PERSONAL DATA PROCESSING POLICY

Garden of Dreamers Project

Last Updated: December 22, 2025

1. General Provisions

This Policy delineates the procedures governing the processing of personal data of participants in the Garden of Dreamers project (hereinafter "Project"). The processing of personal data is conducted by:

Data Controller:

Individual Entrepreneur Dimitri Bahdanau

Individual Enterprise

Identification Number: 345679580

Contact Email: privacy@dreamseed.online

2. Purposes of Personal Data Processing

Facilitation of participation in the non-commercial social experiment known as Garden of Dreamers

Transmission of payment receipts for the symbolic participation fee of USD 1.99

Public display of participant dream information within the visualized Garden (solely with explicit consent)

Conduct of aggregated statistical analysis and generation of anonymized research reports

Dissemination of Project updates to participants (solely with explicit consent)

3. Categories of Personal Data Processed

Electronic mail address

Age classification bracket (18-25, 26-35, etc.)

Country and municipality of residence

Dream designation and selected category (from eight predefined life spheres)

4. Lawful Basis for Processing

Personal data processing is conducted pursuant to the following legal foundations:

Explicit consent of the data subject (Article 6(1)(a) GDPR)

Necessity for performance of contractual obligations to which the data subject is party (Article 6(1)(b) GDPR)

Legitimate interests pursued by the controller for academic research and statistical analysis (Article 6(1)(f) GDPR)

5. Consent Mechanism

Consent for personal data processing is obtained through the participant dashboard during registration. Participants may provide two distinct, granular consents:

Consent for publication of their designated dream title

Consent for geographic positioning of their symbolic tree within the visualization

6. Data Subject Rights

Data subjects maintain the following rights:

Right of access to information regarding processed personal data

Right to rectification of inaccurate data

Right to erasure ("right to be forgotten")

Right to restriction of processing

Right to object to processing

Right to data portability

Right to withdraw consent at any time without detriment

Right to lodge complaints with relevant supervisory authorities

To exercise these rights, submit a written request to: privacy@dreamseed.online

7. Data Retention Periods

Personal data shall be retained for a period not exceeding three (3) years from the date of last interaction with the participant. Following expiration of this period, data shall be permanently erased. Upon receipt of a valid erasure request, all personal data shall be completely removed within thirty (30) calendar days.

8. Security Measures for Personal Data Protection

The following technical and organizational measures are implemented to ensure data security:

End-to-end encryption of data both in transit and at rest

Strict access controls limiting data access to authorized personnel only

Regular security vulnerability assessments and penetration testing

Systematic anonymization of data used for analytical purposes

Comprehensive protection against unauthorized access through technical and procedural safeguards

9. Third-Party Data Disclosure

Personal data shall not be disclosed to third parties except in the following circumstances:

Payment processors (PayPal, Stripe) strictly for transaction processing

Hosting providers and technical partners processing data pursuant to data processing agreements compliant with Article 28 GDPR

Government authorities pursuant to legally binding requests in accordance with applicable law

10. Contact Information for Data Protection Inquiries

All inquiries regarding personal data processing shall be directed to:

Email: privacy@dreamseed.online

Website: https://dreamseed.online

11. Final Provisions

The Data Controller reserves the right to amend this Policy. Material changes shall be communicated to participants via electronic mail. The current version of this Policy shall be maintained at https://dreamseed.online for continuous public access.