1. Data Controller

The controller of your personal data is:

Comerito Patryk Lewczuk ul. Falista 22 lok. 14, 81-331 Gdynia Tax ID (NIP): 7272765097 Email: patryk.lewczuk@comerito.com

(hereinafter the “Organizer”, “we” or “us”)

2. Scope

This Privacy Policy applies to all personal data collected in connection with the HackOn hackathon, including registration, participation, communication and post-event activities. It covers all participants, mentors, judges, sponsors, volunteers and other individuals whose data is processed in connection with the event.

3. What personal data we collect

We collect and process the following categories of personal data:

Registration and identification data:

• First and last name
• Email address
• Phone number
• Description / bio
• Job title
• Company or organization name and professional title

Social and communication data:

• Discord handle
• Links to social media profiles (e.g., LinkedIn, GitHub, X/Twitter)

Event-related data:

• Incident reports submitted through the HackOn app
• Team assignments and project submissions
• Recordings of presentations and demos (with consent)

Technical data:

• IP address and browser metadata while using the HackOn app
• Session and authentication data

Visual data:

• Photographs and video recordings taken during the event (see Section 8)

4. Legal bases for processing

We process your personal data on the following legal bases under the GDPR (Regulation (EU) 2016/679):

• Art. 6(1)(a) — Consent — for marketing communication, publication of photos/video and processing of social media profile data.
• Art. 6(1)(b) — Performance of a contract — for registration, event participation and related organizational activities.
• Art. 6(1)(c) — Legal obligation — for tax documentation and legal requirements.
• Art. 6(1)(f) — Legitimate interest — for event safety, incident handling, abuse prevention and improving future events.

5. Purpose of data processing

Your personal data is processed for the following purposes:

• Registration and management of your participation in HackOn.
• Communication about event logistics, updates and important announcements.
• Facilitating team formation, mentoring and judging processes.
• Handling incident reports and ensuring a safe event environment.
• Payment processing (where applicable).
• Documenting the event through photography and video.
• Post-event communication, including surveys and information about future events (with consent).
• Fulfilling legal and tax obligations.

6. Data recipients and processors

Your data may be shared with the following processors, which act on our behalf and under our instructions:

* Where data is transferred to the United States, appropriate safeguards are applied in accordance with Chapter V of the GDPR, including Standard Contractual Clauses (SCC) or equivalent mechanisms.

We do not sell, rent or share your personal data with third parties for commercial purposes. We share data only to the extent necessary to fulfill the purposes set out in this policy.

7. Data retention period

We retain your personal data for 6 months after the end of the event (September 20, 2026), i.e., until March 20, 2027, unless:

• A longer retention period is required by law (e.g., tax/accounting records — up to 5 years).
• You request earlier deletion (see Section 9).
• The data is anonymized and used solely for statistical purposes.

After the retention period, all personal data will be permanently deleted or irreversibly anonymized.

8. Photography and video

The event will be documented with photography and video for promotional, editorial and archival purposes.

• General event shots (crowd photos, room views, stage presentations) are recorded on the basis of our legitimate interest (Art. 6(1)(f) GDPR).
• Material focused on individuals (close-ups, interviews, team presentations) requires your explicit verbal consent before recording.
• If you do not wish to appear in event materials, let the organizers know during registration. You will receive a visible marker (e.g., a lanyard tag) so photographers can respect your preference.
• Published material in which you are recognizable may be withdrawn at your request — contact us at patryk.lewczuk@comerito.com.

9. Your rights

Under the GDPR, you have the following rights regarding your personal data:

• Right of access (Art. 15) — to obtain confirmation of processing and request a copy of your data.
• Right to rectification (Art. 16) — to correct inaccurate or incomplete data.
• Right to erasure (Art. 17) — to request deletion of your data (the “right to be forgotten”).
• Right to restriction of processing (Art. 18) — to restrict processing in certain circumstances.
• Right to data portability (Art. 20) — to receive your data in a structured, commonly used, machine-readable format.
• Right to object (Art. 21) — to object to processing based on legitimate interest.
• Right to withdraw consent (Art. 7(3)) — to withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, contact us at patryk.lewczuk@comerito.com. We will respond within 30 days.

You also have the right to lodge a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw, www.uodo.gov.pl).

10. Data security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encrypted data transmission (TLS/HTTPS).
• Access control and authentication in the HackOn app.
• Restricted access to personal data, limited to those among the organizers who need it.
• Regular reviews of security practices.

We make every effort to protect your data; however, no method of electronic transmission or storage is 100% secure. In the event of a data breach, we will notify affected individuals and the supervisory authority in accordance with Art. 33 and 34 of the GDPR.

11. Cookies and analytics

The HackOn app may use essential cookies for session management and authentication. We do not use third-party tracking or advertising cookies.

If analytics tools are implemented, they will use only anonymized or aggregated data and will not collect personally identifiable data without your explicit consent.

12. Changes to this policy

We reserve the right to update this Privacy Policy. We will inform participants of any material changes via email or the HackOn app.

13. Contact

If you have any questions or concerns about this Privacy Policy or the processing of your personal data:

Comerito Patryk Lewczuk Email: patryk.lewczuk@comerito.com Phone: +48 662 216 721