Glossary - basic concepts.

Personal Data - all information that we process related to you. For example: first name, last name, e-mail address, telephone number, demographic data (including your age), billing data, etc.;

Processing - all activities performed relating to your Personal Data. For example: gathering, retaining, updating, sending messages to you, deleting data;

Services - services offered by Techland, in particular over the Websites, which the User is entitled to use, including, for example Product-related services, the setting–up of accounts by the User on the Websites or in our Products and using said accounts, placing orders for Products and Services, making purchases, testing games, using the forum for players, using technical support for Users, participating in competitions organized by Techland, filling in questionnaires concerning the Websites, and making other functionalities of the Websites available;

Products - products, in particular games developed by Techland; this Privacy Policy also applies to Personal Data processed in connection with the use of the Products, including in particular games developed by Techland;

Techland - the data controller of the Personal Data, i.e. Techland S.A. with its registered office in Wrocław, address: ul. Jana Szczyrki 11, 54-426 Wrocław, Poland;

User - a natural person using one of our Websites, Products or Services;

Websites - websites owned by Techland to which this Privacy Policy applies and their subpages, in particular, available at the following addresses: techland.net, dyinglightgame.com, techlandgg.com; the rules of using the Websites can be found in the relevant regulations available at the following link: https://techland.net/docs/terms-of-service (“Regulations”).

In the scope of all of the above definition references to the plural also include references to the singular and vice versa.

You contact us or visit our Websites: what Personal Data do we gather, what is the purpose and legal basis for its processing?

What are the „cookie” files and other similar technologies? How do we use them and for what purpose?

We may use the cookie files for our Services or Products, including both within the Techland Websites, as well as within the websites of our business partners. We may also collect Personal Data by using pixels (web beacons), server logs and other similar technologies.

Cookies are small data files that are issued to your device when you visit a particular Website, which stores information about your use of it and sometimes tracks information about you.. Cookie files allow us to recognize your device and collect data such as your internet service provider’s domain name, type of browser, type of operating system, IP address, websites visited by you, as well as operational data, or device location information. Information collected by cookie files is not always Personal Data in the meaning of the GDPR. However, if you have previously provided your Personal Data, cookie files can be directly linked to you, for example by associating the identification numbers in the cookies with other information.

Pixels (also known as web beacons) - Websites and other content (such as videos, emails, and advertisements) may contain pieces of code that send information about your use of such to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a Website, video, email, or advertisement that contains a pixel, the pixel may permit us or another entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels that allow us track our conversions, bring you advertising both on and off the Services, and provide you with additional functionality.

In principle, the legal basis for processing your Personal Data collected through cookie files and similar technologies, is your consent (Article 6(1) letter a of the GDPR), except when their use is necessary for the proper functioning of the Websites (provision of the services by electronic means), when we rely on Article 173 par. 3 point 2 of Telecommunication Law of 16 July 2004 and accordingly our legitimate interest (Article 6(1) letter f of the GDPR).

We process the abovementioned Personal Data to improve the quality of our Services, Techland’s operation and Products, and also to adjust the content available via Websites or Products to your interests (including as part of the automated processing of Personal Data, to present content, including general advertisements, offers, or promotions, regarding the Services or Products in a manner adapted to the User’s interests without, however, significantly affecting their decisions – profiling). We may read your preferences, for example by analysing how often you visit our Websites, what Services or Products you use, including what games, expansions, downloadable content you choose, etc. This allows a better understanding of your expectations and adaptation to your needs. Thanks to the use of advanced technologies, the above activities will often be performed by the system in an automated manner, thanks to which the content showed to you will be the most up–to–date (we process your Personal Data based on our legitimate interest – promotional/analytical/performance purposes – art 6(1) letter f of the GDPR).

In the event of the legal basis for processing of your Personal Data is your consent, we remind you that you can withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. Whereas, if your Personal Data is processed on the basis of our legitimate interest, you have the right to object to such processing. You can find a description of your rights in Section VI. below.

