App Privacy policy

THE KNIGHTS OF UNITY SP. Z O.O. 
PRIVACY POLICY

Protecting your personal data is of great importance to us. We encourage You to read our Privacy Policy below. 

§ 1 

Definitions

Controller – the personal data controller within the meaning of Article 4(7) of the GDPR, that is The Knights of Unity sp. z o.o. with its registered office in Poland, Wrocław (50-224) pl. Strzelecki 25, KRS (company number): 0000695250, Polish Tax Number: 8982236807

Cookies – text data collected in the form of files placed on the Device when you visit a particular website, which store information about your use of it and sometimes tracks information about you

GDPR – Regulation of the European Parliament and of the Council (EU) 2016/679 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 – a device with software through which the User gains access to the Services

Personal Data – information about an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual

processing – an operation or a set of operations performed on Personal Data or sets of Personal Data, whether or not by automated means, such as collecting, recording, organising, structuring, storing, adapting or modifying, retrieving, viewing, using, disclosing by transmission, dissemination or otherwise sharing, aligning or combining, restricting, erasing or destroying

Privacy Policy – this document

Services – services offered by TKoU via Website and its social media profiles as well as mobile and video games offered by TKoU and game related services

TKoU, we – The Knights of Unity sp. z o.o. 

You, User – a natural person using the Services offered by the Controller In the case of a minor or completely incapacitated person, the legal representative of that person is considered to be the User.

Website – a website where the Controller provides its Services, that is: www.theknightsofu.com   

§ 2

Data Controller

Your Personal Data Controller is a Polish limited liability company, The Knights of Unity Sp. z o.o. (“TKoU”), with its registered office in Poland, Wrocław (50-224) pl. Strzelecki 25, KRS: 0000695250, Polish Tax Number: 8982236807. You can contact us at the following e-mail address: gdpr@theknightsofunity.com or traditional mail at the address: The Knights of Unity Sp. z o.o., pl. Strzelecki 25, 50- 224 Wrocław, Poland. 

§ 3

Scope and general provisions 

  1. This Privacy Policy sets out the rules for the processing and protection of Personal Data provided by Users in connection with their use of the Services and rights Users are entitled to in this context. 
  2. The Privacy Policy applies to all Users using our Services by:
  • purchasing and playing our mobile and video games, unless such games have dedicated Privacy Policies;
  • visiting our Website or TKoU’s social media profiles;
  • contacting our customer service or sales representatives;
  • contacting us through a contact form;  
  • taking part in the events that we organise;
  • receiving our newsletter;
  • participating in research analyzes in games;
  • participating in pre-release tests;
  • reporting irregularities which may constitute a breach of law, internal procedures or ethical standards or which in any other way may negatively affect our business activity or reputation.

§ 4

How do we collect Personal Data?

  1. We collect Personal Data: 
  • directly from the User when the User uses our Services (by filling in various forms on the Website or by communicating directly with us);
  • indirectly from social media platforms, publishers of our games or owners of digital distribution platforms where you purchase and through which you play our games; 
  • automatically when the User accesses or uses the Website (technical data, IP address, information relating to his/her browsing, etc.).
  1. If you create or log in to your account using a third-party platform and when you choose to link a third-party tool (e.g., Facebook, Messenger, or Google) to our Services, or when you use the Services (in particular, by playing our games) through any third-party applications, we may come into possession of some of your data that will be provided to us by the provider of the aforementioned third-party applications. The information we obtain depends on the Services you use (this applies, in particular, to the game you play), the third-party applications you use, your privacy settings and, if applicable, the privacy settings of your friends in third-party applications. We may collect and store some or all of the following information from the provider of the third-party application:
  • name and surname;
  • profile picture, your user ID (Facebook ID), which may be associated with your publicly available information (profile picture);
  • your friends’ list and other publicly available data;
  • email address provided in the respective application belonging to a third party;
  • your location and the location of the devices on which you use our Services;
  • gender;
  • age;
  • information regarding other activities undertaken through or in third-party applications;
  • other publicly available data made available in applications belonging to third parties.
  1. If you play our games connected with third-party apps or their platforms (such as e.g. Apple, Google, Steam), all purchases made by you will be processed by the respective third-party application and will be subject to the terms of service and privacy policy of the respective third party. TKoU does not come into possession of your financial data related to the above-mentioned purchases, but may obtain access to your non-financial information related to the purchases made by you, such as your name and surname and the items purchased by you. The type of information we receive depends on the game you play and the third-party application.
  2. We may receive Data about You from our partners or third parties, like for example Steam and its third parties. We may collect Data about You from such account, including e.g. your Steam name, Steam ID. We may also receive Data from third parties (such as game distributors) to add to the Data we possess to prevent fraud and/or abuse.

