Introduction

The protection of personal data is a necessary aspect of the activities of GAMEDEVOCEAN sp. z o.o. with its registered seat in Kobyłka (“GAMEDEVOCEAN“). At GAMEDEVOCEAN, we feel responsible for the security of personal data processed in connection with our current activities, based on 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 (OJ EU.L No. 119, p. 1, as amended; “GDPR“). In this document, we provide information on the legal basis for the processing of personal data by GAMEDEVOCEAN, on the methods of their collection and use, as well as on the rights of entities whose data GAMEDEVOCEAN processes.

This Privacy Policy applies to all cases in which GAMEDEVOCEAN is the controller of personal data and processes personal data. This applies both to cases in which GAMEDEVOCEAN processes personal data obtained directly from the data subject and to cases in which GAMEDEVOCEAN has obtained personal data from other sources. GAMEDEVOCEAN fulfils its information obligations in both of the above cases, specified respectively in Article 13 and Article 14 of the GDPR in accordance with these provisions. Below we indicate the full details of GAMEDEVOCEAN as the controller of personal data: GAMEDEVOCEAN sp. z o.o. based in Kobyłka (05-230), at Akacjowa 8 (Str.), NIP No.: 1251779814, REGON No.: 540558847. The person responsible for personal data protection at GAMEDEVOCEAN is Ms. Angelina Stokłosa (angelina.stoklosa@sklegal.pl).

GAMEDEVOCEAN wants to maintain transparency regarding the methods and legal bases of personal data processing as well as the purposes for which GAMEDEVOCEAN processes personal data. GAMEDEVOCEAN ensures that the necessary information in this regard is always indicated to each person whose personal data it processes as a data controller. Below is a summary of personal data processing operations.

At the same time, we point out that whenever GAMEDEVOCEAN processes personal data based on the legitimate interest of the data controller, it tries to analyze and balance its own interest and the potential impact on the data subject (positive or negative) and the rights of that person resulting from the relevant provisions on the protection of personal data. GAMEDEVOCEAN does not process personal data based on its legitimate interest if it comes to the conclusion that the impact on the data subject would outweigh the interests of GAMEDEVOCEAN (in which case GAMEDEVOCEAN may process personal data if, for example, it has the appropriate consent or is required or permitted by the relevant provisions of law).

Processing of personal data of persons visiting websites operated by GAMEDEVOCEAN or using services provided electronically

Individuals visiting the GAMEDEVOCEAN websites or using the services provided by GAMEDEVOCEAN electronically (hereinafter collectively referred to as the “Services“, and in the singular as the “Service“) have control over the personal data they provide to GAMEDEVOCEAN. The Services limit the collection and use of information about their users to the necessary minimum required to provide them with services at the desired level, in accordance with Art. 18 of the Act of 18 July 2002 on the provision of services by electronic means (Journal of Laws of 2024, item 1513, as amended).

To a limited extent, GAMEDEVOCEAN may collect personal data automatically through cookies on websites. Cookies are small text files saved on the user’s computer or other mobile device when using websites. These files are used, among other things, to use various functions provided on a given website or to confirm that a given user has seen specific content from a given website. Among the cookies, we can distinguish those that are necessary for the operation of services providing services electronically. Cookies belonging to this category are used to ensure:

• maintaining the user session; 
• saving the user session state; 
• enabling authorization using the login service; 
• saving information allowing anonymous user login; 
• monitoring service availability.

The next category of cookies are files that, although not essential to using the Services, make it easier to use them. They are used to enable:

• remembering the user’s choice to stop displaying a selected message or display it a specified number of times;
• restoring the user’s session;
• checking whether the cookie saving is functioning correctly;
• enabling automatic logging into the Service (“remember me” option);
• matching the content of the Service to user preferences;
• setting the preferred language, font size and other such features that make it easier to work with the application.

GAMEDEVOCEAN uses only necessary cookies (so-called session cookies).

GAMEDEVOCEAN also uses the services of third parties, the list of which may change, and which use cookies for the following purposes:

• monitoring traffic on the GAMEDEVOCEAN websites;
• collecting anonymous, aggregated statistics that allow GAMEDEVOCEAN to understand how users use the GAMEDEVOCEAN website and that enable continuous improvement of the GAMEDEVOCEAN Services;
• determining the number of anonymous users of the GAMEDEVOCEAN websites – needed to analyze the use of the Services;
• controlling how often selected content is shown to users;
• controlling how often users select a given service;
• using a communication tool;
• integration with a social networking site.

