Website 

When you use our Website we process your personal data (including IP address or other identifiers and information collected through cookies or other similar technologies) for the following purposes:  

• to provide services electronically in terms of providing users with access to content collected on the Website – the legal basis for the processing is the necessity of the processing for the performance of the agreement for the provision of electronic services (Article 6 (1)(b) GDPR); 
• for analytical and statistical purposes – the legal basis for the processing is our legitimate interest (Article 6(1)(f) GDPR), involving analysis of users’ activities, as well as their preferences to improve the functionalities used and services provided. 

Products 

When you use our Products we process your personal data for the following purposes: 

• to offer you support in case something goes wrong i.e., respond to reported problems with our Products, to improve and update our Products, in particular via Steam or Discord – the legal basis for processing is our legitimate interest (Article 6(1)(f) GDPR) involving improving and ensuring the proper operation of our Products; 
• to prepare analyses and statistics – the legal basis for processing is our legitimate interest (Article 6(1)(f) GDPR) involving analysis of your activities to improve, update and make our Products better over time; 

When you use our games we collect data about your playing session, but we compare and analyze it only after proper anonymization (that means that the set of data we use to prepare analyses and statistics does not contain any information that could identify you personally). For this purpose, we use information like your story decisions, combat decisions, deaths, in-game locations you have visited, in-game shopping decisions, and your party and character customization decisions. It does not include hardware or software information, IP address, email address, usernames, or anything else that does not have anything to do with playing the game. 

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Contact 

You can also contact us or we can contact you (for example if you are our contractor) via our e-mail address.  

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When you contact us by e-mail or in case we contact you by e-mail, we process your personal data for the following purposes: 

• to identify you as a sender and to handle your request sent via the electronic contact form – the legal basis for processing is the necessity of processing to perform the service contract (Article 6(1)(b) GDPR) and – in case of data provided optionally – our legitimate interest of being able to provide an answer to a request concerning our activity (Article 6(1)(f) GDPR); 
• to contact you in order to handle your request sent via e-mail or post, to contact you in connection with our contract or other arrangements, to conduct further correspondence with you –  the legal basis for processing is our legitimate interest of being able to provide an answer to a request concerning our activity or other contact request from your side or conclusion or performance of a contract with a person or entity you represent (Article 6(1)(f) GDPR); in case we provide you with our correspondence or answer your correspondence in connection with an agreement to be concluded or that is concluded with you – the legal basis for processing is the necessity of processing for the performance of the agreement or necessity to take steps prior to entering into such an agreement at your request (Article 6(1)(b) GDPR); 
• in case of marketing e-mail correspondence we process you data also to promote our Products or business activity – in such a case the legal basis for processing is our legitimate interest (Article 6(1)(f) GDPR) in connection with your consent to receive such a correspondence (we will send you marketing information by e-mail only after you give your consent for such a mailing). 

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Events ​

When you participate in our Stationary Events and Online Events, we may process your personal data for the following purposes: 

• in case you fill out the questionnaire provided by us about our Products – to create analysis and statistics – the legal basis for the processing is our legitimate interest (Article 6(1)(f) GDPR), involving creating analysis and statistics in order to improve our Products functionality; 
• in case your image is captured in photos of the Stationary Event – to promote our activities in our social media – the legal basis for the processing is our legitimate interest (Article 6(1)(f) GDPR) involving promoting and marketing our activities in connection with your consent to use such image.  

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Newsletter  ​

If you would like to subscribe to our Newsletter, you need to provide us with your e-mail address. Providing your e-mail address is voluntary, but failure to provide it will result in the inability to provide you with our Newsletter. Since our Newsletter may contain and typically contains marketing content, it may be sent to you only after you agree to such a  subscription.  

When you subscribe to our Newsletter we process your personal data (name, e-mail address) for the following purposes: 

• to provide the Newsletter to you, including to promote our Products and business activity – the legal basis for processing is our legitimate interest (Article 6(1)(f) GDPR) in connection with your consent to receive such a Newsletter;  
• to create analysis and statistics  – the legal basis of the processing is our legitimate interest (Article 6(1)(f) GDPR), involving conducting analyses of users’ activity on the Website in order to improve the applied functionalities. 

