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Privacy Policy for Sneak Out
Kinguin Studios sp. z o.o. (limited liability company), with its registered office at ul. Nowogrodzka 50/515, 00-695 Warsaw, Poland („the Controller” or “Kinguin”) is the Controller of the User’s personal data provided in accordance with the T&C (“Personal data”).
In order to preserve the right to privacy of the User and to meet the requirements of the law, in the following statement Kinguin explains and informs about the manner in which Personal data is collected, processed and secured. Before accessing and using the Game, the User should familiarize themselves with the content of this Privacy Policy.
1. The User’s Personal Data are processed in accordance with applicable laws, including the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) („GDPR”).
2. The Controller’s contact details are: gdpr@kinguin.io.
3. In connection with the User’s access and use of the Game, the Controller processes the following User’s personal data: the User’s Steam ID, Steam Friends List, nickname. Supplying the aforementioned data is necessary, otherwise User will not be able to access and use the Game.
4. Personal data are processed in order to provide the Game to the User based on the T&C and to track and display the nickname, the User’s results in the Game on Steam Platform, as well as to comply with the Controller’s legal obligations (if any) and realize the Controller’s legitimate interests (if any). The Controller will maintain the record of User’s data related to the use of the Game, such as User in-game ranking, Game’s progress and items, in order to allow continuity of progress upon reinstallation.
5. We may transfer personal data to third parties located outside of the European Union (EU) or the European Economic Area (EEA) for the purposes described in this Privacy Policy related to providing the User with access to and operation of the Game. When we transfer your personal data to such third parties, we ensure an adequate level of protection by implementing Standard Contractual Clauses (SCC) as approved by the European Commission. We take appropriate measures to ensure that your personal data remains protected and that any transfers comply with applicable data protection laws. After linking to an account on Kinguin.net, the User’s Steam ID will be shared with a company from the capital group - Kinguin Digital Limited.
6. The Personal data may be transferred to entities processing the Personal data on behalf of the Controller, among others, administrative, telco, payment, back office, legal service providers, as well as IT service providers etc. - these entities process the Personal data on the basis of a contract with the Controller and only in accordance with the Controller’s instructions. The Personal data may also be transferred to entities authorized to obtain them on the basis of the applicable law, e.g. law enforcement authorities in the event of a request being made by the authority on the appropriate legal basis (e.g. for the needs of pending criminal proceedings). The Personal data may be transferred in certain cases to recipients from third countries, i.e. from countries outside the European Economic Area, e.g. if it is necessary for the provision of services under the T&C or under a different, important legal basis.
7. Personal data will be processed during the implementation of a goal for which they have been collected, until the expiry of claims connected with the User’s access and use of the Game. After processing of the Personal data for the original purpose has ended and after the legal reporting obligations have expired, the Personal data will not be processed for any other purpose without the User’s consent.
8. The User has the right to:
a) access the Personal data: At the User’s request, Kinguin will confirm what Personal data Kinguin processes and provide the User with a copy of such Personal data.
b) rectify the Personal data: In case the User’s Personal data is inaccurate or incomplete, the User may demand from Kinguin correcting or supplementing the Personal data.
c) erase the Personal data: In certain situations, the User may claim Kinguin to remove the Personal data processed by Kinguin e.g. when the Personal data is no longer required to provide the service by Kinguin unless further processing is justified by the legitimate interest of the Controller or required under applicable law.
d) limit the processing of the Personal data: The User may demand in certain situations that Kinguin temporarily suspend processing of the Personal data. For example, the User may request to restrict the processing of the Personal data when they object to the processing or when they question the correctness of the Personal data. Despite the restriction of processing, Kinguin will still be entitled to hold the Personal Data.
e) The right to request the transfer of Personal data: In certain situations, the User has the right to receive the Personal Data processed by Kinguin in a structured, commonly used machine-readable format to transfer this data to another controller.
f) object to the processing of Personal Data: The User may demand that Kinguin cease processing the Personal data when Kinguin processes the Personal data based on Kinguin’s or third party’s legitimate interest, except in situations, where these interests are superior to the interests, rights and freedoms of the User.
g) lodge a complaint with the supervisory body dealing with the protection of personal data: the User can file a complaint to the appropriate Personal Data Protection Authority in the User’s country of residence, which in Poland is the President of the Personal Data Protection Office. However, if you are not satisfied with the way Kinguin processes your Personal Data, please contact Kinguin at gdpr@kinguin.io.
h) oppose to being a subject to automated decision making, including profiling (if any).
In order to exercise the above rights, the User may contact the Controller using contact details specified in Section 17 of this Privacy Policy for Sneak Out.
