Privacy policy

PRIVACY POLICY AND GDPR

Before you start to use Our website and/or services as described below, owned and operated
by Sonic Dune, please read Privacy Policy carefully, since it governs your use of this website and
use of materials downloaded from website, including video games and mobile games, all
information, text, graphics, software, and services available (collectively referred to as
“services”. By using this website and/or services, you accept this Privacy Policy in full and
without reservation. If you disagree with this Privacy Policy, you must not use this website nor
services.

OUR IDENTITY AND CONTACT DETAILS ARE AS FOLLOWS: SONIC DUNE DOO NOVI SAD,
PARTIZANSKA 18 STREET, 21000 NOVI SAD, REPUBLIC OF SERBIA.

THIS POLICY BINDS YOU OR THE COMPANY YOU REPRESENT (“USER,” “YOU”, OR “YOUR”) TO
THE TERMS AND CONDITIONS SET FORTH HEREIN IN CONNECTION WITH YOUR USE OF SONIC
DUNE SOLUTIONS (“OUR”, “WE”, “COMPANY” OR “SONIC DUNE”) SOFTWARE, APPLICATIONS,
SERVICES OR OTHER OFFERINGS ON OUR SITE, SOFTWARE OR APPLICATION (COLLECTIVELY,
OUR “SERVICES”).

Sonic Dune makes this website and/or services for your use subject to this Privacy Policy set
forth in this document (“Privacy Policy”). By using this website and/or services offered on it,
downloading any software, or browsing the website, as well as by downloading any of Sonic
Dune’s mobile games from app stores, you accept the following Privacy Policy. If you do NOT
agree to all this Privacy Policy please do NOT use this website nor our services.

PLEASE READ THESE PRIVACY POLICY AND GDPR CAREFULLY, AS IT CONTAINS IMPORTANT
INFORMATION REGARDING YOUR LEGAL RIGHTS AND REMEDIES AS WELL AS OUR POLICY IN
RESPECT WITH GDPR.

GDPR STANDS FOR GENERAL DATA PROTECTION REGULATION (GDPR) (EU) 2016/679 A
REGULATION IN EUROPEAN UNION (EU) ON DATA PROTECTION AND PRIVACY FOR ALL
INDIVIDUALS WITHIN THE EUROPEAN UNION. IT ALSO ADDRESSES THE EXPORT OF PERSONAL
DATA OUTSIDE THE EU (FURTHER BELOW REFERRED TO AS GDPR).

We reserve the right to change this policy from time to time, so be sure to check it periodically.

PERSONAL DATA
All personal details that you provide to our website and/or services are absolutely safe, private,
and secure. We respect the importance of information security and confidentiality, and do not
disclose them to outside sources.

We do not share your information with any third parties, with the exception of verified and
secure e-commerce payment providers. When placing orders, our e-commerce provider
handles your personal information and keeps it absolutely safe and secure—in fact, even we
cannot access your credit card information. Your personal information (excluding credit card
data) is shared with us only for administration purposes.

INFORMATION COLLECTION AND USE
Sonic Dune collects personal data to improve the manner in which we operate and offer our
products and services, communicate with you about those products and services, and provide
effective, timely customer support when needed. We may collect the following information
from our users:
● First name, last name, email address, billing address, and phone number
● For processing transactions, we also collect either credit card information or bank
information, depending on your form of payment, though we do not store any credit
card information once your transaction is complete

We also collect Non-Personal Information, a term that refers to data that does not identify you.
Such information can be related to the Games (including but not limited to your in-game score,
how long you’ve been playing, and your in-game activities) or to the general use (including but
not limited to internet protocol addresses, browser types, browser languages, referring and exit
URLs, and number of clicks).

We reserve the right to use all content generated by our users. By such content, we mean all
content that users publish through the game and that is visible to other users (including but not
limited to wall posts, sent messages, and other kinds of interaction with other players). Please
note that Sonic Dune does not guarantee the protection of any Personal Information posted in
comments and/or on user walls. With that in mind, please double-check information before
publishing it in the public domain. We are in no way responsible for how that information is
used by other parties.

