Privacy Policy

DEFINITIONS
1. Controller – QUBICGAMES JOINT-STOCK COMPANY, with its registered seat and address in Siedlce at ul. Katedralna 16, 08-110 Siedlce, entered into the Register of Business Entities kept by the District Court for Lublin-Wschód in Lublin, with its registered office in Świdnik, VI Economic Division of the National Court Register, under KRS No. 00000598476, with NIP (Tax Identification Number) 8212515641, REGON (Statistical Number) 141229265, with fully paid-up share capital in the amount of PLN 982,000.00.
2. Personal Data – any information about a natural person, identified or identifiable by one or several factors defining his/her physical, physiological, genetic, psychic, economic, cultural or social identity, including the IP of the device used to access the Controller’s website, location data, online identifier and information collected through cookie files and other similar technologies.
3. Policy – this Privacy Policy.
4. GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC.
5. Website – an online service run by the Controller at the address https://qubicgames.com/.
6. User – any natural person visiting the Website or using one or more services or functionalities described in the Policy.
DATA PROCESSING IN CONNECTION WITH THE USE OF THE WEBSITE
1. In connection with the User’s use of the Website, the Controller collects the data necessary to provide its services and collects information about the User’s activity on the Website. The detailed rules and purposes of processing the personal data collected during the use of the Website by the User are described below.
PURPOSES AND LEGAL BASIS OF THE DATA PROCESSING
1. The Personal Data of the User is processed by the Controller:
  1. to provide services electronically and give the User access to the content collected on the Website – in this case, the legal basis for the processing of data is that such processing is necessary for the performance of the relevant service provision contract (pursuant to Article 6(1)(b) of the GDPR);
  2. for analytical and statistical purposes – in this case, the legal basis for the processing of data is the legitimate interest of the Controller (pursuant to Article 6(1)(f) of the GDPR) in analysing the activity of the User and his/her preferences in order to improve the functionalities used and the services provided;
  3. to determine and pursue possible claims or defend against claims – in this case, the legal basis for the processing of data is the legitimate interest of the Controller (pursuant to Article 6(1)(f) of the GDPR) in protecting its rights;
  4. for the marketing purposes of the Controller – the rules of personal data processing for such purposes are described in the section titled “MARKETING”.
2. The activity of a User on the Website, including his/her Personal Data, is recorded in system logs (files for storing a chronological record of information about events and actions, used for the provision of services by the Controller). The information collected in logs is processed mainly for purposes related to the provision of services. The Controller also processes the information for technical and administrative purposes and in order to ensure the security of the IT system and manage the system, as well as for analytical and statistical purposes – in this respect, the legal basis for the processing is the legitimate interest of the Controller (pursuant to Article 6(1)(f) of the GDPR).
3. The Controller provides a technical solution enabling the User to contact it by using an electronic contact form. Using the form requires the provision of Personal Data, which is needed in order to respond to the User’s inquiries. The User can also provide other data to facilitate contact and the handling of his/her inquiries. The provision of data marked as mandatory is required in order to accept and handle a given inquiry, while the provision of other data is voluntary.
4. The Personal Data of the User is processed:
  1. to identify the User and handle his/her inquiry sent through the provided contact form – in this case, the legal basis for the processing of data is that such processing is necessary for the performance of the relevant service provision contract (pursuant to Article 6(1)(b) of the GDPR);
  2. for analytical and statistical purposes – in this case, the legal basis for the processing of data is the legitimate interest of the Controller (pursuant to Article 6(1)(f) of the GDPR) in analysing the inquiries made by User through the Website in order to enhance its functionalities.
5. If any correspondence not related to the contractual provision of services to the User or to any other agreement concluded with him/her is sent to the Controller by electronic or regular mail, any Personal Data included in such correspondence is processed exclusively for the purpose of communication and resolving the issue to which the correspondence pertains.
6. The processing of Personal Data is necessary for the purposes of the legitimate interest of the Controller (pursuant to Article 6 (1)(f) of the GDPR) in conducting correspondence addressed to it in connection with its business activity.
7. The Controller shall only process Personal Data that is relevant for the issue to which the correspondence pertains. The correspondence shall be stored in a manner which ensures the safety of the Personal Data (and other information) included therein and its disclosure only to authorised persons.