9. Providing the Personal data is a requirement necessary to access and use the Game based on the T&C. Providing the Personal data is voluntary, however required to access and use the Game.
10. The Personal data will not be processed in an automated way.
11. Processing of the Personal data in order to perform the Agreement as specified in the T&C by is based on art. 6 par. 1 b) of the GDPR - necessity to perform the contract to which the User is a party. The Personal data will be processed until the termination of Agreement, with the provision that sometimes these data can be processed also after the expiration thereof, but only if it is allowed or required under applicable law e.g. processing for statistical, billing or claims purposes.
12. Processing of Personal data in order to comply with applicable laws (anti-money laundering obligations etc.) is based on art. 6 par. 1 c) of the GDPR - necessity to comply with a legal obligation to which the Controller is a subject. The Personal data will be processed until the Controller’s legal obligations remain binding under the applicable law.
13. Processing of Personal data in order to realize the Controller’s or third party’s other legitimate interest is based on art. 6 par. 1 f) of the GDPR – the Controller’s or third party’s legitimate interest, including complaint handling, resolution of technical problems, the assertion and defence of contractual or service-related claims, including debt recovery, litigation, arbitration and mediation proceedings. The Personal data will be processed until the relevant legitimate interest remains in force.
14. Kinguin stores the User’s personal data only for the time that is necessary to achieve the purposes for which the Personal data was collected.. After this time, the Personal data is deleted or anonymized in such a way that it is not possible to establish the identity of the User. The Personal data may be stored for longer if such an obligation arises from the provisions of applicable law or if it is necessary for Kinguin to defend or seek claims against Users.
15. The Personal data is processed and stored using appropriate security measures in accordance with the requirements set by the applicable law. Kinguin secures the User’s data against unauthorized access, use or disclosure. The data is processed in a controlled environment while maintaining high standards of protection. At the same time, Kinguin draws attention to the fact that Users do not share the Personal data with third parties.
16. In case of any amendments to this Privacy Policy, Kinguin will inform the User of the introduction of such amendments.
17. Questions, applications and remarks regarding the principles of this Privacy Policy and processing of the Personal data by Kinguin should be sent by e-mail to the following e-mail address: gdpr@kinguin.io, or in writing to: Kinguin Studios sp. z o.o. (limited liability company), ul. Nowogrodzka 50/515, 00-695 Warsaw, Poland.
Kinguin Studios sp. z o.o. (limited liability company), with its registered office at ul. Nowogrodzka 50/515, 00-695 Warsaw, Poland („the Controller” or “Kinguin”) is the Controller of the User’s personal data provided in accordance with the T&C (“Personal data”).
In order to preserve the right to privacy of the User and to meet the requirements of the law, in the following statement Kinguin explains and informs about the manner in which Personal data is collected, processed and secured. Before accessing and using the Game, the User should familiarize themselves with the content of this Privacy Policy.
1. The User’s Personal Data are processed in accordance with applicable laws, including the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) („GDPR”).
2. The Controller’s contact details are: gdpr@kinguin.io.
3. In connection with the User’s access and use of the Game, the Controller processes the following User’s personal data: the User’s Steam ID, Steam Friends List, nickname. Supplying the aforementioned data is necessary, otherwise User will not be able to access and use the Game.
4. Personal data are processed in order to provide the Game to the User based on the T&C and to track and display the nickname, the User’s results in the Game on Steam Platform, as well as to comply with the Controller’s legal obligations (if any) and realize the Controller’s legitimate interests (if any). The Controller will maintain the record of User’s data related to the use of the Game, such as User in-game ranking, Game’s progress and items, in order to allow continuity of progress upon reinstallation.
5. We may transfer personal data to third parties located outside of the European Union (EU) or the European Economic Area (EEA) for the purposes described in this Privacy Policy related to providing the User with access to and operation of the Game. When we transfer your personal data to such third parties, we ensure an adequate level of protection by implementing Standard Contractual Clauses (SCC) as approved by the European Commission. We take appropriate measures to ensure that your personal data remains protected and that any transfers comply with applicable data protection laws. After linking to an account on Kinguin.net, the User’s Steam ID will be shared with a company from the capital group - Kinguin Digital Limited.
6. The Personal data may be transferred to entities processing the Personal data on behalf of the Controller, among others, administrative, telco, payment, back office, legal service providers, as well as IT service providers etc. - these entities process the Personal data on the basis of a contract with the Controller and only in accordance with the Controller’s instructions. The Personal data may also be transferred to entities authorized to obtain them on the basis of the applicable law, e.g. law enforcement authorities in the event of a request being made by the authority on the appropriate legal basis (e.g. for the needs of pending criminal proceedings). The Personal data may be transferred in certain cases to recipients from third countries, i.e. from countries outside the European Economic Area, e.g. if it is necessary for the provision of services under the T&C or under a different, important legal basis.