We may use your Personal Information to contact you as needed, including but not limited to
by sending you notifications. If you do not want to receive further notifications from us, you can
always disable this option.

In the event that local law requires, and/or if we believe it will help avoid liability or fraud,
and/or to comply with legal processes, we may disclose or access information about you,
including but not limited to sharing information with the government and other companies.
Sonic Dune does not have to and will not question governmental requests and processes.

GDPR COMPLIANCE
OUR PRIVACY POLICY IS IN FULL COMPLIANCE WITH GDPR REQUIREMENTS IN RESPECT WITH
COLLECTION AND PROCESSING OF PERSONAL DATA AS WELL WITH ALL APPLICABLE
REGULATIONS WITH RESPECT TO PERSONAL DATA SAFEGUARDING AND PROCESSING. ALL
PERSONAL DETAILS THAT YOU PROVIDE TO US ARE ABSOLUTELY SAFE, PRIVATE, AND SECURE.
WE RESPECT THE IMPORTANCE OF INFORMATION SECURITY AND CONFIDENTIALITY, AND DO
NOT DISCLOSE THEM TO OUTSIDE SOURCES.

This Privacy Policy and GDPR represents ‘binding corporate rules’ as stipulated under GDPR.
This Agreement regulates personal data protection policies which are adhered to in any and all
cases of processing of Personal data.

PURPOSE OF PERSONAL DATA COLLECTION AND USE
SONIC DUNE COLLECTS AND PROCESS PERSONAL DATA TO IMPROVE THE MANNER IN WHICH
WE OPERATE AND OFFER OUR SERVICES, COMMUNICATE WITH YOU ABOUT OUR PRODUCTS
AND SERVICES, AND PROVIDE EFFECTIVE AND TIMELY CUSTOMER SUPPORT WHEN NEEDED
(PURPOSE).

Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the
data subject e.g. our Users. Sonic Dune guarantees that Personal data shall be collected for
specified, explicit and legitimate purposes (as stated above) and not further processed in a
manner that is incompatible with those purposes.

We may collect and process the following Personal data from our Users:

● First name, last name, email address, billing address, and phone number and any
other personal data as may be required. Personal data shall mean any information
relating to an identified or identifiable natural person (‘data subject’); an identifiable
natural person is one who can be identified, directly or indirectly, in particular by
reference to an identifier such as a name, an identification number, location data, an
online identifier, etc.
● Processing of personal data shall mean: any operation or set of operations which
is performed on personal data or on sets of personal data, whether or not by automated
means, such as collection, recording, organization, structuring, storage, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction, erasure or
destruction
● For processing transactions, we also collect either credit card information or
bank information, depending on your form of payment, though we do not store any
credit card information once your transaction is complete

Taking into account the nature of Personal data, scope, context and purposes of processing
Personal data as well as the risks of varying likelihood and severity for the rights and freedoms
of our Users, Sonic Dune shall implement appropriate technical and organizational measures to
ensure and to be able to demonstrate that processing of Personal data is performed in
accordance with standards as set under GDPR. Those measures shall be reviewed and updated
where necessary. Sonic Dune shall, both at the time of the determination of the means for
processing of Personal data and at the time of the processing itself, implement appropriate
technical and organizational measures, such as pseudonymisation, which are designed to
implement data-protection principles, such as data minimization, in an effective manner and to
integrate the necessary safeguards into the processing in order to meet the requirements of
GDPR and protect the rights of our Users.

Sonic Dune will at its own discretion implement appropriate technical and organizational
measures to ensure a level of security appropriate to the risk, including among others following
technical measures:
(a) the pseudonymisation and encryption of personal data;

(b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of
processing systems and services;

(c) the ability to restore the availability and access to personal data in a timely manner in the
event of a physical or technical incident;

(d) a process for regularly testing, assessing and evaluating the effectiveness of technical and
organisational measures for ensuring the security of the processing.

We also collect Non-Personal Information, a term that refers to data that does not identify you.
Such information can be related to the Services or to the general use (including but not limited
to internet protocol addresses, browser types, browser languages, referring and exit URLs, and
number of clicks).