As of the date of preparation of this document, these entities include:

LinkedIn (more information at: linkedin.com),

Instagram (more information at: instagram.com),

Facebook (more information at: https://pl-pl.facebook.com/). 

The user can manage cookies used by GAMEDEVOCEAN or any other external suppliers by changing the settings of their web browser.

GAMEDEVOCEAN also reserves that after rejecting cookies, some functions offered by the Services may not function properly, and in some cases this may even result in complete disabling of the use of the selected product.

GAMEDEVOCEAN collects information on the use of the Services by their users and their IP addresses based on the analysis of access logs. We use this information to diagnose problems related to the operation of the server, to analyze possible security breaches and to manage the website. The IP address may also be used by GAMEDEVOCEAN for statistical purposes, i.e. to collect and analyze demographic data of people visiting the website (e.g. information about the region from which the connection was made). Based on the information obtained in the above manner, in special cases, collective, general statistical summaries are prepared, disclosed to third parties cooperating with GAMEDEVOCEAN. They usually include information on the viewing of the Service. However, these summaries do not contain any data allowing for the identification (definition of the identity) of a given user of the Service.

GAMEDEVOCEAN may be required to disclose information regarding the IP number of a given user of the Service at the request of authorized state authorities in connection with proceedings conducted by them, on the basis of the relevant provisions of generally applicable law.

As a rule, only when it is actually necessary to provide a given service in certain cases, e.g. when subscribing to free newsletters, surveys or in order forms, GAMEDEVOCEAN collects more detailed information about users, such as e-mail addresses or other personal data necessary for the proper provision of services by GAMEDEVOCEAN.

The information that GAMEDEVOCEAN collects in connection with the use of the Services may be processed in an automated manner, but this will not produce any legal effects for a natural person or significantly affect their situation in a similar manner.

Legal basis for processing

In the case of processing personal data in connection with the use of the GAMEDEVOCEAN Services by users, we may have different legal bases for processing, depending on the category of personal data that we process and the purpose of processing. For example:

• we process personal data of persons visiting the GAMEDEVOCEAN websites based on the legitimate interest of the data controller, e.g. by tailoring the displayed advertisements or based on consent in the event that we have requested such consent from the data subject;
• when the relevant provisions of generally applicable law require the processing of certain personal data for tax or accounting purposes.

Processing of personal data of persons contacting GAMEDEVOCEAN in order to obtain information about the offer or to share comments regarding GAMEDEVOCEAN services, as well as those contacting in order to conclude a contract with GAMEDEVOCEAN

In addition to the above data from individuals who contact GAMEDEVOCEAN to obtain information about the offer or share comments regarding GAMEDEVOCEAN services, as well as those who contact GAMEDEVOCEAN in order to conclude an agreement with GAMEDEVOCEAN, we collect the following personal data: name and surname, e-mail address and telephone number.

We ask that you do not provide any special categories of personal data (such as information about race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information concerning physical or mental health, genetic data, biometric data, information about sexual life or sexual orientation or criminal history) through the Websites. If you provide such information for any reason, GAMEDEVOCEAN will consider this to be your express consent to our collection and use of such information in the manner set out herein or set out at the point where such information is disclosed.

GAMEDEVOCEAN collects the above data based on the consent expressed by the user directing the request to GAMEDEVOCEAN or in order to perform the contract (fulfill the order) submitted by the given person. We can also process the provided data based on the so-called justified purpose of the data controller.

Processing of personal data of GAMEDEVOCEAN customers and potential customers

GAMEDEVOCEAN processes personal data of its customers and potential customers. This data may also include personal data of persons related to GAMEDEVOCEAN customers who are not natural persons (e.g. contact persons). Personal data of this type are processed in IT systems used by GAMEDEVOCEAN (e.g. CRM system). Personal data processed for these purposes include, among others: first and last name, employer’s name, position of the contact person, telephone number, e-mail address or other business/company contact details. Furthermore, in the case of customers who have concluded agreements with GAMEDEVOCEAN, we may also process payment data, including bank account numbers. Personal data of business contacts may be disclosed to permanent collaborators of GAMEDEVOCEAN and used by them for the purpose of conducting GAMEDEVOCEAN’s business activities.