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Social media 

We may process your personal data when you visit our social media profiles like at:  

• Twitter (https://twitter.com/GGstudiodev )
• Facebook (https://www.facebook.com/hiddenpass)   
• Youtube (https://www.youtube.com/channel/UCXItrYzEwmfoSvjfHPjzSMg)
• Discord (https://discord.gg/GuhRb9N9Dq)

When you enter our social media profiles or use other content provided by us via social media, we may process your data for the following purposes: 

• to maintain our social media profile, to inform you about GG Studio activities and promote various events and our Products. The legal basis for processing of your personal data for this purpose is our legitimate interest (Article 6(1)(f) GDPR) involving promoting our own brand and products.  

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Facebook plug in  

At our Website we use Facebook plug-in. Clicking on it sends you to our Facebook profile. In such a case your data such as information about the web browser or app used, online identifiers including IP addresses and, insofar as provided, FB-related identifiers or device identifiers (such as mobile OS advertising IDs), as well as information on opt-out/limited ad tracking status are transferred to Facebook. In the scope of this data, Facebook (company Meta Platforms Ireland Limited) and GG Studio are joint controllers in accordance with Article 26 GDPR.  

Information how Facebook processes personal data, including the legal basis Facebook relies on and the ways to exercise your rights against Facebook, can be found in Facebook’s Data Policy available at: https://www.facebook.com/about/privacy.  

GG Studio and Facebook have entered into Controller Addendum to determine the respective responsibilities for compliance with the obligations under the GDPR with regard to the joint processing. You may read the provisions of this addendum available at the link https://www.facebook.com/legal/controller_addendum.  

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Kickstarter  

With the help of the Kickstarter platform, we run campaigns where you can support our products’ creation. Kickstarter provides us with some of the data you submit through the Kickstarter platform (your nickname, e-mail address, the amount of your support for our project, the reward you have selected, other information requested to provide you reward and traffic analytics about your activity on our project pages). We are a controller of the personal data that we receive (Kickstarter does not provide us with any of your financial data, so we do not process this kind of data). 

In connection with your participation in the Kickstarter campaign we process your data for the following purposes: 

• to enable you to back our project and to deliver a reward to you as promised – the legal basis for processing is a necessity to perform a project backing agreement (Article 6(1)(b) GDPR); 
• to create analytics and statistics on the activity on our project pages – the legal basis for processing is our legitimate interest (Article 6(1)(f) GDPR) involving analysis of users’ activities, as well as their preferences in order to improve our campaigns.   

More information you can find in Kickstarter Privacy Policy: https://www.kickstarter.com/privacy?ref=global-footer .  

Your data may be transferred to the Backerkit platform. We use the Backerkit platform as a tool to manage our projects on Kickstarter and generate analysis and statistics. Kickstarter on our behalf transmits your data (data we have access to) from the Kickstarter platform to the Backerkit platform. Backerkit adopts appropriate security measures to protect your data. More information you can find in Backerkit privacy policy: https://www.backerkit.com/privacy_policy#:~:text=Privacy%20Policy%20This%20Privacy%20Policy%20governs%20the%20manner,and%20all%20products%20and%20services%20offered%20by%20BackerKit.  

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Other processing purposes 

We may also process your personal data for the following purposes: 

• to comply with legal obligations imposed on GG Studio, such as provision of information and documents required by public administration authorities – the legal basis for processing is necessity to comply with a legal obligation to which the controller is subject (Article 6(1)(c) GDPR); 
• to establish or seek claims or to defense against claims – the legal basis for processing is our legitimate interest (Article 6(1)(f) GDPR) involving protection of our rights. 

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Period of processing your personal data ​

GG Studio will not use or store personal data for longer than is necessary to achieve the above-mentioned purposes and will delete the collected personal data after the expiration of the period necessary to achieve the purposes described herein or to fulfill contractual obligations or to the extent permitted or required under applicable law. The specific retention periods for personal data are indicated with each of the listed processing purposes are as follows: 

• in case we process your data to perform the agreement (e.g. to provide you with Website content, to enable you to use contact form, or to conduct e-mail correspondence connected with the contract you concluded with us) – your data will be processed for the duration of the agreement and after this period for a period no longer than the period of the possible statute of limitations for claims;  
• in case we process your data on the basis of your consent – your data will be processed not longer than necessary to realize purpose for which your consent is granted, and no longer than until the moment you withdraw your consent; 
• in case we process your data to comply with our legal duties – your data will be processed not longer than the term of these legal duties; 
• in case we process your data on the basis of our legitimate interest – your data will be processed until our interest is realized (for example for the duration of correspondence, for the time of subscription of Newsletter – no longer than until you withdraw your consent to receive such a Newsletter), no longer than the statute of limitations for claims, and no longer than until the moment you object to the processing of your data for such purposes. In case we process your data to establish or seek claims or to defend against claims – your data will be processed for the duration of the proceedings and optionally the period of limitation of claims. 