7. Personal data will be processed during the implementation of a goal for which they have been collected, until the expiry of claims connected with the User’s access and use of the Game. After processing of the Personal data for the original purpose has ended and after the legal reporting obligations have expired, the Personal data will not be processed for any other purpose without the User’s consent.
8. The User has the right to:
a) access the Personal data: At the User’s request, Kinguin will confirm what Personal data Kinguin processes and provide the User with a copy of such Personal data.
b) rectify the Personal data: In case the User’s Personal data is inaccurate or incomplete, the User may demand from Kinguin correcting or supplementing the Personal data.
c) erase the Personal data: In certain situations, the User may claim Kinguin to remove the Personal data processed by Kinguin e.g. when the Personal data is no longer required to provide the service by Kinguin unless further processing is justified by the legitimate interest of the Controller or required under applicable law.
d) limit the processing of the Personal data: The User may demand in certain situations that Kinguin temporarily suspend processing of the Personal data. For example, the User may request to restrict the processing of the Personal data when they object to the processing or when they question the correctness of the Personal data. Despite the restriction of processing, Kinguin will still be entitled to hold the Personal Data.
e) The right to request the transfer of Personal data: In certain situations, the User has the right to receive the Personal Data processed by Kinguin in a structured, commonly used machine-readable format to transfer this data to another controller.
f) object to the processing of Personal Data: The User may demand that Kinguin cease processing the Personal data when Kinguin processes the Personal data based on Kinguin’s or third party’s legitimate interest, except in situations, where these interests are superior to the interests, rights and freedoms of the User.
g) lodge a complaint with the supervisory body dealing with the protection of personal data: the User can file a complaint to the appropriate Personal Data Protection Authority in the User’s country of residence, which in Poland is the President of the Personal Data Protection Office. However, if you are not satisfied with the way Kinguin processes your Personal Data, please contact Kinguin at gdpr@kinguin.io.
h) oppose to being a subject to automated decision making, including profiling (if any).
In order to exercise the above rights, the User may contact the Controller using contact details specified in Section 17 of this Privacy Policy for Sneak Out.
9. Providing the Personal data is a requirement necessary to access and use the Game based on the T&C. Providing the Personal data is voluntary, however required to access and use the Game.
10. The Personal data will not be processed in an automated way.
11. Processing of the Personal data in order to perform the Agreement as specified in the T&C by is based on art. 6 par. 1 b) of the GDPR - necessity to perform the contract to which the User is a party. The Personal data will be processed until the termination of Agreement, with the provision that sometimes these data can be processed also after the expiration thereof, but only if it is allowed or required under applicable law e.g. processing for statistical, billing or claims purposes.
12. Processing of Personal data in order to comply with applicable laws (anti-money laundering obligations etc.) is based on art. 6 par. 1 c) of the GDPR - necessity to comply with a legal obligation to which the Controller is a subject. The Personal data will be processed until the Controller’s legal obligations remain binding under the applicable law.
13. Processing of Personal data in order to realize the Controller’s or third party’s other legitimate interest is based on art. 6 par. 1 f) of the GDPR – the Controller’s or third party’s legitimate interest, including complaint handling, resolution of technical problems, the assertion and defence of contractual or service-related claims, including debt recovery, litigation, arbitration and mediation proceedings. The Personal data will be processed until the relevant legitimate interest remains in force.
14. Kinguin stores the User’s personal data only for the time that is necessary to achieve the purposes for which the Personal data was collected.. After this time, the Personal data is deleted or anonymized in such a way that it is not possible to establish the identity of the User. The Personal data may be stored for longer if such an obligation arises from the provisions of applicable law or if it is necessary for Kinguin to defend or seek claims against Users.
15. The Personal data is processed and stored using appropriate security measures in accordance with the requirements set by the applicable law. Kinguin secures the User’s data against unauthorized access, use or disclosure. The data is processed in a controlled environment while maintaining high standards of protection. At the same time, Kinguin draws attention to the fact that Users do not share the Personal data with third parties.
16. In case of any amendments to this Privacy Policy, Kinguin will inform the User of the introduction of such amendments.
17. Questions, applications and remarks regarding the principles of this Privacy Policy and processing of the Personal data by Kinguin should be sent by e-mail to the following e-mail address: gdpr@kinguin.io, or in writing to: Kinguin Studios sp. z o.o. (limited liability company), ul. Nowogrodzka 50/515, 00-695 Warsaw, Poland.