Game Hub Privacy Policy

  1. Definitions

Controller, data controller – Enterosoft Sp. z o. o. with its registered office in Gdańsk, ul. Starodworska 1, 80-137 Gdańsk, court registration (KRS): 0000850020, Tax ID (NIP): 5833401725, National Official Business Register (REGON): 386524824, (hereinafter: We or the Controller).

Application, Service –the Game Hub application offered by the Controller in compliance with the Rules (hereinafter: the Application or Service).

User – a natural person, irrespective of age, using the Application.

Cookie files or other similar technologies – Cookie files or other tools used in Application, intended for similar purposes i.e. collection, recording and storage of information about Users’ activity.

Rules – the Game Hub Application Rules

GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 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).

Device – an electronic device permitting data processing, reception and transmission without the need to maintain a cable connection with the Internet, e.g. smartphones, tablets and consoles.

  1. Contact

Users may contact us:

  1. Data Protection Officer

As we have no duty to do so, we have not appointed the Data Protection Officer. You may obtain a response to any doubts and questions about personal data by sending an e-mail to: privacy@enterosoft.com

  1. Information about personal data processing

DATA PROCESSED BY US, THE PURPOSES AND TIME OF PROCESSING

  1. Service provision

To ensure the option to use the functionalities of the Application, we will process the following data: your first and last name, account ID by means of which you log into the Application (Facebook, Google, Apple ID), gender, age and e-mail.

These data are processed in conformity with Article 6(1)(b) of the GDPR to the extent as the Service is used, and until the definite cessation of the use of the Application by the User, in compliance with the Rules.

  1. Complaints

To handle complaints, we process the personal data of the Users filing the complaints, in particular the e-mail, first and last name, complaint content, the circumstances of the event which is the reason for the complaint, information obtained in the course of the complaint handling procedure, including the explanation for the event which is the reason for the complaint. In the course of complaint handling, we may processes other pieces of information, including the User’s first and last name, e-mail, information on the User’s taking advantage of the Services, Cookie Files or other similar technologies and information about devices.

Data are processed in compliance with Article 6(1)(b) of the GDPR for the provision of the services i.e. for the performance the electronic services agreement, in compliance with the Rules, and are processed over the time necessary to handle complaints, not longer than for 3 months from the end of the complaints procedure, for storage purposes, in case there is a need for defence against claims, if any.

  1. Explanatory proceedings and the pursuance of claims

If explanatory proceedings are undertaken which concern any breach of the Rules, law, rules of social contract or good manners, or if proceedings are undertaken to pursue claims by the Controller or other Users or entities, for the defence against claims made by Users or other entities, we may process personal data of specific Users until the end of the proceedings and until the expiry of the time for prescription of the Controller’s claims against the User, such time usually being 3 years.

If personal data are processed for the pursuance of other Users’ claims, those data may be disclosed for that purpose to another User, entity or public authority entitled under law, e.g. courts, the police or prosecution service.

Those data will then be processed, including disclosure, in compliance with Article 6(1)(c) of the GDPR, i.e. to perform a legal obligation, or in compliance with Article 6(1)(f) of the GDPR, i.e. in the Controller’s legitimate interest consisting in pursuing his claims against the User. The Controller’s legitimate interest will then be overriding in relation to his rights and freedoms.

  1. Contact

When you contact us, you should provide your e-mail address. Information, in particular personal data, obtained in the course of correspondence with the User, will be used by us to respond to your message.

These data are processed in compliance with Article 6(1)(f) of the GDPR in the Controller’s and Users’ legitimate interest consisting in the need to ensure contact. The content of correspondence and contact details are processed for the time necessary to resolve the User’s matter and, for storage purposes, not longer than for 3 months after the matter has been resolved.

  1. Analysis of the service User's behaviour / cookie files

To improve Service quality and for statistical purposes, we process information about Service usage, such as the IP address, the data and ID of the device on which the Application is installed (the system, device model, Application configuration), data about errors from the Application, time and date of Application usage and the advertising ID, as well as cookie files or other similar technologies. The User may manage the settings of the cookie files and advertising ID’s  from the level of his or her device.

These data are processed on the basis of Article 6(1)(f) of the GDPR for the Controller’s legitimate interest in facilitating the use of the Service and improving its quality and functionality. The information is processed for 3 months from its acquisition, but no longer than until the data subject has filed an objection.

  1. Marketing activities

E-mail addresses and other data concerning the Users’ identity are not used by the Controller for marketing purposes. The Controller protects the above-mentioned data of the Users against the transmission of other entities’ marketing content with the use of such data. The Controller may, however, sporadically sent information about his promotion activities. The Controller does not undertake any profiling activities, in particular he does not analyse information about Users or create their behavioural profiles.

Processing of User information by the Controller takes place on the basis of the Controller's legitimate interest (Article 6(1)(f) of the GDPR) in undertaking marketing activities in order to present marketing information. The User may, at any time, make an objection against the transmission of marketing materials.

  1. Change of data

Certain personal data may be changed by the User by using the options available in the Service.

USERS’ RIGHTS

In relation to personal data processing, the User has the following rights (to use them, please contact us):

SECURITY

We ensure the confidentiality of any personal data provided to us. We ensure that appropriate security and data protection measures are taken as required by data protection laws. Personal data are collected with due care and adequately protected from access by unauthorised persons.

DATA RECIPIENTS AND PERSONAL DATA TRANSFER TO THIRD COUNTRIES

Your personal data will be processed by third party entities whose services we use, or through which you log in the Game Hub, in particular:

We transfer your personal data to third countries in connection with the use of tools that store personal data on servers located in third countries, in particular the USA. The providers of these tools guarantee an adequate level of protection of personal data through the relevant compliance mechanisms provided by the GDPR, in particular the use of standard contractual clauses.

PROFILING

We do not make decisions based on automated processing only, including profiling, which would cause legal effects in relation to or significantly affect the User.

CHANGES IN THE PRIVACY POLICY

The Privacy Policy may be supplemented or updated as necessary in order to provide current and reliable information to Users with regard to their personal data and information about such data. Users will be notified of any changes in the Privacy Policy in the Services and, if the Controller deems it appropriate or necessary, to the e-mail address provided by the User.