ATGM OPEARATOR GAME PRIVACY POLICY

Protecting personal information and privacy is a fundamental value for us, so in terms of this Privacy Policy (“Policy”) we fulfill our informative duty imposed on us by the power of European Parliament and Council (EU) 2016/679 from the 27th of April 2016 regarding 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) (02016R0679 — EN — 04.05.2016 — 000.002) (“GDPR”), and provide you with more detailed information on using cookies or other, similar technologies within the “ATGM Operator” mobile game (“Game”).

PRIVACY POLICY
1. Your personal data administrator is Bartosz Błachucki FOXBYTES IT based in Łódź (Marynarzy Polskich 33/14, 92-732 Łódź), REGON: 520080597, NIP: 7282855525. (“Administrator”). Administrator can be reached under the following e-mail address: contact@atgmoperator.com.
2. Your personal data (e.g. IP address, game activity information, user’s device details, user’s approximate location, user’s email address) will be processed on the basis of:
  1. article 6 (1b) of GDPR (agreement) in order to establish and execute an agreement between you and the Administrator;
  2. article 6 (1c) of GDPR (legal obligation) in order to execute legal obligation bestowed on the Administrator, notably the tax and fiscal obligation;
  3. aarticle 6 (1f) of GDPR (legally justified operation) in connection with the following, legally justified operations carried out by the Administrator or a third party with a view to (i) carry out marketing, analytical, statistical activity by the Administrator (e.g. presenting you with advertisements and business offers tailored to your interests); (ii) providing the highest quality and security of services; and (iii) possible vindication of claims and defense of rights connected with the activity ran by the Administrator.
3. Providing personal data is voluntary, but necessary for the completion of goals listed in point 1.2 above. Notably, providing this data is necessary for you to be able to use the Game (via establishing an agreement with the Administrator).
4. You do not fall subject to decisions made solely on the automatic data processing, including profiling, which cause legal effects toward your person or affect you in any other, meaningful way.
5. Your personal data may be transferred to subjects that cooperate with the Administrator, such as internet marketing platform providers or providers of IT, legal, financial or marketing solutions. Additional information on our partners may be acquired in point 2.4 below.
6. In principle, your personal data is processed only within the European Economic Area (“EEA”). Nevertheless, due to the Administrator’s cooperation with third parties in terms of the Game, your data may be transferred to countries outside of EEA, where subjects cooperating with the Administrator may keep their data-handling infrastructure. If such a data transfer were to happen, it will go on only to the extent that is necessary for these subjects to provide services to the Administrator.
7. In case of passing personal data to subjects based outside of EEA, the Administrator assures that the legal obligation mentioned in Article 5 of the GDPR is fulfilled. This covers the use of appropriate security measures in the shape of contractual clauses accepted by the power of the European Commission. You are eligible to receive a copy of security measures used to protect personal data that is passed outside of EEA by contacting the Administrator under the following e-mail address: contact@atgmoperator.com.
8. Your personal data is processed (i) on behalf of an agreement between you and the Administrator – over the duration of this agreement, (ii) on behalf of marketing, statistical and analytical activity – over the duration of legally justified business need on the Administrator’s or a third party’s side, or unless you file an objection to such processing. Moreover, your personal data may also be processed over the time necessary to (iii) fulfill the duties imposed on the Administrator by law, or (iv) to pursue or defend against any possible legal claims. Depending on the extent of personal data and the aim with which they are processed, your personal data may be stored over various time periods. In each case the decisive factor is the longest possible storing limit.
9. You have the right to demand: (i) access to your personal data, together with a right to receive a copy of this data, (ii) rectify your personal data, (iii) delete your personal data, (iv) limit the processing of your personal data, (v) transfer your personal data (under the condition that processing such personal data happens on the basis of a legal agreement made with your consent), (vi) to oppose the processing of your personal data.
10. You have the right to bring a complaint to the proper supervisory body. In the Republic of Poland, such a supervisory body is the President of Personal Data Protection Office (Stawki 2, 00-193 Warsaw).
11. When you choose to log into the Game via accounts provided by the providers of external platforms, we may come into the possession of your personal data collected by Facebook, Google or Apple. If this is the case we will download such personal data connected with using the Game – in particular your name, surname, nickname and e-mail address.
12. In case when the Administrator introduces such a functionality within the Game, the Game may be used to send you push notifications with information about the Game. You can opt out of these notifications in any given moment by turning them off in your devices’ settings.
COOKIES AND SIMILAR TECHNOLOGIES
1. Cookie files (small text files) or similar technologies (“Technologies”) may be utilized within the game and stored on your device in relation to your usage of the Game.
2. Technologies may provide us with a possibility to maintain the proper operationality of the Game and the realization of its basic functions. They may be also used by us or our partners in order to analyze how the Game is played, tailor its functionalities to your needs and present targeted marketing content.
3. Technologies may collect all kinds of information which, by nature, do not fall under the personal data category (i.e. they do not allow for your identification). Some information, depending on their content and mode of usage, may be attributed to a certain person and therefore be understood as personal data. While handling this kind of information we use the appropriate provisions of the Policy regarding personal data. To the extent to which gathered information will contain your personal data, the basis for processing such data is a legally justified business operation conducted by the Administrator or a third party (Article 6 (1f) of the GDPR).
4. Aside from indispensable Technologies (needed for the proper functioning of the Game and its secure usage – and for which we do not need your permission), other technologies – also coming from the third parties (i.e. Partners) may be used within the Game. These technologies may be used to meet marketing, statistical or analytical goals and, in some cases, Partners may act as administrators of your personal data.
5. In many cases your device may allow for the storing and using these Technologies by default. Configuring your device’s settings may be a proper mode of deleting / blocking these Technologies. Putting limitations on the usage of these Technologies may influence the availability of some of the Game’s functionalities, render using the Game impossible or near impossible, and even cause the loss of your progress within the Game.
FINAL PROVISIONS
1. The Administrator stipulates the right to make future amendments in the Policy. This may happen due to the following, essential reasons:
  1. changes within binding laws, especially those that affect the rights and duties of both the Administrator and the Game user and rule over the protection of personal data, telecommunication law, and providing digital services;
  2. the development of functionalities or digital services resulting from the web technology advancements, together with the usage and implementation of new technological solutions affecting the scope of the Policy.
2. Each time, the Administrator will publish information about any changes in the Policy within the Game. Each change in the Policy will be published with a new date when it was issued.
3. The present version of the Policy is in effect from the May 2, 2022.