Source of data  ​​

In general, we collect your data directly from you. However, there are situations in which we receive your data directly from a third party. If you are an employee or representative of our contractor, we may receive your identifying information (such as name, surname, email address, position) from him. 

GG Studio does not knowingly solicit personal information from children or send them requests for personal information. Although visitors of all ages may navigate through our Website and use our Products, we do not intentionally collect personal information from persons under the age of sixteen. We require parental consent to process the personal data of a child under 16 years of age.  GG Studio encourage parents to instruct their children to never give out personal information when online. If following a notification by a parent or guardian, or discovery by other means, that a child under sixteen has improperly use our Products by using false information, we will cancel the child’s account and delete the child’s personal information from our records. 

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Your rights  ​​

In connection with the processing of your personal data, you have the right to: 

• object to the processing of your data, if the basis for processing is our legitimate interest in accordance with art. 6 (1) (f) of the GDPR. In this case, we will no longer process this personal data, unless we prove the existence of valid, overriding, legitimate grounds for processing, or grounds for establishing, investigating or defending claims; 
• withdraw consent to the processing of personal data (given by you) at any time. This withdrawal does not affect the compliance of the processing which was carried out on the basis of consent before its withdrawal; 

Remember that you can also at any time withdraw your consent on marketing content. In this case, we will no longer process your personal data for this purpose. 

• access your personal data; 
• require us to correct your data; 
• require us to delete your data to the extent provided for by law; 
• require us to limit the processing of your data to the extent provided for by law; 
• require us to transfer your data, if the processing is carried out by automated means and if the data is processed in connection with a contract.

Recipients of your data  

GG Studio does not and will not sell personal information about our customers. We only disclose your data as authorized in this statement. We may share information with the types of third parties described below and always ensure, when sharing information, such third parties adhere to the same principles. 

In respect of the data processing for the purposes specified in this Policy, the recipients of your personal data may be the following: 

• our authorized personnel, as well as the authorized personnel of our subcontractors; 
• entities services to us, i.e operating our IT systems, website management, hosting, advertising agencies, entities providing consulting, legal, debt collection, accounting and auditing services, in particular: 
• provider of Mailchimp (emailing tool) – The Rocket Science Group LLC – if you subscribe our Newsletter; 
• provider of our email system – Microsoft Ireland Operations Limited – if we correspond by e-mail; 
• provider of the Discord messenger with the help of which we provide support – Discord Netherlands BV. Discord Netherlands BV  
• provider of Steam – with the help of which we provide support –  Valve Corporation 
• viewers of our social media posts about Stationary Events in which your image was published;  
• providers of Kickstarter and Backerkit platform.  

We may also share non-personal information such as aggregated data with our partners or publicly. For example, we may inform a games service about how their users have utilized GG Studio Products on their platform, or we may share the total sales of a GG Studio Product, or share overall game statistics with our audience. 

We reserve the right to disclose selected information concerning you to the competent authorities or to third parties who request such information on an appropriate legal basis and in accordance with applicable law. 

Transfer outside EEA ​​

The level of personal data protection outside the European Economic Area (EEA) differs from that provided by European law. For this reason, we transfers personal data outside the EEA only when necessary and with an adequate level of protection. Transfers outside the EEA occur in particular: 

• in connection with use of the mailing tool – Mailchimp, transfers are made primarily to the United States under standard contractual clauses approved by the European Commission; 
• in connection with our support through Discord and Steam – transfers are made primarily to the United States under standard contractual clauses approved by the European Commission or other appropriate legal safeguards;  
• if our subcontractor is located outside the EEA – transfers are made most often under standard contractual clauses approved by the European Commission or on the basis of a decision of the European Commission finding a sufficient level of protection of personal data in a given country. 

In order to obtain a copy of the European Commission’s decision or standard contractual clause, you can contact us using the data indicated here.  

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Safety of your data  

GG Studio is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. 

GG Studio takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. 

The servers on which your personal information is stored are kept in a controlled environment with limited access. While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is impenetrable. 

Changes to this privacy policy  ​

GG Studio may modify or update this privacy policy when necessary to reflect customer feedback and changes in our Products and Website; so, please review it periodically. When we update this policy, we will revise the “Last Updated” date at the top of the statement.