Usually, web browsers or other software installed on your device, allow, by default, the use of cookie files on such a device, and thus to collect the abovementioned information. You can change the way of using cookies files, including completely blocking or deleting them, via your web browser – please refer to the user manual for more information on how to do it. Remember that disabling or blocking some of the cookies may prevent or significantly impede the proper functioning of our Websites, for example by slowing it down. More information about the settings for cookies can be found in the browser information and/or on our Websites. You can also visit https://www.allaboutcookies.org for some practical advice.

With regard to the domain they come from, we divide cookies into:

1. first-party cookies - set by the web servers of our Websites;
2. third-party cookies - set by web servers of pages other than our Websites.

With regard to the life cycle, we divide cookies into:

1. session - a session cookie contains information that is stored in a temporary memory location and then subsequently deleted after the session is completed or the web browser is closed;
2. persistent - also called a permanent cookie, or a stored cookie; a cookie that is stored on a User’s hard drive until it expires (persistent cookies are set with expiration dates) or until the User deletes the cookie; persistent cookies are used to collect identifying information about the User, such as Website surfing behaviour or User preferences for a specific Website.

We may use the following types of cookie files:

1. necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies;
2. preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in;
3. statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously;
4. marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers;
5. unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

As required under GDPR, you can manage your consents to different types of cookie files. We provide you with a Cookiebot tool, which interface allows you to decide which types of cookie files you accept, and you can change these settings whenever you wish depending on your preference. Click here to see and manage your cookies preferences under GDPR.

Depending on the purposes and legal grounds for processing cookies, they may be stored and processed for the time indicated in Section IV of this Policy.

How long do we process your Personal Data?

If your Personal Data are collected only in connection with our current communication (section II of the Privacy Policy above), we may process them, depending on the category of particular information, for a period of several days (some cookies) or for a maximum of two years (more detailed inquiries and conversations that may be relevant to our contact in the future).

Where Techland processes data for the direct marketing of its Products and the Services, the data will cease to be processed for this purpose as soon as the User objects to the processing of their data. The User may also withdraw their consent to the sending of marketing information by electronic means at any time, and the information will no longer be sent after the withdrawal of consent.

Personal Data of the User will be stored for as long as it is necessary to use an individual account for the purpose of a specific Website to provide Services (the duration of the agreement) or use of the Products and usually for approximately next seven years after its termination, which results in particular from tax regulations.

If your Personal Data is being processed because you use our forum, test games, participate in a competition, or we provide you with technical support and/or prepare an answer to an inquiry or complaint, your Personal Data will be stored and processed for as long as it is necessary to use it to perform any of the above functionalities and no longer than for the period specified in the law or for the period of the statute of limitations of claims.

Personal Data processed on the basis of your consent may be stored until its withdrawal, until the achievement of the objectives for which such consent was expressed or, if the processing is related to cookie files (tracking) or other similar technology – until the deletion of such files via the browser/device settings (where it is technically possible).

Personal Data processed on the basis of our legitimate interest may be stored until you object to such processing, except when despite your objection we conclude that there are important legitimate grounds for processing that override your interests, rights, and freedoms, or the basis for establishing, pursuing, or defending claims.

The retention periods described above may be extended as appropriate in the event of potential claims (during the prescription period defined by law, in particular the Civil Code), any claims and court proceedings – for the duration of such proceedings and their settlement – and if the law obligates us in certain cases to process such data for a longer period of time. In any case, a longer period of storage of Personal Data is decisive.

Who has access to your Personal Data?

The access to your Personal Data is only granted to:

1. authorized employees and collaborators of Techland, or its affiliates, who have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
2. entities that support us in providing the Services or giving you access to our Products, based on appropriate contracts, for example other entities from the Techland group, entities providing IT services or tools allowing for our communication, legal and consulting services providers, auditors/reviewers, entities handling internet payments, marketing and advertising agencies (including marketing and advertising services provided by Google, Facebook, etc.).

All of these entities have access only to information necessary for their performance.

We may also be required – if there is a legal basis to do so – to provide certain information to public authorities, for purposes related to proceedings they are conducting.

