PRIVACY POLICY GRIMCOVEN

This Privacy Policy („Policy”) is designed to inform You about how we collect, use, and share Your Personal data, Your rights regarding the information You provide to us when You use our application GRIMCOVEN. 

Contents:

1. Basic definitions.

2. What Personal data do we collect and process, what is the purpose of processing and what is the legal basis?

3. How long do we process Your Personal data for?

4. Who has access to Your Personal data?

5. What are Your rights regarding Your Personal data?

6. Final provisions.

1. BASIC DEFINITIONS

1. Application - application GRIMCOVEN provided by Controller;
2. Personal data – any information relating to You, that allows Your identification i.e.: name, surname, e-mail address, phone number, IP address 
3. Controller (“we”, “our’, “us”) – Realms Distribution Sp. z o.o. (limited liability company) with its registered office in Wrocław (50-127) at the following address: ul. św. Mikołaja 58, entered into the registry of entrepreneurs of the Polish National Court Register kept by the District Court for Wrocław-Fabryczna, VIth Commercial Division under KRS number 0000637257, holder of Business entity statistical number (REGON): 365403324, Polish taxpayer’s identification number (NIP): 8992798122, holder of share capital in the amount of 26 500,00 PLN („Realms Distribution”);
4. 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);
5. Services – all services provided to You by us;.
6. You – a player who uses our application Nemesis.

2. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS, WHAT IS THE PURPOSE OF PROCESSING AND WHAT IS THE LEGAL BASIS?

1. The only data based on which we can link You as a player with Your identity as a natural person is Your name. We process such data for the purpose of enabling Your gameplay, and such processing is necessary for the performance of a contract between You and us (legal basis: Article 6.1(b) of the GDPR). Providing us with such data is not Your legal obligation, but it is necessary for You to make use of our Services and use our Application.
2. Moreover, we collect gameplay data in order to provide the necessary information for the game development. Gameplay data is linked to a unique Player ID, to which we do not collect and assign data of a natural person. Such data may typically include gameplay-related information such as: choices made in the game and reaction time, the popularity of particular character or scenario in the game, players’ achievements, time spent in the Application. To the extent this data may constitute the Personal data within the meaning of the GDPR we process such data for the purpose of development of our Application what constitutes our legitimate interest (legal basis: Article 6.1. (f) of the GDPR). 
3. Please also be aware that in case You contact us or create a claim, we will collect and store Your Personal data such as name, surname, e-mail address, phone number, etc. in accordance with our legitimate interest for the period specified in point 3 (based on the art. 6.1.(f) of the GDPR).
4. We may also process Your Personal data if it is necessary for us to comply with our legal obligation (based on the art. 6.1.(c) of the GDPR) or if You give us Your consent to the processing for one or more purposes (based on the art 6.1(a) of the GDPR).

 3. HOW LONG DO WE PROCESS YOUR PERSONAL DATA FOR?

1. We store Personal data not longer than the time necessary to achieve the purposes, for which they are processed. 
2. Your name is being processed for as long as You have an active Application.
3. If we process Your Personal data to determine or assert any claims or to defend against above mentioned claims, we store the Personal data until the laps of the limitation period for those claims, which arise from the generally applicable provisions of law.
4. If we process Your data which is Personal data within the meaning GDPR to develop our Application, we store this data until You file an effective objection. Please note that we may store fully anonymized data until we need it.
5. If we process Your Personal data to comply with our legal obligation, we store the Personal data for a period of performing such obligation.
6. If we process Your Personal data on the basis of Your consent, such data is being processed until the withdrawal of Your consent or by the time the purpose, for which it was collected, ceases to exist.

