version of 03.10.2026

Privacy and Cookie Policy

Draft — under legal review

The Polish version of this document is binding.

This policy explains how we process personal data in RingPass (ringpass.eu — for exhibitors and spectators) and RingDesk (ringdesk.eu — for dog show organisers). A short summary comes first, followed by the details. This English version is provided for information; in case of any discrepancy the Polish version prevails.

In short

1. Controller and contact

1. The controller of the data described in parts 2 and 7–8 is Kynologic spółka z ograniczoną odpowiedzialnością, ul. Półwiejska 17/26, 61-888 Poznań, Poland, entered in the Register of Entrepreneurs of the National Court Register under KRS number 0001066149 (District Court Poznań – Nowe Miasto i Wilda in Poznań, 8th Commercial Division), tax ID (NIP) 7831890477, REGON 526785413 (“we”). RingPass and RingDesk are services of this company.
2. We have not appointed a data protection officer. For personal data matters write to privacy@ringpass.eu or privacy@ringdesk.eu or by post to the company address.
3. Depending on the situation, a different entity controls your data:

2. Data we process as controller

2.1. Browsing the websites

1. You can browse the show calendar, show pages, live results and the catalogue without an account. The server records in its logs the IP address, date and time, requested page, response code and browser information — to ensure security, detect abuse and fix errors. Legal basis: our legitimate interest (Article 6(1)(f) GDPR). Logs are kept for 180 days (for security purposes and to investigate incidents) and are then deleted.
2. To protect forms against abuse, we briefly (up to one hour) count attempts from a given IP address and e-mail address in server memory. To protect accounts against password guessing, we count failed login attempts in the database — separately for the IP address and for the e-mail address (we store only a cryptographic hash of the address, not the address itself). After several failed attempts login is temporarily blocked, and each further block lasts longer. The account counter is cleared after a successful login, and all counters at the latest 24 hours after the last failed attempt.
3. Aggregate visit statistics (if we keep them) are produced only from server logs, with anonymised IP addresses and without cookies.
4. We use no analytics or advertising tools (e.g. Google Analytics, advertising pixels), do not profile visitors and do not sell data. Our pages do not load scripts, fonts or images from third-party servers — fonts are served from our own server.

2.2. RingPass account

This part will apply once exhibitor accounts are launched.

1. Providing data is voluntary, but an account cannot be created without a name and e-mail address, and a dog cannot be entered without its data.
2. The microchip number is confidential. It is visible to you and to the office of the show you enter the dog in (it also appears on the judging sheet, following the Polish Kennel Club template). We never show it on public pages, in the catalogue or in results.
3. Document scans are stored in a directory not accessible from the internet. They are visible to you and to the office of the show you have entered the dog in — for verifying the entry.
4. The dog’s data include data of other people — the breeder and co-owner. We process them because they are needed for the entry and show catalogue under show regulations (our and your legitimate interest, Article 6(1)(f) GDPR). We do not contact these people. Please let them know.
5. Reading data from a photo of the pedigree — only if you choose it. When you add your first dog we ask whether an artificial intelligence model should read the data automatically or you prefer to type it in yourself. If you choose reading, it is done by a model running on a server of Kynologic Sp. z o.o. in the EEA — the photo does not leave our infrastructure and is not sent to external AI providers. The reading only suggests form fields; you approve the data, and the document is verified by a person in the show office (no solely automated decisions). The legal basis is your consent (Art. 6(1)(a) GDPR); you can change your choice at any time in your account settings (“Reading the pedigree from a photo”) — the change applies to subsequent photos. We record when and which option you chose (part 2.6).
6. You can log in with a password or with a one-time link from an e-mail (valid for 15 minutes). After login your browser stores a session cookie (part 7).
7. Deleting a dog or a document. You can delete a dog and any document yourself in RingPass. If the dog or document was not passed on in any entry, we delete it immediately together with the file. If it was passed on in a show entry, it disappears from your account, and its copy remains in the entry archive of the show organiser (part 3(3) and (5)).
8. Deleting the account. You can delete your account in the account settings (“Delete account”) after confirming with your password or with a link sent by e-mail. You can change your mind within 14 days — with the button in your account or the link in the confirmation e-mail. After 14 days we anonymise the account: we erase your name, e-mail address, phone, password, dogs and documents not passed on in entries (with their files), followed shows and notification settings. The history of accepted Terms and entries in the security log (with the e-mail address the account acted from) are kept to demonstrate compliance and to defend against claims (Article 6(1)(c) and (f) GDPR; part 2.6). Data of entries passed on to organisers remain in their archive (part 3).
9. Downloading your data (“My data”). In the account settings you can download a ZIP file (JSON and CSV plus files) with all account data: profile, dogs, documents and photos, entries and payments with their status, dog results, notification settings and history of accepted Terms. Before downloading we ask you to confirm again (password or e-mail link); data can be downloaded up to 3 times a day.
10. Photos without metadata. Dog photos, pedigree photos and document scans are re-saved without metadata (EXIF, including GPS location, phone model and date taken), under a random file name.