Since some of our affiliates are registered outside the European Economic Area (EEA), and so could be some of the entities providing us with solutions connected with Techland, Websites and providing Services and our Products, and your Personal Data may be transferred there, we provide the appropriate legal mechanisms for the security of your Personal Data, including standard data protection clauses adopted under the decision of the European Commission and concluding data processing agreements that meet the requirements of the GDPR.

You have the right to obtain a copy of the appropriate legal mechanisms for the transfer of your Personal Data, to countries outside the EEA, by contacting us.

In the event that Users are redirected to websites of entities other than Techland (e.g. in order to purchase a selected product), Techland does not provide such entities with any Personal Data of the Users. To the extent that the functions or related websites visited by the User are not Techland Websites, Techland is not responsible for the processing of personal data related to the use of these websites. In order to understand the principles of data processing on these websites, the User should refer to the privacy policies made available on these websites.

Techland declares that the data stored and processed by it are secured in a necessary manner in accordance with applicable legal regulations. Techland maintains appropriate technical and organisational security measures. Access to the User's Personal Data is granted only to persons who need the data in order to provide the Services and Products and operate the Websites.

Your rights as related to processing of your Personal Data

For the effective exercise of your rights, we recommend sending any requests to the gdpr@techland.pl e-mail address from the contact address you have provided, along with the title “GDPR Request.” In the e-mail, please specify which right(s) you wish to invoke. Remember that this is only a suggestion on how you can exercise your rights. Complying with the above mentioned rules is not mandatory and any failure in this matter will not lead to the loss of the rights described below.

You have the following rights:

• Access to your Personal Data - you may ask us to provide detailed information regarding, for example:
  • whether we are processing your Personal Data;
  • for what purpose;
  • what categories of Personal Data we are processing;
  • who is the recipient of your Personal Data;
  • what is the planned duration of processing (if possible), and if we are not able to answer, the criteria for determining that duration;
  • if the Personal Data has not been collected from you – all available information as to their source.

You can also receive access to all of your Personal Data that we are processing (data copy).

• Data rectification - if information about you is or has become inaccurate, you have the right to demand that data to be rectified.
• Consent withdrawal - you may withdraw your consent to the processing of your Personal Data at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Erasure of data - in certain situations, the GDPR gives you the “right to be forgotten.” You can invoke this right if we are still processing your Personal Data, particularly in the following cases:
  • your Personal Data is no longer vital for the purposes for which it was collected or otherwise processed;
  • you revoked consent to the processing of Personal Data and there is no other legal basis for continuing to process it;
  • you object to the processing of your Personal Data when there is no overriding justified legal basis for processing;
  • you object to the processing of your Personal Data for marketing purposes;
  • your Personal Data is processed in a manner that violates the law;
  • the law requires that we erase your Personal Data.
• Restriction of processing - in principle, you can demand that we limit our activities only to storing information about you when:
  • you question the correctness of the Personal Data we are processing – for a period of time that allows us to determine the correctness of that data;
  • the processing of your Personal Data violates the law, but you prefer that processing be restricted rather than the data be erased;
  • Techland no longer needs your Personal Data for the purposes of processing, but you need it for establishing, pursuing, or defending legal claims;
  • you have objected to the processing of your Personal Data – only until such time as it is determined whether your interests take precedence over our legally justified interests.
• Data portability - you have the right to receive your Personal Data in a commonly-used format that can be read by a computer and also to have your Personal Data sent to another data controller, if:
  • processing is done on the basis of your consent or a contract; and
  • processing is done in an automated manner.
• Objection - you have the right to object to some operations we perform on your Personal Data for special reasons related to your personal situation, particularly in the following cases:
  • when our processing is based on a legitimate interest;
  • when we process your Personal Data for purposes related to scientific or historical studies, or for statistical purposes.

Remember, however, that when in spite of your objection, we conclude that there are important legitimate grounds for processing that override your interests, rights, and freedoms, or the basis for establishing, pursuing, or defending claims, we will continue to process your Personal Data encompassed by the objection to the extent necessary. If you disagree with such an assessment of the situation, you can exercise your right to file a complaint with the relevant public authority (more information below).

Where Personal Data are processed for direct marketing purposes, you have the right to object to the processing of your Personal Data for such marketing at any time. Where you object to the processing for direct marketing purposes, the Personal Data shall no longer be processed for such purposes.