MARKETING
1. The Controller processes the Personal Data of the User for marketing purposes in connection with contextual advertising directed to the User (i.e. advertising which is not tailored to the User’s preferences). In this case, the legal basis for the processing of data is the legitimate interest of the Controller (pursuant to Article 6(1)(f) of the GDPR).
SOCIAL MEDIA
1. The Controller processes the Personal Data of the User if he/she visits the Controller’s profiles on social media (Twitter, Facebook, YouTube). Such data is processed only in connection with maintaining the profile, informing the User about the Controller’s activity, and promoting various events, services and products. In this case, the legal basis for the processing of data by the Controller is the legitimate interest of the Controller (pursuant to Article 6(1)(f) of the GDPR) in promoting its own brand.
COOKIES AND SIMILAR TECHNOLOGY
1. The Controller uses cookies mainly to provide the User with electronic services and improve the quality of such services. In connection with that, the Controller uses cookies to store information or obtain access to information already stored in the User’s end device (computer, telephone, tablet, etc.). The use of cookies within the Website is not intended to identify Users. The Policy regulates the processing of data related to the use of the Controller’s own cookies.
2. Cookies are small text files stored in the device of the User browsing the Website. Cookies contain information that is used to facilitate the use of a website, e.g., by remembering the User’s visits on the Website and the activities performed by him/her.
3. The Controller uses necessary cookies mainly to provide the User with services and functionalities of the Website that he/she wants to use. Necessary cookies may only be provided by the Controller through the Website.
4. The legal basis for the processing of data in connection with the use of necessary cookies is that such processing is necessary for the performance of the relevant service provision contract (pursuant to Article 6 (1)(b) of the GDPR).
5. Functionality cookies are used in order to remember and adjust the Website to the User’s preferred products, including with respect to language preferences. Functionality cookies may be provided by the Controller and its partners via the Website.
6. Analytics cookies make it possible to obtain information such as the number of visits and the sources of traffic on the Website. They are used for identifying more popular and less popular sites and to understand how Users navigate a site by keeping statistics regarding traffic on the Website. The processing of data is carried out to improve the Website’s performance. Information gathered by such cookies is aggregated; therefore, it is not intended to establish the User’s identity. Functionality cookies may be provided by the Controller and its partners via the Website.
7. The legal basis for the processing of data in connection with the use of functionality and analytics cookies by the Controller is the consent of the User (pursuant to Article 6 (1)(a) of GDPR).
8. The processing of Personal Data in connection with the use of functionality and analytics cookies requires the obtaining of the User’s consent. Such consent may be withdrawn at any time.
9. Advertising cookies allow the adaptation of the advertising content displayed to the User's interests within and outside the Website. Based on information from these cookies and the User's activity on other services, a profile of the User's interests is built. Advertising cookies may be provided by the Controller and its partners through the Website.
10. The legal basis for the processing of Personal Data in connection with the use of advertising cookies by the Controller is the consent of the User (pursuant to Article 6(1)(a) of the GDPR).
11. The processing of Personal Data in connection with the use of advertising cookies requires the obtaining of the User’s consent. Such consent may be withdrawn at any time.
ANALYTICAL TOOLS USED BY THE CONTROLLER
1. The Controller uses various solutions and tools for analytical purposes. Below please find basic information on such tools. Detailed information in this respect can be found in the privacy policy of the relevant partner.
2. Google Analytics cookies are files used by Google to analyse the use of the Website by the User and to create statistics and reports concerning the functioning of the Website. Google does not use the data gathered by it to identify the User, nor does it combine such information in order to enable identification. Detailed information on the scope and principles of collecting data in connection with such service can be found under the following link: https://www.google.com/intl/pl/policies/privacy/partners.
MANAGEMENT OF COOKIE SETTINGS
1. The User’s consent is required for the collection of data through such cookies, in particular the data saved on the User’s device. On the Website the Controller receives the User’s consent through the cookies management platform.
2. Consent is not required only for cookies that are necessary for providing telecommunication services (i.e. data transmission in order to view the content) – the User cannot opt out of receiving such cookies if he/she wants to use the Website.
3. The User can withdraw his/her consent by changing the browser settings. Detailed information in this respect can be found under the following links:
  1. Internet Explorer: https://support.microsoft.com/pl-pl/help/17442/windows-internet-explorer-delete-manage-cookies
  2. Mozilla Firefox: http://support.mozilla.org/pl/kb/ciasteczka
  3. Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647
  4. Opera: http://help.opera.com/Windows/12.10/pl/cookie.html/
  5. Safari: https://support.apple.com/kb/PH5042?locale=en-GB
  6. Microsoft Edge: https://support.microsoft.com/pl-pl/microsoft-edge/usuwanie-plik%C3%B3w-cookie-w-przegl%C4%85darce-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09.
