Last Updated: 2024-09-26

1. Data Controller: We are CT Tornado sp. z o.o., with its registered office in Wrocław,
   Poland (address: ul. Wyspa Słodowa 7, 50-266 Wrocław; registration: District Court
   Wrocław-Fabryczna, KRS number: 783910; tax ID no.: 8982262377; share capital: PLN
   5 000,00; info(at)catchthetornado.com).
2. Scope of Processing: We process personal data of users of the Doctor Dok application
   (the “App”) and the access management site (each, a “User”).
3. Consent: By using our services, you consent to the processing of your personal data in
   accordance with this Privacy Policy.
4. Contact Information: Queries about personal data can be directed to us via: (i) email:
   info(at)catchthetornado.com; (ii) contact form: doctordok.com/contact; or (iii) postal address: our registered office.
5. Compliance with Privacy Laws: We adhere to the General Data Protection Regulation
   (the “GDPR”), which sets the framework for data protection and privacy within the
   European Union. Our practices also comply with the e-Privacy Directive and its local
   implementations, particularly for email marketing consents. We recognize and respect the
   privacy rights of California residents under the California Consumer Privacy Act (the
   “CCPA”). Additionally, we actively comply with relevant privacy laws applicable to various
   jurisdictions where our services are accessed or used. This multi-layered approach
   ensures that all personal data we handle is managed with the utmost care and respect for
   individual privacy rights.
6. Purposes of Processing: We process data to: (i) manage your account; (ii) provide and
   perform our Services; (iii) respond to inquiries and communications; and (iii) obtain
   feedback concerning the App.
7. Performance of Contracts: Data is processed to perform contracts with you or to take
   steps at your request before entering into a contract.
8. Legitimate Interests: Data processing is also conducted based on our legitimate
   interests, including obtaining feedback on the App.
9. Categories of Data: We process the following categories of personal data: (i) name; (ii)
   email address; or (iii) affiliated company and position.
10. Recipients of Data: Your data may be shared with: (i) contractors; (ii) accounting and
    legal firms; and (iii) various service providers, including OpenAI, in its capacity as the
    provider of ChatGPT, which processes data on our behalf under a data processing
    agreement between us and OpenAI.
11. International Transfers: Your data may be transferred to third countries with appropriate
    safeguards under Article 46 of the GDPR. You can request a copy of the transferred data
12. Data Retention: We retain personal data for as long as necessary to fulfill processing
    purposes, including: (i) providing and performing our services (including managing your
    account); (ii) responding to inquiries and communications; (iii) obtaining feedback
    concerning the App; and (iv) compliance with legal retention requirements. Your data will
    be permanently deleted once these periods expire.
13. Your Rights Under GDPR: (a) Access: You have the right to confirm if your data is being
    processed and to obtain a copy. (b) Rectification: You can request correction of
    inaccurate data. (c) Erasure: You can request deletion of your data under certain
    conditions, such as when it is no longer necessary or has been unlawfully processed. (d)
    Restriction: You can request restricted processing in specific cases, such as contesting data accuracy or needing data for legal claims. (e) Portability: You can receive your data
    in a structured format and transmit it to another controller. (f) Objection: You can object to
    processing based on legitimate interests or for direct marketing purposes.
14. California Consumer Privacy Act (CCPA) Rights: (a) Right to Know and Access: You
    can request information about the collection, use, and sharing of your personal data over
    the past 12 months, including specific pieces of personal data collected. (b) Right to
    Deletion: You can request deletion of your personal data, subject to legal exceptions. (c)
    Right to Non-Discrimination: You will not face discriminatory treatment for exercising your
    privacy rights under the CCPA. (d) Right to Opt-Out of Sale: While we do not sell
    personal data as defined by the CCPA, you have the right to opt-out if we were to engage
    in such sales. (e) Contact for More Information: For inquiries or to exercise any of these
    CCPA rights, please contact us at email address: info(at)catchthetornado.com.
15. Withdrawal of Consent: Where the processing of your personal data is based on your
    consent, you have the right to withdraw that consent at any time. Withdrawal of consent
    does not affect the lawfulness of processing based on consent before its withdrawal.
    Please note that withdrawing consent may result in the termination of your account or
    limit your ability to use certain features of our services.
16. Mandatory Data Provision: Providing personal data is necessary for account
    management and related services.
17. Complaints: You have the right to lodge a complaint with a supervisory authority if you
    believe our processing of your data violates GDPR provisions or CCPA rights.

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