• Complaints to the relevant public authority - in connection with our actions as the data controller regarding your Personal Data, you have the right to file a complaint to the relevant public authority which, in Poland, is the President of the Personal Data Protection Office. A detailed description of the complaint procedure is available at: https://uodo.gov.pl/en/559/941. You can find a list of local authorities responsible for data protection across the EU and their contact details at: https://edpb.europa.eu/about-edpb/board/members_en.

Of course, if you have any comments about how we do things, we encourage you to contact our Data Protection Officer at gdpr@techland.pl.

California Residents – additional information

Notwithstanding the preceding provisions of this Privacy Policy, the California Consumer Privacy Act or “CCPA” provides consumers residing in California certain rights with respect to their personal information. If you are a California resident, you have:

• Right to Know.You have a have a right to submit a verifiable request, up to two times a year, for the following information: (1) the categories of personal information we have collected from or about you; (2) the categories of sources from which we have collected that personal information, and the business or commercial purpose for the collection; (3) the categories of third parties with whom we have shared your personal information or sold your information, and the business or commercial purpose for said sharing or selling (if any); and (4) specific pieces of your personal information, subject to appropriate exceptions. Please note, your request may only go back 12 months from the date of your request.
• Right to Delete.You have a right to request that we delete your personal information, subject to certain exceptions such as if the information is necessary to complete the transaction for which the information was collected, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, identify and repair errors and for various other reasons available under California law.
• Right to Opt-Out.To exercise this right send an e-mail to gdpr@techland.pl or manage your cookie preferences here.
• Right to Non-Discrimination.We will not discriminate against you in any way for exercising any of the above rights.

You or your authorized agent may make the above-mentioned requests by contacting us at gdpr@techland.pl. Note that we may ask you for additional information to help us verify who you are before completing your request. If we receive your request from an authorized agent, we may ask for evidence that you gave that person authority to submit requests to exercise rights on your behalf. We will not discriminate against you if you exercise your rights under the CCPA.

Notice of Collection

To learn more about the list categories of personal information we have collected about California residents in the 12 months preceding the date this notice was last updated, including information about how we collect such information, the purpose for collection, and whether we share the information please see:

• Section II. You Contact Us Or Visit Our Websites: What Personal Data Do We Gather, What Is The Purpose And Legal Basis For Its Processing?
• Section III. What Are The “Cookie” Files And Other Similar Technologies? How Do We Use Them And For What Purpose?
• Section V. Who Has Access To Your Personal Data?

Notice of Sale

Techland does not sell the personal information we collect. Our data sharing practices are set forth above. We do not believe that these activities are sales of your personal information. We do not sell information that directly identifies you such as your name, telephone number, mailing address or email address. We also do not provide customer personal information to third parties for monetary or other valuable consideration.

Notice of Disclosure for a Business Purpose

To learn more about the list of categories of personal information we have disclosed for a business purpose about California residents in the 12 months preceding the date this notice was last updated, please see:

• Section II. You Contact Us Or Visit Our Websites: What Personal Data Do We Gather, What Is The Purpose And Legal Basis For Its Processing?
• Section III. What Are The “Cookie” Files And Other Similar Technologies? How Do We Use Them And For What Purpose?
• Section V. Who Has Access To Your Personal Data?

California Minors

California Business and Professions Code Section 22581 permits you, if you are a California resident under the age of 18, to view, correct, or delete information provided by you or publicly posted by you, by sending us an email asking us to delete certain posted content at gdpr@techland.pl.

We will be happy to review, update or remove information and/or content as appropriate. Residual copies of information and/or content that have been removed may remain in our backup systems. We may still retain your information to resolve disputes, enforce our user agreement, or comply with legal requirements; in this case, your Personal Data will be blocked from use for any other purpose.

Additional Disclosures for Nevada Residents

Nevada law requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties.

We do not believe that our sharing of your Personal Data would qualify as a sale under Nevada law. Nonetheless If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at gdpr@techland.pl.

Last Privacy Policy update: 23.09.2022