2.3. E-mails from the service

1. We send: login links, password reset links, entry payment confirmations, reminders (judging of your dog the next day, entry deadlines for followed shows, unpaid entries) and important information about your account and changes to the Terms.
2. Legal basis: the account contract (Article 6(1)(b) GDPR). You can switch reminders off at any time in your account settings (“Notifications”). We send no newsletters or advertising.
3. E-mails about a specific entry (e.g. payment confirmation) are also sent on behalf of the show organiser.
4. E-mails are sent from our own mail server, without external e-mail delivery providers.

2.4. “Book a demo” form (RingDesk) and sales contact

Providing data is voluntary, but we cannot reply without a name, branch name and e-mail address. Requests go to our sales mailbox (sales@ringdesk.eu).

2.5. Organiser representatives, agreements and billing

1. We process data of people who represent show organisers or contact us on their behalf (name, position, e-mail, phone) — to conclude and perform the RingDesk agreement with the organiser (our legitimate interest, Article 6(1)(f) GDPR; where you are the party to the agreement — Article 6(1)(b) GDPR).
2. Billing documents (invoices, proof of licence payments) are kept for 5 years from the end of the tax year in which the tax obligation arose — to meet tax and accounting obligations (Article 6(1)(c) GDPR). Other data — for the duration of the agreement and until claims become time-barred.
3. Show office staff accounts in the RingDesk panel are created by the organiser; these data are described in part 6.

2.6. Security, event logs and correspondence

1. We keep a log of administrative actions in the system (who made which change, when, and from which IP address) and a log of notifications from payment operators — for security, accountability and troubleshooting (Article 6(1)(f) GDPR). The action log includes logins of show office staff and the operator, failed logins and blocks, downloads of documents and judging sheet photos, data exports from the panel, “My data” downloads and account deletion requests. Entries are not deleted automatically: action log entries older than 3 years and payment operator notifications older than 12 months go to an archive that is hidden in everyday use and accessible only to the system operator [TO BE CONFIRMED: whether the log archive should have an upper retention limit — decision of the owner and legal counsel].
2. Correspondence with you (support questions, complaints, illegal content notices, data requests) is kept for as long as needed to handle the matter and then until claims become time-barred — to demonstrate how we handled it (Article 6(1)(c) and (f) GDPR) [TO BE CONFIRMED: specific retention period for correspondence].

2.7. Passing your dog’s results to BreedManager — at your request

This part will apply once exhibitor accounts are launched.