§ 5

Purposes and legal bases for the Personal Data processing

Personal Data obtained as part of the operation of Services are processed on the following basis. 

  1. In connection with the provision of Services offered by the Website:
  • the legal basis for the processing of Personal Data is a contract, i.e. processing is necessary to perform a contract to which the data subject is a party, or to take action at the request of the data subject before concluding a contract (Article 6(1)(b) of the GDPR),
  • we may process information concerning your activity on our Website, including your Personal Data, as recorded in system logs and through analytical scripts, IP address automatically assigned to your computer when you use the Internet, the type of internet browser you are using, the type of operating system and Device you use to access the Website; the domain name of your Internet service provider, the web page you came from, your country of residence and language, the pages and features you visit and access on our Website, as well as the time spent on those pages. We use this Data primarily for the purposes of providing our Services, for technical and administrative purposes, for the security and management of the IT system, and for analytical and statistical purposes. In this respect, the legal basis for the processing of Personal Data is our legitimate interest (Article 6(1)(f) of the GDPR). We indicate that our legitimate interests shall be also maintenance and development and improvement of Services (legal basis: legitimate interests i.e. Article 6.1. (f) GDPR);
  • on our Website we also use Cookies and similar tracking solutions to ensure its proper functioning and compliance with the provisions of law, as well as to measure traffic on the Website and collect certain data relating to your use of the Products and Services and your activity on the Website. You can find more about this in our Cookies Policy.
  1. When you are a player or purchaser of our games: 
  • we get access to the Personal Data concerning You and your activity as a player in the following situations we process your Personal Data (e.g. name, ID, IP address, information about your devices and software used by You, uncontrolled exit report and player device error information, game statistics, your game experience, duration, time of use, trials, progress, results, and saved preferences in-game activity including but not limited to what games you play, own, how you play, how often and for how long, multiplayer sessions, when these sessions were played and which players were in them, friend relations added to the Friends List in chat systems in games). We use this Data primarily for the purposes of providing our Services, for technical and administrative purposes, for the security and management of the IT system, and for analytical and statistical purposes. In this respect, the legal basis for the processing of Personal Data is our legitimate interest (Article 6(1)(f) of the GDPR). We indicate that our legitimate interests are also the following: maintenance and development of games and Services, delivery of software updates, tracking and fixing bugs, ensuring integrity and security in games, organizing and carrying tests/betatests of game to which player signed up, establishment, assertion or defense against claims and protecting our rights, protection of unauthorized access; we may also manage your in-game account; enable you to contact other users, update your user profile, and provide other services that are necessary for you to play our games.
  1. In connection with contacting our customer service or sales representatives, contacting us through a contact form:
  • when you communicate with us, for example via an external tool/chat, e-mail, forms published on the Website or within the Services, Discord, social media, etc., we may process your Personal Data that identify you (e.g. e-mail address, IP number, your nickname), metadata concerning the contact (e.g. contact date, duration of our conversation) and also the content of our communication (e.g. chat conversation history, e-mail content);
  • your Personal Data is processed in order to answer your inquiry, improving our communication, improving the quality of customer service, as well as for marketing purposes and concluding an agreement. In such cases, the legal basis for processing depends on the communication context. If you contact us to receive information regarding Services, as a rule, we process your Personal Data based on our legitimate interest (resulting from the abovementioned purposes; Article 6(1)(f) of the GDPR). The legitimate interest of TKoU exists in the necessity to respond to the Users or, depending on the context of your question, to promote our Services. However, if your inquiry leads to the conclusion of an agreement, the legal basis for processing shall be Article 6(1)(b) of the GDPR – taking steps at the request of the data subject prior to entering into a contract;
  • we can also send you commercial information about TKoU or our Services via electronic mail after your prior consent (e.g. newsletters). The consent is entirely voluntary. The User can opt out of commercial information via electronic means at any time, (it does not affect the lawfulness of sending commercial information based on consent before its withdrawal). The legal basis for processing of your Personal Data for this purpose is our legitimate interest (Article 6(1)(f) of the GDPR) –marketing;
  • we can also process your Personal Data for contact purposes, i.e. receiving and handling reports and inquiries sent via the contact form, e-mail, telephone or other means of distance communication, pursuant to Article 6(1)(f) of the GDPR, where the legitimate interest of the Controller is to respond to submitted notifications and inquiries,
  • when you are informing us about irregularities regarding TKoU you observed, we will process your data to fulfil our legal obligations (Article 6(1)(c) GDPR) or– in case of any other irregularity – based on our legitimate interest (art. Article 6(1)(f) of the GDPR). In this case we have a legitimate interest in preventing or responding to situations that may constitute a violation of law or the norms and standards adopted by us;
  • If you wish to participate in our playtests, we will process the data you provide us in your application. In this case, we will act on the basis of your consent, which you give by submitting your application (Article 6(1)(a) of the GDPR).
  1. The personal data may be also processed in following purposes: 
  • execution of legal obligations related, among others, to in-game payments, ensuring fair practices, preventing fraud and other illegal activities, ensuring compliance with applicable laws and regulations (legal basis: the necessity to comply with a legal obligation, i.e. Article 6(1)(c) GDPR); 
  • User’s service i.e. answering questions, comments, chat support, provision of technical support (legal basis: legitimate interests in solving the User’ problems i.e. Article 6(1)(f) GDPR);
  • determination, investigation and defense against legal claims (legal basis: legitimate interests in providing Controller with effective legal protection, i.e. Article 6(1)(f) GDPR);

