Privacy Policy

Effective date: August 27, 2026

U3DA ("we," "us," "our") is operated by Marcin Stempniewicz, a sole proprietorship (jednoosobowa działalność gospodarcza) registered under Polish law at ul. Chociszewskiego 21/4, 60-255 Poznań, Poland, NIP 6342604170, EU VAT PL6342604170 (the "Controller"). This Privacy Policy explains how we handle your personal data when you visit our website, enroll in the course, or use the U3DA member portal.

Platform provider. The U3DA website and member portal run on the CommunitySync platform, technically provided and hosted by Trusun Media Inc., 240 E Palmetto Ave #100, Longwood, FL 32750, United States. Trusun Media Inc. processes personal data on our behalf as a data processor under Article 28 GDPR — it operates the infrastructure but is not a party to your purchase and has no independent right to use your data.

1. Information We Collect

• Account details you provide when you enroll: name, email address, and any optional profile fields you fill in.
• Order and payment data: which plan you purchased and the payment status Stripe confirms to us. We do not receive, see, or store your card number (Section 4).
• Course activity: lessons and materials you access, and any questionnaire or quiz responses you submit.
• Technical data: IP address, browser and device information, and cookies (Section 7).

2. Legal Bases for Processing (GDPR Art. 6)

• Performance of a contract (Art. 6(1)(b)) — creating your account, granting course access, and fulfilling your order.
• Legal obligation (Art. 6(1)(c)) — issuing invoices and keeping the accounting and VAT records Polish law requires.
• Legitimate interest (Art. 6(1)(f)) — securing the platform, preventing fraud and abuse, and improving the course.
• Consent (Art. 6(1)(a)) — optional marketing communications, where applicable. You can withdraw consent at any time without affecting your existing course access.

3. Who We Share Data With

• Trusun Media Inc. (platform provider, data processor) — hosting, security, and technical operation of the member portal.
• Stripe (payment processor) — processes your payment; we never receive your full card number (Section 4).
• Cloud infrastructure providers we rely on to run the portal — including our database and hosting provider (Supabase) and our content-delivery and security provider (Cloudflare), both of which may process data outside the EU/EEA (Section 5).
• Error monitoring: technical diagnostic data (such as IP address, device/browser information, and the actions immediately before a failure) may be processed by our error-monitoring provider to help us detect and fix bugs.
• Lesson hosting: where course videos or files are hosted on third-party platforms (such as YouTube, Vimeo, or Google Drive), your access to that content is also subject to that platform's own privacy terms.
• AI-assisted features: if you use a portal feature that generates or analyzes text, your input may be processed transiently by third-party AI model providers (Google, Anthropic) via an AI routing service (OpenRouter, Inc.) to fulfill that specific request. It is not used to train their models and is not retained beyond what's needed to complete the request.
• Authorities, where disclosure is required by law — for example, invoice records requested by the Polish tax administration.

We do not sell your personal data.

4. Payment Processing

Payments are handled by Stripe (Stripe Payments Europe, Ltd.), an independent, PCI-DSS compliant payment processor. We never receive or store your full card number. Your purchase is a direct transaction between you and the Controller (Marcin Stempniewicz) — the platform provider has no role in, and no visibility into, the payment itself beyond confirmation that it succeeded.

5. International Data Transfers

Some of the processors listed in Section 3 (including our hosting and infrastructure providers) are based in, or process data in, the United States. Where personal data is transferred outside the EU/EEA, we rely on the safeguards those providers offer for such transfers — including the EU Standard Contractual Clauses — to ensure your data continues to receive an equivalent level of protection.

6. How Long We Keep It

We keep your account and course-activity data for as long as your account is active. Invoices and VAT records are kept for the period Polish tax law requires (currently 5 years from the end of the relevant tax year). If you delete your account, your data may briefly persist in encrypted backups until those backups cycle out.

7. Cookies

The portal uses cookies necessary for login and basic functionality, and may use analytics cookies to understand how the site is used. You can control cookies through your browser settings; disabling them may limit some functionality.

8. Your Rights

Under the GDPR, you have the right to:

• access the personal data we hold about you;
• request correction of inaccurate data;
• request deletion of your data ("right to be forgotten");
• request restriction of, or object to, certain processing;
• receive a portable copy of the data you provided us;
• withdraw consent at any time, where processing is based on consent.

To exercise any of these rights, contact us at underwater3dacademy@gmail.com. We will respond within 30 days.

You also have the right to lodge a complaint with Poland's data protection authority:

Prezes Urzędu Ochrony Danych Osobowych (UODO) ul. Stawki 2, 00-193 Warszawa, Poland

or with the supervisory authority in your own EU country of residence.

9. Children's Privacy

U3DA is not directed at, and we do not knowingly collect data from, children under 16. If we learn that we have collected such data, we will delete it promptly.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted here with an updated effective date, and we will make reasonable efforts to notify you by email. Continued use of the portal after the effective date constitutes acceptance of the revised policy.

11. Contact Us

Marcin Stempniewicz (sole proprietorship) ul. Chociszewskiego 21/4, 60-255 Poznań, Poland NIP: 6342604170 · EU VAT: PL6342604170 Email: underwater3dacademy@gmail.com

For questions about the Portal's technical operation, you may also contact the platform provider: Trusun Media Inc. — 240 E Palmetto Ave #100, Longwood, FL 32750, United States · +1 407-388-1001 · privacy@mycommunitysync.com