1. Show results are data controlled by the show organiser (part 3). We pass them to BreedManager on the organiser’s behalf, under its instruction in the data processing agreement, and only at your request.
2. The kennel in BreedManager and the dog’s owner are often different people — that is why you, not the kennel, decide about the link. The kennel may ask you (an invitation e-mail from BreedManager); declining changes nothing in RingPass.
3. You see the link on the dog’s page (“Linked to BreedManager (kennel …) since …”). If you link the dog with another dog or another kennel, the previous link ends (as if unlinked).
4. An organiser may disable passing results to BreedManager for its shows. We do not pass on results from such an organiser’s shows — also for dogs already linked; the link page tells you about this.

3. Show entries — the organiser is the controller

1. When you enter a dog in a show, the controller of the entry data is the organiser of that show (e.g. a branch or club of the Polish Kennel Club). The organiser’s name and contact details are shown on the show page in RingPass and in the show rules. We process these data on behalf of the organiser, as a processor, under a data processing agreement (Article 28 GDPR).
2. Entry data include in particular: your name, e-mail and phone; the dog’s data copied from your account when the entry is submitted (including microchip and pedigree number); class and extras (e.g. car registration number for a parking pass, the name of a Junior Handling participant); class change requests and withdrawals; payments and their status; catalogue number; grades, placements, titles and the judge’s critique; judging sheets and their photos; notes of ring stewards and judges.
3. By submitting an entry you also pass on to the organiser the dog’s documents saved in your account (and documents added later, until the show is moved to the archive) — the show office uses them to verify the entry and class. The verification status of a document is saved with the dog in your account. A document passed on in an entry remains in the entry archive even if you later delete it (or the dog or your whole account) from RingPass.
4. The purposes and legal bases for processing entry data are determined by the organiser — usually performance of the show participation contract (Article 6(1)(b) GDPR), legal obligations such as tax obligations (Article 6(1)(c) GDPR), and the organiser’s legitimate interest in keeping the catalogue and results archive under show regulations (Article 6(1)(f) GDPR). Details are in the information notice provided by the organiser.
5. How long entry data are kept is decided by the organiser. Unless instructed otherwise, the default rules apply: after the show entry data are not deleted but archived. 30 days after the last day of the show it is moved to the archive — the organiser’s office has read-only access (viewing, printing and exports), without the ability to make changes. 5 years after the last day of the show the archive is anonymised: the catalogue and results (dog name, breed, sex, class, breeder, grades, placements, titles and judges’ critiques) remain, while exhibitor data (name, e-mail, phone, co-owner), microchip, pedigree and registration numbers, documents passed on in entries, ring notes, photos of judging sheets, details of extras (e.g. car registration number) and office notes are erased.
6. The organiser may import its bank statements into RingDesk to match transfers with entries. The statement file is not stored, and unmatched transactions are deleted when the import is closed, at the latest after 30 days.
7. You exercise your rights regarding entry data with the organiser. You may also write to us — we will forward your request to the organiser without delay and help them handle it.
8. Deleting your RingPass account does not delete entry data already passed on to organisers — they remain in the organiser’s archive under point 5; the show office sees them from the copy saved in the entry.

4. Payments

1. You pay the entry fee directly to the organiser. For online payments we redirect you to the website of the payment operator with which the organiser has an agreement:
   • PayU S.A., ul. Grunwaldzka 186, 60-166 Poznań, Poland, or
   • PayPro S.A. (Przelewy24), ul. Pastelowa 8, 60-198 Poznań, Poland.
2. We pass on to the operator: your name, e-mail address, the amount, payment description, language and payment identifier. The operator is a separate controller of payment data and processes them under its own privacy policy. From the operator we receive only the payment status (e.g. paid, cancelled, refunded) and its identifier.
3. We do not receive or store payment card data or online banking credentials. We do not receive exhibitors’ money.
4. For a traditional bank transfer you pay into the organiser’s account and the show office confirms the payment (part 3(6)). Refunds are made by the organiser.

