November 4, 2019
This information of processing of personal data are addressed to the clients (players) of the Utin Computer, s. r. o., which are primarily users („Players”) of software products („Games”) of the company. Our company depends on the proper processing of its clients’ personal data. As of Nov 4th, 2019 we are processing the data of our clients in accordance with Regulation (EU) 2016/679 of the European Parliament and the Council of 27th of April 2016 on the protection of individuals focusing on processing of personal data and on the free movement of such data, which repeals the Directive 95/46/EC (General Regulation on the Protection of Personal Data) (afterwards referred to only as „Regulation“) and the relevant Slovak legislation no. 18/2018 Z. z. on the Protection of Personal Data and on the Amendment to Certain Acts (the "Act").
Please, follow the text below in acquaintance to the processing of your personal data. The purpose of this document is to provide you with a clear answer to why we are processing your personal data, how we process it, what your rights according to this process are and provide you with other relevant information about processing your personal data.
A. Terms related to the process of assessment of personal data
B. Who is the operator of your personal data?
C. Which personal data are we processing?
D. From which source are we collecting your personal data?
E. Which are the main purposes for processing of your personal data?
F. To whom can be your personal data provided?
G. Where are your personal data being processed?
H. How long do we keep your personal data in evidence?
I. Profiling and the process of an automated decision
J. Your rights related to processing of your personal data
K. How can you get more information and enforce your rights?
Please, get acquainted with basic terms listed on this document, which can be useful to you for the better understanding of this document.
Personal data – any information regarded to the identified and identifiable individual, e. g. name, surname, date of birth, telephone number, e-mail address, user ID, IP address, etc.,
Affected person – an individual, to which the personal data are related,
Processing of personal data – an operation or set of the operations with personal data, e. g. collecting, recording, organizing, storing, changing, using, providing to third parties or deleting,
Operator – an individual or legal person, which determines the purpose and ways related to the processing of your personal data; this competence can be transferred to the intermediary,
Intermediary – an individual or legal person, a public authority, an agency or other subject, which processes the personal data for the operator and in his name,
Purpose – a reason, why personal data are being processed by the operator,
Special categories of personal data – a sensitive personal information, which is defined by its specific character, e. g. health or biometric data to identify the person,
Authorized (legitimate) interest – an interest of operator or any other subject that results in the need to process the personal data, if it prevails over the interest of the affected person,
Profiling – any automated processing of personal data, which consists of the use of personal data to evaluate certain personal aspects of the affected person,
Recipient – an individual, legal person, public authority or any other subject, to whom are personal data provided.
The operator of your personal data is Utin Computer, s. r. o. with registered residence: Sládkovičova 858/7, 81106, Bratislava, Slovakia, IČO: 46319328, registered in the Commercial Register of the District Court Bratislava I, section: Sro, insertion no. 80056/B (thereinafter in text referred to as "Company"). The Company determines the purpose and ways of the processing of your personal data.
Basic information about Company: Sládkovičova 858/7, 81106, Bratislava, Slovakia
For questions concerning the processing of your personal data by the Company feel free to contact us via the firstname.lastname@example.org email address or by writing at Utin Computer, s. r. o., Sládkovičova 858/7, 81106, Bratislava, Slovakia.
The Company processes personal data that is necessary to provide you with products and services or, where appropriate, to protect itself and its legitimate interests. The Company processes primarily the next necessary categories of personal data about its clients (Players):
Basic identification data: name, surname, unique identifier of a player (User ID)
Contact data: e-mail address, country
Other data, that are being processed by the Company: IP address, Cookies files, in certain situations also your Facebook friends and other traffic data (IP address, device model, architecture of CPU, version OS, etc.)
The Company acquires your personal data in particular from you, especially when accepting the mutual (contractual) agreement about the software use (EULA). Your personal data can be also acquired from other subjects – third parties, e. g. Facebook, Google, Apple, Amazon, Steam, Samsung, WizQ, however only on the basis of your personal authorization provided to these subjects in order to grant your data to the Company.
For the reason of concluding and fulfilling the contract.
Due to the process of conclusion and fulfillment of the contract Company processes your personal data in order of providing an access to the software (game) of the Company for the user (Player), in order of providing the player support and improving the quality of the services provided by the Company necessary to the rightful function through updates and enhancements, the enhancement of the game surrounding and providing of new functionalities. For this purpose, Company may follow your interactions with Company, as well as to monitor different areas, in which you are interested in. The obtained data can be also used as for the purposes of optimization and improvement of the content of services provided to you by the Company as part of the software and also in order to detect potential malfunctions and mistakes (errors).
Obtained and processed data by Company may be also processed in order to compiling and publishing purposes of general statistical reports to extend and customize of services provided to players, appealing to their preferences. These data do not contain information about the content which could by any way lead to identification of random individual.
Data obtained by the Company for designed purposes are being processed on the legal basis of the contractual agreement between the Company and end users – Players – in form of defined licensing terms and agreements about the use of products and services provided by the Company (EULA).
According to GDPR is EULA being considered to be a contract in accordance with article 6, point 1, letter b) for the purposes of the determination of legal basis in the operation of processing the personal data.
