Privacy Policy
Last updated 2026-10-11
1. Who is responsible
The controller for the personal data processed on pwnd.rs is pwnd.rs, Street 1, 1234 AB City. Reach us about privacy at privacy@pwnd.rs. This policy applies to the website and the training platform; it does not cover the websites of our payment provider, which have their own policies.
We run a training platform, not an advertising business. We do not sell data, we do not profile you, and there is no analytics or tracking script on the site.
2. What we process, why, and on what legal basis
| Data | Purpose | Legal basis (GDPR art. 6) |
|---|---|---|
| Account: name, email, password (stored only as a salted hash), generated avatar seed, billing country | Run your account, sign you in, send transactional email, charge the right VAT | Contract (1b) |
| Training: lab progress, scores, captured flags, course completions, certificates | Provide the labs, dashboards and leaderboards; issue certificates | Contract (1b) |
| Lab submissions: the code and answers you submit, with timestamps and results | Run the sandboxed checks; keep an audit trail to investigate cheating, abuse and disputes about certificates | Contract (1b); legitimate interest in security and integrity (1f) |
| Course reviews: rating and comment | Show instructors how a course lands | Contract (1b) |
| Sessions: a random session token, user agent, creation and expiry time | Keep you logged in; let you see and revoke devices; detect account takeover | Contract (1b); legitimate interest in security (1f) |
| Certificates: your name, course, issue date, certificate id | Shown on the public verification page to anyone who has the link | Contract (1b); legitimate interest of you and employers in verifiable certificates (1f) |
| Payments: amount, currency, status, invoice number, payment id, billing country, VAT number | Take payment, issue invoices, keep books | Contract (1b); legal obligation to keep tax records (1c) |
| Team membership: which organisation you belong to, who invited you, your role | Give seated members access; let the owner manage seats | Contract (1b) |
| Server logs: IP address, requested URL, user agent, time | Keep the platform secure and debug outages | Legitimate interest in security (1f) |
Card details are entered on Mollie’s pages and never touch our systems. We do not ask for anything we do not need: no phone number, no date of birth, no photo (the avatar is drawn from a random seed).
If you join a live session, the instructor and your team see your name, avatar, team and score on the session leaderboard. On a Teams plan the team owner sees the members’ names, emails and training progress.
3. Who we share data with
We use a small number of service providers (processors) that act only on our instructions under a data processing agreement:
| Provider | What for | Where |
|---|---|---|
| OVHcloud | Hosting of the platform, database, lab targets and backups | EU data centres |
| Mollie B.V. | Payment processing and subscription mandates | Netherlands (EU) |
| Moneybird B.V. | Invoicing and bookkeeping | Netherlands (EU) |
| Resend, Inc. | Sending transactional email (verification, receipts, session invites, security notices) | United States; transfer covered by the EU standard contractual clauses |
Beyond that we disclose data only when the law requires it, to enforce our Terms after abuse (which may include reporting to the authorities), or to a successor if the business is transferred, under this same policy.
4. How long we keep it
- Account and training data: until you delete your account. Deletion removes your profile, progress, captures, certificates and reviews.
- Invoices and payment records: 7 years after the financial year they belong to, as tax law requires, even if you delete your account. They are kept in a minimal form (name, address, amount, invoice number).
- Lab submissions: 12 months after submission, then deleted.
- Sessions: 7 days, or until you log out or revoke them.
- Server logs: rotated within a short period, at most 30 days.
- Email: our mail provider keeps delivery logs briefly; we keep correspondence with you for as long as the matter is open.
Backups are overwritten on a rolling schedule; deleted data disappears from them within a few weeks.
5. Your rights
Under the GDPR you can:
- access your data and take it with you: download a JSON export from your account page, no request needed;
- correct your name, email, avatar and password yourself on the same page;
- erase everything by deleting your account there, subject only to the invoice records we must keep;
- object to processing we base on legitimate interest, and ask us to restrict processing while we look into it;
- complain to a supervisory authority. Ours is Autoriteit Persoonsgegevens; you may also complain to the authority of the country where you live.
For anything the account page cannot do, email privacy@pwnd.rs from your account address. We answer within one month. We do not use automated decision-making with legal effect on you.
6. Cookies
We set two cookies, both strictly necessary for the site to work, which is why there is no consent banner:
| Cookie | Purpose | Lifetime |
|---|---|---|
sid | Your login session (random token, HttpOnly, Secure) | 7 days or until logout |
motion | Remembers that you prefer reduced motion | 1 year |
No analytics, no advertising, no third-party cookies, no fingerprinting. The payment pages run on Mollie’s domain and use their own cookies.
7. Security
- All traffic is encrypted with TLS; the database and lab network are not reachable from the internet.
- Passwords are stored as salted scrypt hashes. We never see or email your password.
- Fix-lab checks run in sandboxes; attack-lab targets are isolated, throwaway instances that are destroyed after the exercise and cannot reach your data or other users’ targets.
- Sessions are random tokens stored hashed; you can revoke any session from Security & devices.
- Access to production is limited to the people who run the platform and is logged. Backups are encrypted.
If a breach affects your data we will tell you and the authority without undue delay, as the GDPR requires. Found a vulnerability? Tell us at privacy@pwnd.rs; we will not take action against good-faith research on the platform itself.
8. Children
pwnd.rs is for people aged 16 and over. We do not knowingly collect data from anyone younger, and team owners may not seat them. If you believe a child has created an account, email privacy@pwnd.rs and we will delete it.
9. Changes to this policy
We update this policy when the Service or the law changes. The date at the top tells you which version you are reading. For changes that affect you materially, such as a new purpose or a new category of recipients, we email you before they take effect.
10. Contact
pwnd.rs, Street 1, 1234 AB City. Privacy: privacy@pwnd.rs. Everything else: hello@pwnd.rs.
This text was drafted as a template and should be reviewed by a lawyer before relying on it.