5. What is public: show pages, catalogue and results

1. Show catalogues and results are published on behalf of the organiser, who is the controller of these data and decides on their publication. The pages are accessible without login and may be indexed by search engines. A dog’s result is published only after the judge has signed the judging sheet (in the finals — the finals report). Until then only the show office and the ring devices see it; the same applies to a later correction of the result.
2. The following are publicly visible:
   • show page: name, date and venue, organiser, price list, judges assigned to breeds (name), number of entries by FCI group;
   • online catalogue: catalogue number, dog name, breed and variety, sex, class, date of birth, breeder (the catalogue search uses only these data — not the owner’s name);
   • live results and breed results: grade, placement, titles and awards, the judge’s critique (if entered by the organiser), ring and judge; the dog photo added in the account — only if photo publication has been enabled with the consent of the kennel club (disabled by default); the ring app used by judges and secretaries never shows dog photos;
   • finals and results screen: winners of the final competitions with the names of the breeder and owner (and the dog photo — on the terms above). After an account is deleted and after the show archive is anonymised, the owner’s name is no longer shown.
3. We never publish: the microchip number, pedigree number, the exhibitor’s e-mail, phone or address, dog documents, judging sheets (visible after login only to the exhibitor and the dog’s owner) or payment information.
4. You can remove the dog photo from your account at any time — it will no longer be shown in results. Objections to publication in the catalogue or results should be addressed to the organiser.

[TO BE CONFIRMED: scope of public data — whether the owner’s name in finals and the dog photo (once enabled with the kennel club’s consent) should be public; decision of the owner, organisers and legal counsel.]

6. Judges, ring stewards and show office staff

1. Data of judges (name, country, e-mail, ring and breed assignments), ring stewards (name, e-mail, ring) and show office staff (name, e-mail, role, actions in the panel) are entered by the show organiser, who is their controller. We process them on its behalf (part 3(1)).
2. Ring stewards — and, if the organiser allows it, judges — receive a personal link to the notes app by e-mail, without creating an account. The link is single-use: when first opened it is exchanged for a device token, and only its hash is stored in the database. The link and device stop working when revoked, re-sent or after the show.
3. The notes app and ring app record entries (attendance, grade, placement, remarks), the time of entry on the device and browser information — to check the accuracy of results and as material for handling protests. Notes are not published.
4. A judge’s name is public on the show page and in results (part 5). You exercise your rights with the show organiser; you may also write to us and we will forward your request to the organiser.
5. Show office staff log in to RingDesk with a password and a mandatory second factor — a code from an authenticator app on their phone (two-step verification, TOTP). We store the encrypted app secret, hashes of backup codes and, in the security log: logins (successful and failed), blocks, downloads of dog documents and judging sheet photos, and data exports from the panel. A staff account is deleted (anonymised) by the RingDesk operator at the organiser’s request — on the same terms as an exhibitor account, without the cancellation period.

7. Cookies and device storage

1. We use only strictly necessary cookies. They do not require consent, so we do not show a cookie banner. We use no analytics, advertising or third-party cookies.

2. The ring app and the notes app (used by the show office, ring secretaries, ring stewards and judges) store working ring data and a device token in the browser storage of the tablet or phone (IndexedDB and the app cache) so they can work offline. These data are not used for tracking.
3. You can block or delete cookies in your browser settings, but forms and login will then not work.