For the needs of above defined purposes Company processes following personal data of the players:
For the reasons of direct marketing.
Under the conditions of its software (game) the Company also uses the functionality of so-called „banners“. This menu is displayed to the players while using software (playing game) as one of the interface screens during the progress through the game.
Based on an analogical advance, various limited offers (so called „premium item“) are being promoted in order to purchase the special edition of the particular element under the conditions of software.
These activities represent the form of direct marketing used by Company in the relation to GDPR, that is oriented at specific players and address their potential needs.
The Company implements these activities only under the conditions of the software (game) itself. The use of these activities in any way leads players to the process of purchase, nor does them limit in common use of the game.
According to GDPR, the legal basis for processing of your personal data in terms of this form of marketing is to legitimate interest of the Company in accordance with article 6, point 1, letter f) and in accordance with section 47 of the GDPR.
In terms of the direct marketing’s realization necessaries Company processed the following personal data of players:
We process your personal data to their fullest possible extent internally within the Company. Your personal data are being provided to other subjects only when it’s necessary to achieve the purpose of processing.
Company cooperates in the case of some activities with external subjects, which process personal data under the name of the Company (thereinafter „Intermediaries”). Intermediaries process personal data always on the basis of a contract between the Company and intermediary. Current company intermediaries are:
The purpose of intermediaries’ services is to collect, store and provide data, that are necessary for the basic and distributed operation of provided services by Company within the offered software, as well as providing of the basic infrastructure for the operation of specific functionalities and software components.
Your personal data can be provided to public authorities in case of imposition by law or this advance is necessary for the fulfillment of law’s obligations. Public authorities include in particular courts and authorities involved in criminal investigation, etc.
Your personal data are being processed on servers within the so-called cloud services, provided through third parties’ companies on the basis of a contract between the Company and particular third party. These companies are from the point of view of processing the personal data perceived as an intermediary.
Company processes your personal data for as long as it’s necessary for the duration of an EULA’s contractual relations.
Company applies the principle of minimalization, which means that after the duration of processing your personal data expires, the personal data will be anonymized or deleted from databases and information systems of the Company, and at the latest 10 years after the termination of a contractual obligation of EULA.
Company doesn’t implement in relation to you and your personal data an automatic individualized decision making including profiling, that could cause legal effects on your person.
You have the following rules in relation to the processing of your personal data:
Access to personal data
According to art. 15 of the Regulation you have right to: a) obtain the confirmation that Company processed your personal data, b) in case the Company processes your personal data, the right to obtain information about this advance as referred in art. 15 point 1 of the Regulation, c) receive a copy of personal data, which are being processed by Company.
In case of unfounded and inadequate requests, primarily because of their repeated nature, Company can demand a reasonable fee for the copy.
Correction of personal data
According to art. 16 of the Regulation you have right to demand correction of incorrect data or completion of incomplete personal data processed by Company. Correction or completion is Company obligated to do without undue delay, always based on technical options in particular case.
Deletion of personal data
You have the right to demand the deletion of your personal data without undue delay and in cases listed in art. 17 of the Regulation, especially when: a) personal data are no longer required for the purposes, for which were obtained, b) you’ll call off the approval with the processing of personal data, c) you oppose to the processing of personal data for the legitimate purposes of the Company and there are no legitimate reasons for the processing or you oppose to the processing for the purposes of direct marketing, or d) personal data were processed illegally.
Restriction to the process of personal data
According to art. 18 of the Regulation you have right to object to the processing of personal data, in case you’ll object the accuracy of the personal data, legitimacy or merits of its processing, or if you’ll object to their processing.
The portability of personal data
If you provide us with your personal data in relation to the contract or based on your own approval and the processing of personal data is being based on an automated manner, you have the right to obtain from us these personal data in a structured, commonly used and machine-readable format. If it’d be technically possible, we may provide your personal data to the operator, which you’ll determine.
The right to object against the processing of personal data
According to art. 21 of the Regulation you have right to object against the processing of your personal data, in case the processing is being carried due to the legitimate interest of the Company. In case Company won’t exhibit that there exist necessary and legitimate reasons for processing, which prevail over your own interests, rights and freedom, or reasons for demonstration, applying or defense of the law requirements, Company will end processing of personal data based on your objection and without undue delay.
The right to turn to supervisory authority
If you suppose that in terms of our activities comes to an unauthorized processing of the personal data, you may address with the complaint to the supervisory authority, which is the Office for the Protection of Personal Data of the Slovak Republic for the territory of the Slovak Republic.
Revocation with the processing of personal data
Conferment of the approval with the processing of personal data is optional and it’s up to you, whether you confer the approval in a proposed scope or not. The approval with the processing of personal data can be at any time taken back. The withdrawal with the approval does not have any effect on the legitimacy of the processing before it was taken back.
The above rights apply to the extent and under the conditions set forth in the Regulation.
In case you have questions about the processing of your personal data or you want to know more information, you can contact us by writing us on our address: Utin Computer, s. r. o., Sládkovičova 858/7, 81106, Bratislava, Slovakia, or by e-mail address: email@example.com
This document will be regularly updated. Status as of 4th of Nov 2019.