We reserve the right to use all content generated by our users. By such content, we mean all
content that users publish through the Services whether or not visible to other users. Please
note that Sonic Dune does not guarantee the protection of any Personal Information posted
publicly by You. With that in mind, please double-check information before publishing it in the
public domain. We are in no way responsible for how that information is used by other parties.
We may use your Personal Information to contact you as needed, including but not limited to
by sending you notifications. If you do not want to receive further notifications from us, you can
always disable this option.

In the event that local law requires, and/or if we believe it will help avoid liability or fraud,
and/or to comply with legal processes, we may disclose or access information about you,
including but not limited to sharing information with the government and other companies.
Sonic Dune does not have to and will not question governmental requests and processes.

SPECIAL NOTE ABOUT CHILDREN

The processing of the personal data of a child shall be lawful where the child is at least 16 years
old. Where the child is below the age of 16 years, such processing shall be lawful only if and to
the extent that consent is given or authorized by the holder of parental responsibility over the
child.

We do not collect information about children under the age of 16. In the event any personal
data were collected, we will delete it as soon as possible if you contact us at:
info@sonicdune.com.

We strongly recommend that minors seek consent from a parent or legal guardian before
accessing and/or using our Service and providing any private data.

LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
Sonic Dune shall collect and process Personal data only in a lawful way. Sonic Dune will collect
and process your Personal Data based on one of the following legal basis:

a) the User or You have given Us consent to the processing of Yours personal data for one or
more specific purposes. Your express consent shall be deemed as granted by accepting
electronic consent form or by clicking “accept”, “agree” of similar button;
(b) processing is necessary for the performance of a contract to which You and Sonic Dune are
contractual Parties or in order to take steps at the request of the User prior to entering into a
contract;
(c) processing is necessary for compliance with a legal obligation to which the Sonic Dune is
subject;
(d) processing is necessary in order to protect Your vital interests or interests of another natural
person;
(e) processing is necessary for the performance of a task carried out in the public interest or in
the exercise of official authority vested in the Sonic Dune, if applicable;
(f) processing is necessary for the purposes of the legitimate interests pursued by the Sonic
Dune or by a third party, except where such interests are overridden by the interests or
fundamental rights and freedoms of the data subject which require protection of personal data,
in particular where the data subject is a child.

YOU SHALL HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AT ANY TIME. THE WITHDRAWAL
OF CONSENT SHALL NOT AFFECT THE LAWFULNESS OF PROCESSING BASED ON CONSENT
BEFORE ITS WITHDRAWAL.

RECIPIENTS OF PERSONAL DATA
Sonic Dune may disclose your Personal Data internally within our business to the relevant
teams such as, without limitation, the customer services team, the legal team, the finance
team, the sales team, and where you have chosen to receive marketing messages, the
marketing teams. We may also disclose your information to the our affiliates, only to the extent
that this will be necessary to perform the Purpose as described herein.

Your information may be shared among Sonic Dune affiliates for the purposes described in this
Privacy Policy. The term ‘affiliates’ refers to companies related to Sonic Dune by common
ownership or control. We also may share your Personal Data with trusted business partners,
including without limitation, wireless carriers, retailers, and distributors. These entities may use
your Personal Data to provide you with services you request and to make predictions about
your interests, and may provide you with promotional materials, advertisements, and other
materials with your separate consent.

In addition to the disclosures described in this Privacy Policy, we may share information about
you with third parties when you separately consent to or request such sharing.

TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANIZATIONS
Sonic Dune may transfer Your Personal Data to recipients in third countries or international
organizations may take place where the EU Commission has decided that the third country, a
territory or one or more specified sectors within that third country, or the international
organization in question ensures an adequate level of protection. Such a transfer shall not
require any specific authorization.

In the absence of a decision of EU Commission from the previous paragraph, Sonic Dune may
transfer Your Personal Data to a third country or an international organization only if the
recipient of Your Personal Data has provided appropriate safeguards, and on condition that
enforceable data subject rights and effective legal remedies for data subjects are available.