8. Recipients and place of processing

1. We share data only to the extent necessary with:
   • Xerti Tech Sp. z o.o., Poznań, Poland (ul. Półwiejska 17/26, 61-888 Poznań, KRS 0001087524, NIP 7831897829) — infrastructure maintenance: servers, backups, e-mail and network; uses an OVH data centre in France and a server room at the Poznań Science and Technology Park (colocation; backups are also kept there); acts as our processor under a data processing agreement [TO BE CONFIRMED: conclusion of the data processing agreement Kynologic ↔ Xerti Tech — draft in preparation];
   • show organisers — the entry data you provide to them (part 3);
   • the organiser’s payment operators — for online payments (part 4);
   • accountants and advisers — for billing documents with organisers [TO BE CONFIRMED: accounting office / invoicing system];
   • Kynologic Sp. z o.o. as the controller of the BreedManager service — show results of a dog you yourself link with a dog in BreedManager of a chosen kennel (part 2.7);
   • public authorities — only where required by law.
2. E-mails are sent from our own mail servers, without external delivery providers.
3. Servers and e-mail run in a cluster at two sites — an OVH data centre in France and a server room in Poznań, Poland (Poznań Science and Technology Park) — and backups are kept in Poznań; all within the European Economic Area. Traffic between these sites goes only through encrypted tunnels. We do not transfer data outside the European Economic Area.
4. Kynologic also runs other services — BreedManager (breedmanager.eu) and DogWorldBase (dogworldbase.com). They are separate services with separate databases: We pass a dog’s show results to BreedManager only at your request — when you link the dog yourself (part 2.7). We do not combine any other RingPass and RingDesk data with BreedManager or DogWorldBase.

9. How long we keep data — overview

10. Your rights

1. You have the right to:
   • access your data and obtain a copy (Article 15 GDPR) — you can download a copy of your account data yourself in “My data” (part 2.2(9));
   • rectification (Article 16 GDPR) — you can correct most account and dog data yourself in RingPass;
   • erasure (Article 17 GDPR) — you can delete a dog, a document or your whole account yourself in RingPass (part 2.2(7) and (8));
   • restriction of processing (Article 18 GDPR);
   • portability of data processed on the basis of a contract (Article 20 GDPR);
   • object to processing based on our legitimate interest (Article 21 GDPR) — we always respect objections to sales contact;
   • withdraw consent at any time (Article 7(3) GDPR) — e.g. consent to passing a dog’s results to BreedManager: “Unlink from BreedManager” on the dog’s page (part 2.7).
2. Send requests to privacy@ringpass.eu or privacy@ringdesk.eu. We reply without undue delay and within one month at the latest (in exceptional cases this may be extended by two further months — we will let you know). We may ask you to confirm your identity, e.g. by writing from the e-mail address assigned to your account. Exercising your rights is free of charge.
3. Rights regarding entry data, catalogue, results, judging sheets and ring notes are handled by the show organiser (part 3(7)).
4. You have the right to lodge a complaint with the supervisory authority — the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, Poland, uodo.gov.pl) — or with the supervisory authority of your country of residence.

11. Security

1. Connections to the service are encrypted (HTTPS). Passwords are stored only as cryptographic hashes. Login links are cryptographically signed, single-use and valid for 15 minutes, and notes app invitation tokens are stored only as hashes.
2. Document scans and photos of judging sheets are stored outside the server’s public directory and served only to authorised persons after an access check.
3. Show office staff see only the data of their own organiser’s shows; archived shows — read-only. Show office staff and the operator log in with mandatory two-step verification (a code from an authenticator app), and their logins, downloads of documents and judging sheet photos and data exports are recorded in the security log. After several failed attempts login is temporarily blocked. Administrative access to the servers is possible only through a secured network.
4. We make regular backups at a different site from the production servers; since 3 October 2026 we encrypt them before they leave the server, and the backup server does not know the key. Backups cannot be deleted from the production servers. After deletion, data may remain in backups for a limited time (up to 12 months; part 9) and are then permanently erased; we restore data from backups only after a failure or incident.

12. Profiling and automated decisions

We do not profile users and do not take decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you. Automatic pedigree reading only suggests form data; documents and entries are accepted by people in the show office.

13. Minors

Only adults can create a RingPass account. If you enter a child in the Junior Handling competition, you provide the child’s name as a parent or guardian from your own account; these data go to the show organiser as part of the entry (part 3).

14. Changes to this policy

We update this policy when our services, data processing or the law change. The version date is always shown at the top of this page. We will inform account holders of material changes by e-mail and in the service before they take effect.