Automatic processing of personal data

The information we collect in connection with the use of our online services may be processed in an automated manner (including in the form of profiling), however, this will not produce any legal effects for an individual or significantly affect their situation in a similar way. We attach particular importance to the issue of profiling and indicate that: for the purposes of profiling, we do not process any sensitive data, for the purposes of profiling, we process data that was previously subject to pseudonymisation or such data that was aggregated by us, if we cannot achieve the purpose otherwise than by profiling non-pseudonymised or non-aggregated personal data, we use typical data for this purpose: e-mail and IP address or cookies, we profile in order to analyse or forecast the personal preferences and interests of people using our Services or services and to match the content found in our Services or products to these preferences, we profile for marketing purposes, i.e. to match the marketing offer to the above preferences.

The processing of personal data of natural persons who are our customers is based on:

• legitimate interest of GAMEDEVOCEAN as the data controller (e.g. in the scope of creating a database, analytical and profiling activities, including activities concerning the analysis of the use of products, securing documentation for the purpose of defending against potential claims or for the purpose of pursuing claims);
• consent (including in particular consent to e-mail marketing);
• performance of the concluded contract;
• obligations resulting from the provisions of generally applicable law (e.g. tax law or accounting regulations).

The processing of personal data of natural persons who are potential customers is based on:

• legitimate interest of GAMEDEVOCEAN as data controller (e.g. in the creation of a database);
• consent (including in particular consent to e-mail marketing).

How long does GAMEDEVOCEAN process personal data?

The period for which we may process personal data depends on the legal basis that constitutes the legal premise for the processing of personal data by GAMEDEVOCEAN. We are not allowed to process personal data for a period longer than that resulting from the above legal basis. Accordingly, we inform you that:

• in the event that GAMEDEVOCEAN processes personal data on the basis of consent, the processing period lasts until the user withdraws this consent;
• in the event that GAMEDEVOCEAN processes personal data on the basis of the legitimate interest of the data controller, the processing period lasts until the aforementioned interest ceases (e.g. the limitation period for civil claims) or until the data subject objects to further such processing – in situations where such an objection is available under generally applicable law;
• in the event that GAMEDEVOCEAN processes personal data because it is necessary due to applicable legal provisions, the periods of data processing for this purpose are specified by these provisions;
• in the absence of specific legal provisions or contractual regulations, the basic period for storing data in the case of records and other evidentiary documentation prepared during the performance of the contract is no longer than 10 years.

When and how we share personal information with third parties

We only transfer personal data to others when we are permitted to do so by applicable law. In such a case, in an appropriate agreement concluded with a third party, we provide for security provisions and mechanisms to protect the data and maintain our standards in the field of data protection, confidentiality and security. Such agreements are called personal data processing entrustment agreements, and GAMEDEVOCEAN has control over how and to what extent the entity to which GAMEDEVOCEAN has entrusted the processing of certain categories of personal data processes such data. In connection with this, we indicate that the recipients of personal data that GAMEDEVOCEAN processes as a personal data controller may be:

• the above entities processing personal data under personal data processing agreements (so-called processors);
• entities providing hosting services for GAMEDEVOCEAN;
• entities implementing marketing or sales campaigns for GAMEDEVOCEAN;
• other subcontractors of GAMEDEVOCEAN, providing services in the field of software delivery, software or hardware servicing services used by GAMEDEVOCEAN, as well as suppliers of goods whose assistance we use;
• entities providing services in the field of survey research, including NPS (customer satisfaction) research;
• debt collection companies (whereby we only transfer personal data to the extent that it is actually necessary to achieve a given purpose);
• auditors and certified public accountants, legal advisors, tax advisors;
• authorities supervising compliance with legal provisions, regulatory authorities and other public administration bodies (whereas in the latter two cases we transfer data only when and to the extent that it is actually necessary and required under the mandatory provisions of law and in a manner consistent with these provisions).

In the case of personal data subject to EU law, we indicate that: cross-border transfers may concern countries outside the European Economic Area (“EEA“) and countries where there is no legislation providing for special protection of personal data. We take steps to ensure adequate protection of all personal data and the lawfulness of transfers of personal data outside the EEA. In the case of transfers of personal data outside the EEA to a country that, according to the European Commission, does not provide an adequate level of protection for personal data, the transfer will only take place on the basis of an agreement that takes into account EU requirements for the transfer of personal data outside the EEA.

What rights do data subjects have and how can they be exercised?