Appropriate safeguards in respect with protection of Your Personal Data include:

  • Legally binding and enforceable instrument between public authorities or bodies.
  • Binding corporate rules.
  • Standard data protection contractual clauses adopted by the EU Commission.
  • Standard data protection contractual clauses adopted by a supervisory authority and
    approved by the EU Commission.
  • An approved code of conduct in regard with protection of Personal Data with binding
    and enforceable commitments of the recipient in the third country to apply the
    appropriate safeguards.
  • An approved certification of the recipient of the Personal Data issued by competent
    authority.

TRANSPARENCY AND MODALITIES

The Sonic Dune shall provide information and provide services on the request of the User
related to the Right to access Personal data of the User, Right to rectification, Right to
restriction of processing, Notification on regarding rectification or erasure of personal data or
restriction of processing, Right to data portability, Right to object and Right of Users not to be
subject to a decision based solely on automated processing.

Users requests related to previous paragraph shall be services without undue delay and in any
event within one month of receipt of the request. That period may be extended by two further
months where necessary, taking into account the complexity and number of the requests. The
Sonic Dune shall inform the data subject of any such extension within one month of receipt of
the request, together with the reasons for the delay. Information shall be provided by
electronic means only.

HOWEVER, SONIC DUNE SHALL REJECT USER REQUEST WHERE THE SONIC DUNE HAS
REASONABLE DOUBTS CONCERNING THE IDENTITY OF THE USER MAKING THE REQUEST
REFERRED TO IN THIS PARAGRAPH. IN SUCH CASES SONIC DUNE MAY REQUEST THE
PROVISION OF ADDITIONAL INFORMATION NECESSARY TO CONFIRM THE IDENTITY OF THE
USER.

RIGHT OF ACCESS BY THE USER
The User shall have the right to obtain from the Sonic Dune confirmation as to whether or not
personal data concerning him or her are being processed, and, where that is the case, access to
the personal data and the following information:

(a) the purposes of the processing;

(b) the categories of personal data concerned;

(c) the recipients or categories of recipient to whom the personal data have been or will be
disclosed, in particular recipients in third countries or international organizations;

(d) where possible, the envisaged period for which the personal data will be stored, or, if not
possible, the criteria used to determine that period;

(e) the existence of the right to request from the Sonic Dune rectification or erasure of personal
data or restriction of processing of personal data concerning the User or to object to such
processing;

(f) the right to lodge a complaint with a supervisory authority;

(g) where the personal data are not collected from the User, any available information as to
their source;

(h) the existence of automated decision-making, including profiling, information about the logic
involved, as well as the significance and the envisaged consequences of such processing for the
User.

RIGHT TO RECTIFICATION
The User shall have the right to obtain from the Sonic Dune without undue delay the
rectification of inaccurate personal data concerning him or her. Taking into account the
purposes of the processing, the User shall have the right to have incomplete personal data
completed, including by means of providing a supplementary statement.

RIGHT TO ERASURE (‘RIGHT TO BE FORGOTTEN’)
The User shall have the right to obtain from the Sonic Dune the erasure of personal data
concerning him or her without undue delay and the Sonic Dune shall have the obligation to
erase personal data without undue delay where one of the following conditions are fulfilled:
(a) the personal data are no longer necessary in relation to the purposes for which they were
collected or otherwise processed;
(b) the User withdraws consent on which the processing is based and where there is no other
legal ground for the processing;
(c) the User objects to the processing and there are no overriding legitimate grounds for the
processing;
(d) the personal data have been unlawfully processed;
(e) the personal data have to be erased for compliance with a legal obligation in Union or
Member State law to which the Sonic Dune is subject;
(f) the personal data have been collected in relation to the offer of information society services
referred to in Article 8(1) of GDPR.