4. The User can at any time verify the status of his/her current privacy settings for his/her browser using tools available under the following links:
  1. http://www.youronlinechoices.com/pl/twojewybory
  2. http://optout.aboutads.info/?c=2&lang=EN.
5. In order to exercise the rights of access, rectification, erasure, restriction or data portability, or the right to object to the processing of Personal Data, or to lodge a complaint or ask any type of question related to cookies, an inquiry should be sent using the Controller’s contact details indicated in the Policy.
PERIOD OF PERSONAL DATA PROCESSING
1. The period of data processing by the Controller depends on the type of service provided and the purpose of such processing. In principle, data is processed for the entire period of the provision of the service until the moment consent is withdrawn or an effective objection is filed in relation to such data processing in cases where the legal basis for the processing is the legitimate interest of the Controller.
2. The data processing period may be extended if processing is necessary for determining and pursuing possible claims or defending against claims and, after that time, only when and to the extent required by law. After the lapse of the processing period, the data is irreversibly deleted and anonymised.
USER’S RIGHTS
1. A User has the right to: access the content of the Personal Data, demand the rectification, erasure, portability or restriction of the processing of such data, and object to the processing of such data, as well as the right to lodge a complaint with the supervisory authority responsible for personal data protection.
2. To the extent that a User’s data is processed on the basis of his/her consent, the consent may be withdrawn at any moment by contacting the Controller or using the functionalities available on the Website.
3. The User has the right to object to data processing for marketing purposes if the processing is done in connection with the legitimate interest of the Controller and also – for reasons connected with the User’s particular situation – in other cases where the legal basis for data processing is the legitimate interest of the Controller (e.g. in connection with pursuing analytical and statistical objectives).
DATA RECIPIENTS
1. In connection with the provision of services, personal data will be disclosed to external entities, including, in particular, vendors responsible for maintenance of IT systems, marketing agencies (regarding the marketing services), accountants, auditors and lawyers.
2. If a User’s consent is obtained, his/her data may also be made available to other entities for their own purposes, including marketing purposes.
3. The Controller reserves the right to disclose selected information items referring to the User to relevant authorities or third parties who demand that they be provided such information based on legitimate legal grounds and in compliance with prevailing laws.
TRANSFER OF DATA OUTSIDE THE EEA
1. The level of protection of Personal Data outside the European Economic Area (EEA) differs from that provided within the EEA. For this reason, the Controller shall only transfer Personal Data outside the EEA when it is necessary and having ensured an appropriate degree of protection, in particular through:
  1. cooperation with entities processing Personal Data in countries with respect to which a relevant decision of the European Commission on the adequate level of protection of Personal Data has been issued; in some cases, the European Commission further requires such processing entity to participate in programs approved by it and equivalent entities outside the EEA are obliged to ensure the same protection of Personal Data as is available in the European Union (detailed information can be found here );
  2. the use of standard contractual clauses issued by the European Commission, along with any required additional safety measures that ensure the same level of protection of Personal Data as is available in the European Union; standard forms of agreements can be found here;
  3. the use of binding corporate rules, approved by the relevant supervisory body.
2. The Controller shall always notify the User regarding its intention to transfer Personal Data outside the EEA at the stage of gathering such data.
PERSONAL DATA SECURITY
1. The Controller conducts risk analyses on an ongoing basis to ensure that Personal Data is processed in a secure manner, guaranteeing that access to the data is provided only to authorised persons and only to the extent necessary for them to perform their tasks. The Controller makes sure that any operations on Personal Data are recorded and performed only by authorised employees or collaborators.
2. The Controller takes any necessary actions, so that its subcontractors and other cooperating entities also apply the appropriate security measures each case they process Personal Data on the Controller’s behalf.
CONTACT DATA
1. The Controller may be contacted by email: rodo@qubicgames.com or by letter sent to its mailing address: Aleja Zjednoczenia 36, 01-830 Warsaw.
AMENDMENTS TO THE PRIVACY POLICY
1. The policy is verified on an ongoing basis and updated as needed. The present version of the Policy was approved and has been in force since April 25, 2024.