§ 6

Providing Personal Data 

If you want to use the Services we offer, you must provide us with the data needed to provide it. However, providing the necessary data and using the Services is fully voluntary – failure to provide Personal Data which are necessary to use a given Service, may prevent the User from using this Service. 

§ 7

Your rights 

  1. To the extent provided for by the law, you may request Controller to exercise the following rights you have: 
  • the right to access  – you have the right to access your Personal Data collected by Controller at any time, you can make a subject access request using gdpr@theknightsofunity.com address;
  • the right to rectify your information which we are processing at any time if they are incorrect or incomplete. To use this right please send us an e‑mail to gdpr@theknightsofunity.com;
  • the right to erase your Personal Data – we shall erase your data once the purpose for which they were collected has been accomplished; you withdraw your consent on which the processing is based (in scope of this consent); you object to data processing; data has been processed unlawfully; data have to be erased for compliance with a legal obligation. At any time you have the right to request us to erase your Personal Data or restrict the processing thereof. To use these rights please send us an e‑mail to: gdpr@theknightsofunity.com;
  • the right to limit processing of your Personal Data;
  • the right to transfer your Personal Data – you have the right to request us to send you your data which we have collected. If technically feasible we shall send your data in a common format, in a way indicated by you and to a specified address. To use this right please send us an e‑mail to: gdpr@theknightsofunity.com;
  • the right not to be subject to automated decision- including profiling – if the data processing (profiling) is based on our legitimate interests, you have the right to object to such data processing at any time due to your particular situation. In such a case, the Controller is not entitled to process (profile) your data, unless it demonstrates compelling and justified grounds for their processing that override your interests, rights, and freedoms, or when the processing is necessary to establish, perform or defend against legal claims. If we use the User’s data to profile them for direct marketing purposes, the User has the unconditional right to object to such processing at any time. In such a case, the User’s Personal Data will no longer be processed for such purposes, regardless of our interests, rights, and freedoms;
  • the right to object to the processing of your Personal Data – if we are processing your Personal Data for a legitimate interest, you have the right to object at any time. To use this right please send us an e‑mail to:  gdpr@theknightsofunity.com;
  • the right to lodge a complaint regarding processing of your Personal Data by TKoU to your local data protection authority or to the President of the Polish Office of Data Protection – Prezes Urzędu Ochrony Danych Osobowych in Poland (address: Stawki 2, 00-193 Warsaw, Poland; https://uodo.gov.pl/en). Such a complaint may also be submitted to any other personal data protection authority in one of the Member States of the European Union;
  • to the extent you gave us your consent to process your Personal Data, you have the right to withdraw your consent at any time –  withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. To use this right please send us an e‑mail to: gdpr@theknightsofunity.com. 
  1. The execution of certain of your rights may be limited by the provisions of law or the Controller’s legitimate interests.

§ 8

Recipients of your Personal Data

  1. We may share your Personal data with our personnel, partners who help us deliver our Services to you, and who provide us with legal or tax support. This includes:
  • authorized personnel of TKoU;
  • technical service providers such as cloud storage;
  • partners providing us with internal management and data-sharing tools;
  • partners who help us in data analysis by providing us with analytical tools;
  • partners who help us manage email communications by providing us with email marketing tools;
  • partners supporting us in handling correspondence;
  • partners providing marketing services to us;
  • partners providing external IT service (including the providers of IT systems),
  • law firms providing us with legal support;
  • partners providing us with consulting, advisory; 
  • entities providing postal or delivery services;
  • operators of online payment platforms, entities cooperating with us in the field of sales;
  • accounting, law, tax and IT companies entrusted to process Personal Data on behalf of Controller
  1. When required by law, we may also share your Personal Data with courts, police authorities, law enforcement authorities or regulators.
  2. Our Services include third-party features such as social media tools and plugins, APIs or SDKs, and in-game advertising. You can also contact us via Discord. Our Websites may contain links to other websites, including through our social media buttons. We are not responsible for the content, security or privacy practices of other websites, and a link does not constitute an endorsement of such a website. When you navigate from our site to another website, you are subject to that site’s terms and conditions, including but not limited to its privacy policies and practices. Please check these policies before submitting any data to these sites. These partners may have access to your Personal Data. When these entities process personal information, they do so in accordance with their own privacy policies and principles. We encourage you to read these documents to learn more about their practices regarding the processing of Personal Data. 