RIGHT TO RESTRICTION OF PROCESSING

The User shall have the right to obtain from the Sonic Dune restriction of processing where one
of the following conditions are fulfilled:
(a) the accuracy of the personal data is contested by the User, for a period enabling the Sonic
Dune to verify the accuracy of the personal data;
(b) the processing is unlawful and the User opposes the erasure of the personal data and
requests the restriction of their use instead;
(c) the Sonic Dune no longer needs the personal data for the purposes of the processing, but
they are required by the User for the establishment, exercise or defence of legal claims;
(d) the User has objected to processing on grounds relating to his or her particular situation,
pending the verification whether the legitimate grounds of the controller override those of the
data subject.

THE SONIC DUNE SHALL COMMUNICATE ANY RECTIFICATION OR ERASURE OF PERSONAL
DATA OR RESTRICTION OF PROCESSING CARRIED OUT TO EACH RECIPIENT TO WHOM THE
PERSONAL DATA HAVE BEEN DISCLOSED, UNLESS THIS PROVES IMPOSSIBLE OR INVOLVES
DISPROPORTIONATE EFFORT. THE SONIC DUNE SHALL INFORM THE USER ABOUT THOSE
RECIPIENTS IF THE DATA SUBJECT REQUESTS IT.

RIGHT TO DATA PORTABILITY
The User shall have the right to receive the personal data concerning him or her, which he or
she has provided to Sonic Dune, in a structured, commonly used and machine-readable format
and have the right to transmit those data to another persons without hindrance from the Sonic
Dune to which the personal data have been provided, where:

(a) the processing is based on consent,
(b) the processing is carried out by automated means.

RIGHT TO OBJECT
The User shall have the right to object, on grounds relating to his or her particular situation, at
any time to processing of personal data concerning You, including profiling. The Sonic Dune
shall no longer process the personal data unless the Sonic Dune demonstrates compelling

legitimate grounds for the processing which override the interests, rights and freedoms of the
User or for the establishment, exercise or defense of legal claims.

RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
You or User shall have the right to lodge a complaint with a supervisory authority, in Your
habitual residence, place of work or place of the alleged infringement if You consider that Our
processing of your personal data infringes your privacy or rights granted under this Policy.

PERIOD FOR WHICH PERSONAL DATA WILL BE STORED
Sonic Dune will not keep Your Personal Data for longer than is necessary for the Purpose it was
collected. This means that data will be destroyed or erased from Our systems when it is no
longer required.

We take appropriate steps to ensure that we process and retain information about You based
on the following logic:

1. at least the duration for which the information is used to provide you with a service;
2. as required under law, a contract, or with regard to our statutory obligations; or
3. only for as long as is necessary for the purpose for which it was collected, is processed, or
longer if required under any contract, by applicable law, or for statistical purposes, subject to
appropriate safeguards.

SECURITY
We have taken appropriate steps and followed industry standards to secure all personal data
stored by our systems. All transactions are processed in keeping with the highest security level
protocols, ensuring that no one can access or use personal information in an unauthorized
manner.

However, while we take responsible measures to protect your Personal data, the internet is not
a 100% secure environment. We cannot guarantee the absolute security of all information
transmitted or electronically stored. We disclaim any liability for any unauthorized access to,

disclosure or damage to, theft of, or loss of any Personal data. By using our Services, you
acknowledge that you understand and agree to assume these risks.
Please note that you can terminate your account at any time and request that we completely
delete all of your data we have stored. Just contact us at info@sonicdune.com.

PERSONAL DATA FOR STATUTORY OR CONTRACTUAL REQUIREMENTS
Sonic Dune may require Your Personal Data for statutory or contractual requirement, or a
requirement necessary to enter into a contract. In such cases you may be obliged to provide
requested Personal Data, otherwise Sonic Dune shall be entitled to decline, at its sole discretion
to enter any at all contracts concerning You and Sonic Dune.

You shall fully indemnify, hold harmless and defend (collectively “indemnify” and
“indemnification”) Sonic Dune and its directors, officers, employees, agents, stockholders and
Affiliates (collectively, “Indemnified Parties”) from and against all claims, demands, actions,
suits, damages, liabilities, losses, settlements, judgments, costs and expenses (including but not
limited to reasonable attorney’s fees and costs), whether or not involving a third party claim,
which arise out of or relate to (1) Your refusal to provide correct Personal Data for contractual
or statutory purposes, (2) any breach or violation of any covenant or other obligation or duty
under any contract or statute caused by Your refusal to provide required Personal Data.