4. WHO HAS ACCESS TO YOUR PERSONAL DATA?

1. If we collect Your Personal Data You can rest assured that the access to Your Personal data will be granted only to entities that support us in service providing, based on appropriate contracts e.g. legal, consulting, IT, telecommunication service providers.
2. All these entities will have access only to necessary information.
3. Sometimes, the entities providing us with IT solutions are registered outside the European Economic Area (EEA). In this case, if Your Personal data is processed outside the EEA, we will provide the appropriate legal mechanisms for their security, including standard data protection clauses adopted under the decision of the European Commission, and - if necessary - we conclude data processing agreements that meet the requirements of the GDPR. You have the right to access the list of such recipients and a copy of the security measures we use. If we do not provide adequate security measures, we will inform You about it and ask for Your consent to transfer such data. Without adequate protection or possible consent, we will not undertake the transfer of Your Personal Data outside the EEA.
4. We may also be required to provide specific information relating to You, to public authorities for the purposes of proceedings conducted by them. In this case, the information is provided only if there is a proper legal ground.

5. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA? 

You have the following rights:

1. Right of access. In any time, You can obtain from us confirmation as to whether or not Your Personal data are being processed, access to the Personal data and the following information:

• the purposes of the processing;
• the categories of Personal data concerned;
• who are the recipients;
• where possible, the envisaged period for which the Personal data will be stored, or, if not possible, the criteria used to determine that period;
• where the Personal data is not collected from the data subject, any available information as to their source;
• the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

2. Right to rectification. If You feel that the information relating to You is incorrect or incomplete, You have the right to request the rectification of the data.
3. Right to withdraw the consent. You can withdraw Your consent at any time, without affecting the legality of the processing, which was performed prior to this withdrawal.
4. Right to erasure (‘right to be forgotten’). The GDPR gives You the right to obtain from us the erasure of all Your Personal data. We are obligated to make Your request, only if one of the following grounds applies: 

• Your Personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• You withdrew consent on which the processing is based and where there is no other legal ground for the processing;
• You object to the processing and there are no overriding legitimate grounds for the processing;
• You object to the processing for direct marketing purposes;
• the Personal data have been unlawfully processed;
• the Personal data have to be erased for compliance with a legal obligation in European Union or Member State law to which the controller is subject;
• the Personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

5. Right to restriction of processing. You can also obtain the restriction of processing, where one of the following applies:

• You contest the accuracy of the Personal data – for a period enabling us to verify the accuracy of the Personal data;
• the processing is unlawful but You oppose the erasure of Your Personal data and You request the restriction of their use instead;
• we no longer need Your Personal data for the purposes of the processing, but they are required by You for the establishment, exercise or defense of legal claims;
• You have objected to processing – only until the dispute is resolved.

6. Right to data portability. You have right to receive Your Personal data in a structured, commonly used and computer-readable format and have the right to transmit those data to another controller, when:

• the processing is based on Your consent or on a contract, and
• the processing is carried out by automated means.

7. Right to object. According to GDPR You have the right to object when we process Your Personal data on our legitimate interest. 
8. Right to lodge a complaint with a supervisory authority. Due to our actions as a Controller, You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of Your habitual residence, place of work or place of the alleged infringement.
9. If You want to lodge a complaint in Poland, the function of the supervisory authority is held by the President of the Data Protection Office / Prezes Urzędu Ochrony Danych Osobowych (PUODO). A detailed description of the procedure for lodging a complaint to PUODO is available on the website maintained by PUODO which You can access by clicking the following link: https://uodo.gov.pl/. 
10. For efficient implementation of Your rights, please send all requests to the e-mail address: privacy@awakenrealms.com, with the subject: “GDPR’s demand”, indicating which right You want to exercise.

 6. FINAL PROVISIONS

1. We have appointed a Data Protection Officer, contact details: privacy@awakenrealms.com.
2. We do not use any information provided by You for the purposes of automated decision-making, including profiling.
3. We constantly review our Policy and strive towards making it better. That is why we reserve the right to amend this Policy from time to time. Each amendment to the Policy will be published in the Application and will be effective from the date of publication.