Meta – https://developers.facebook.com/terms/dfc_platform_terms/   

Unity – https://unity.com/legal/privacy-policy  

Epic Games – https://www.epicgames.com/site/en-US/privacypolicy  

Google – https://policies.google.com/privacy 

Youtube- https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/ 

Discord – https://discord.com/privacy 

  1. In addition, your information may be shared in connection with your use of community features (such as forums and chats) in games. When you use these features, other users may, for instance, see your profile data, and in-game activity data and read your posts. 

§ 9

Duration of storing Personal Data 

  1. We will keep your Personal Data only for as long as needed to fulfil the purposes outlined in this Privacy Policy. In particular, we store your Personal Data for as long as it is necessary to provide our Services to you. 
  2. We may also store your Personal Data for the duration of our legitimate interests in the data processing or until the moment specified by law. 
  3. The storage time of your Personal Data may also be extended if it becomes necessary to protect our rights.

§ 10

Data transfers outside EEA

  1. Your Personal Data may be processed, stored or transferred to various countries, including countries outside the European Economic Area (“EEA”) e.g. to the United States. If so, we will protect your Personal Data using EU standard contractual clauses or other acceptable measures to transfer and protect your Personal Data.
  2. We ensure an adequate level of protection for your Personal Data and rely on legally recognized bases for data sharing, such as Privacy Framework, the EU Standard Contractual Clauses and decisions of the European Commission stating the appropriate level of protection of personal data in a given country. 
  3. You have the right to obtain a copy of your Personal Data transferred to a third country.

§ 11

Automatic processing and profiling

  1. When you use our Services, we collect data about your interactions with the Services and other users in the game through server logs. In order to display personalized advertisements, ensure the security of our Services, and analyze and monitor your use of our Services for such purposes as, for example, improving our games, we may automatically profile and segment all data collected about you  (the information provided by you may be linked to your layer ID, IP address or device ID). We may also undertake marketing activities related to addressing our personalized offers and benefits to you. The legal basis for such processing of Personal Data is the contract for Services between us and you (execution of the contract) and our legitimate interests.
  2. Any automatic processing or profiling will not lead to any legal effects for You, or similarly have significant influence on your situation. We pay particular attention to the issue of profiling, and indicate that: for the needs of profiling we do not process any sensitive data, for the needs of profiling we usually process Data which have already been subject to pseudonimisation or Data which have been aggregated by us. If we are not able to achieve a purpose by other means than profiling of Personal Data which have not been pseudonimised or aggregated, we use typical data: e-mail address and IP or Cookies.

§ 12

Push Notifications in our games 

We may send push notifications through some of our games in order to inform Users about game updates and new records, as well as to send other notifications related to the Services that may be significant to you. You may at any time resign from receiving such notifications by disabling them on your device using the settings.

§ 13

Age restrictions 

  1. Protecting children’s privacy is of high importance for us. Some of our Services or Products may not be intended for persons under a certain age, and we do not knowingly collect data relating to such persons. We use age classifications labels (e.g. PEGI) on our games. Video content, if any, is as a rule published on external sites that have age restriction policies.
  2. Holders of parental responsibility are invited to monitor the use that minors in their care make of our online services and to support them in protecting their privacy.  If you believe that we have received information from a person protected under child protection laws where necessary parental consent was not obtained, please notify us immediately, and we will take reasonable steps to securely remove such information.

§ 14

Personal Data Security

  1. We carry out risk analysis on an ongoing basis to ensure that Personal Data is processed by us in a secure manner, ensuring in particular that only authorized persons have access to the Personal Data and only to the extent that this is necessary for their tasks. We make sure that all operations on Personal Data are recorded and performed only by authorized employees and associates.
  2. We implement appropriate technical and organizational measures to protect your Personal Data against accidental or unlawful destruction, accidental loss, alteration, dissemination or unauthorized access to such Personal Data.
  3. We also monitor how our service providers process your Personal Data, so that they provide sufficient guarantees that appropriate data security measures are in place.
  4. We take all the necessary steps to ensure that our subcontractors and other cooperating entities also guarantee the application of adequate security measures whenever they process Personal Data on our behalf.

§ 15

Updates of Privacy Policy

We may update this Privacy Policy by posting its new versions on the Website and in the relevant games.