AUTOMATED DECISION-MAKING
Sonic Dune may use automated decision-making including profiling based on your Personal
Data. ‘Profiling’ means any form of automated processing of personal data consisting of the use
of personal data to evaluate certain personal aspects relating to You, in particular to analyze or
predict aspects concerning Yours personal preferences, interests, reliability, behavior in respect
with Our Services.

SONIC DUNE WILL NEVER USE FULLY AUTOMATED INDIVIDUAL DECISION-MAKING, INCLUDING
PROFILING THAT HAS A LEGAL OR SIMILARLY SIGNIFICANT EFFECT. DECISION MAKING WITH
LEGAL OR SIMILARLY SIGNIFICANT EFFECT SHALL MEAN ANY POSSIBLE IMPINGEMENTS ON
YOUR FREEDOM TO ASSOCIATE WITH OTHERS, VOTE IN AN ELECTION, OR TAKE LEGAL ACTION
THAT HAVE THE POTENTIAL TO SIGNIFICANTLY INFLUENCE YOUR CIRCUMSTANCES, BEHAVIOR,
OR CHOICES.

However, Sonic Dune will use automated decision-making including profiling when is necessary
for the performance of or entering into a contract with You or is authorized by State law to
which You are subject or Is based on Your explicit consent.

E-MAIL NEWSLETTER
Our newsletter is run on an opt-out basis, and we never send unsolicited emails. The only
information gathered when users voluntarily sign up for our newsletter is their email address.
This information is used solely by Sonic Dune and is not sold to or used by any third party. Sonic
Dune uses this information exclusively to send our regular newsletter about product updates,
new releases, and special offers. If you do not want to receive newsletters or other emails from
us, you can unsubscribe from them at any time using the clear instructions found in every email
we send.

EMAIL ENQUIRY
The information you provide by contacting us via email (name and email address) will only be
used for the purpose of responding to your specific enquiry. The provided information will not
be used for any other purposes.

SUBMISSION FORM
The information you provide via submission form will only be used for the processing of your
application and the accompanying communication. We may use the provided information to
contact you at a later date in regard to new job openings, internships, student practices, etc.
The provided information will not be used for any other purposes.
Unless otherwise stated in the privacy policy, your personal information will not be shared by
any third-party entities for their commercial, marketing or other purposes.

EXTERNAL LINKS

Our website and/or software may have links to other sites. We are not responsible for their
content, activities, or the way they use the information they collect and/or you may provide to
them. Please review their privacy policies.

THIRD-PARTY DATA COLLECTION AND USE OF END-USER INFORMATION
When you use or connect to a Sonic Dune’s website or download Sonic Dune’s software via a
third party platform — including Facebook — you allow us to access and/or collect certain
information from your third-party platform profile/account. You additionally allow us to access
information contained in cookies placed on your device by the third-party platform as
permitted by the terms of your agreement and privacy settings with that platform. We may
share this information with the third-party platform for their use as permitted by the terms of
your agreement with and privacy settings on that platform.

You may access applications and other services linked with Our services but provided by a third
party, which may, for example, require transmission of Personal Data to third party. Sonic Dune
is not responsible for the collection or use of Personal Data in applications or services provided
by a third party, and recommends that you carefully review applicable terms for (and any
integrity policy related to) such applications or services before you use them. If you have
questions concerning a certain third party’s use of your Personal Data, please contact the third
party directly.

Our games may contain third-party tracking tools from our service providers, for example,
Google Analytics, FireBase, FileC, AdColony, etc. For more information about third parties
service providers please review theirs privacy policy and opt-out opportunities.

CONTACT US ABOUT PRIVACY
If for any reason you are concerned with the way that we may be using your personal
information, you have questions about the privacy aspects of our products or services, or you
wish to file a complaint, please contact us at info@sonicdune.com.