
• Maintain network security and prevent system abuse.

5. Data Sharing & Sub-Processors

We do not sell or lease personal data to third parties. Data is shared only with trusted third-party service providers ("sub-processors") bound by strict data processing agreements:

• Hosting & Infrastructure Providers (e.g., cloud hosting, database management).
• Authentication & Payment Gateways (e.g., secure payment processing).
• Transactional Email Services (for sending system notifications and password resets).

6. Data Retention

• Account Data: Retained for as long as your account remains active.
• Participant Data: Retained while your account is active or until you delete the data directly within the application interface.
• Account Deletion: Upon account deletion, personal data is permanently deleted or anonymized within 30 days, except where retention is legally required (e.g., financial invoices).

7. User Rights

Under the GDPR, European citizens and residents have the following rights:

• Access: Request a copy of the personal data processed about you.
• Rectification: Request correction of inaccurate personal data.
• Erasure ("Right to be Forgotten"): Request deletion of your personal data.
• Restriction & Objection: Restrict or object to specific processing activities.
• Data Portability: Request an export of your data in a structured, machine-readable format.

To exercise any of these rights, contact privacy@komondor.app.

8. Security Measures

We implement appropriate technical and organizational measures to safeguard data against accidental loss, unauthorized access, or disclosure, including encrypted communication protocols (HTTPS/TLS) and restricted database access.

9. Updates to This Policy

We may update this Privacy Policy periodically. Notice of material changes will be communicated via email or through an in-app notice prior to the change becoming effective.

10. Contact & Regulatory Authority

If you have questions about this Privacy Policy or wish to lodge a complaint, you may contact:

• Data Protection Contact: privacy@komondor.app
• Supervisory Authority: You have the right to lodge a complaint with your local Data Protection Authority (e.g., the National Authority for Data Protection and Freedom of Information — NAIH in Hungary).