Individuals have rights specified in the relevant provisions regarding their personal data, and GAMEDEVOCEAN as the data controller is responsible for the implementation of these rights in accordance with the relevant provisions of generally applicable law. In the event of any questions or requests regarding the scope and implementation of rights, as well as to contact us to exercise a specific right in the field of personal data protection, please contact us at the following e-mail address: angelina.stoklosa@sklegal.pl. GAMEDEVOCEAN reserves the right to implement the following rights after positive verification of the identity of the person applying for the performance of a given action.

Access to personal data

Individuals have the right to access the data that GAMEDEVOCEAN stores as a data controller. This right can be exercised by sending an email to the following address: angelina.stoklosa@sklegal.pl.

Change of personal data

Changes, including updates of personal data processed by GAMEDEVOCEAN, can be made by sending an e-mail to the following address: angelina.stoklosa@sklegal.pl or by contacting GAMEDEVOCEAN via the relevant website where registration was made, or by traditional mail.

Withdrawal of consent

In the case of processing personal data based on consent, individuals have the right to withdraw this consent at any time. GAMEDEVOCEAN informs about this almost at any time of collecting consents and enables withdrawal of consent in the same way as it was granted. If GAMEDEVOCEAN has not provided another address or contact number for the purpose of withdrawing consent, please send an e-mail to angelina.stoklosa@sklegal.pl.

The right to restrict the processing of personal data or to object to the processing of personal data

Individuals have the right to restrict the processing of or object to the processing of their personal data at any time, due to their particular situation, unless processing is required by generally applicable law.

A natural person may object to the processing of his or her personal data when:

• personal data is processed on the basis of a legitimate interest or for statistical purposes, and the objection is justified by the special situation in which it has found itself;
• personal data is processed for the purposes of direct marketing, including profiling for this purpose.

In turn, with regard to the request to limit the processing of data, GAMEDEVOCEAN indicates that it is available, among other things, when a given person notices that their data is incorrect. In such a case, it is possible to request the restriction of the processing of personal data for a period allowing GAMEDEVOCEAN to check the accuracy of this data.

Other rights: the right to request the deletion of data and the right to transfer data

In case you wish to exercise any of these rights, please send an e-mail to the following address: angelina.stoklosa@sklegal.pl.

The right to delete data may be exercised, among other things, when the data of an individual is no longer necessary for the purposes for which it was collected by GAMEDEVOCEAN or when an individual withdraws their consent to the processing of data by GAMEDEVOCEAN, as well as in the event that an individual objects to the processing of their data or their data is processed unlawfully. Data should also be deleted in order to fulfill an obligation resulting from the relevant legal provision.

The right to data portability exists when the processing of a person’s data is based on the consent of the natural person or on a contract concluded with him or her and when such processing is carried out automatically.

Any other questions, concerns or complaints

If you have any questions, concerns about the content of this Privacy Policy or the way in which GAMEDEVOCEAN processes personal data, as well as in the event of complaints regarding these matters (regardless of the fact that we express our deep hope that there will be no need to file such complaints), please send an e-mail message with detailed information about the complaint to angelina.stoklosa@skleagl.pl. All complaints received will be considered by GAMEDEVOCEAN, and the person submitting the question, concern or complaint will receive a response from GAMEDEVOCEAN.

Persons whose personal data are processed by GAMEDEVOCEAN also have the right to lodge a complaint with the supervisory authority, which is the President of the Office for Personal Data Protection (address: Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw; https://uodo.gov.pl/pl/p/kontakt).

We enable direct contact at the headquarters of GAMEDEVOCEAN and by letter (e-mail or traditional mail) and for this purpose we provide the following contact details:

GAMEDEVOCEAN sp. z o.o.

Ul. Akacjowa 8 (Str.)
05-230 Kobyłka, Poland
e-mail: contact@gamedevocean.dev

If and when amendments to this Privacy Policy are possible

We undertake to regularly review this Privacy Policy and change it when it proves necessary or desirable due to new generally applicable legal provisions, new guidelines from authorities responsible for supervising personal data protection processes, best practices used in the area of ​​personal data protection (i.e. codes of good practice; if GAMEDEVOCEAN is bound by such codes, we will inform you about this fact). We reserve the right to change this Privacy Policy in the event of changes in the technology by which we process personal data (if the change affects the wording of this document), as well as in the event of changes in the methods, purposes or legal basis for processing personal data by GAMEDEVOCEAN.

This document was last updated on March 5, 2025.