Incuvo | Privacy and Cookies Policy

PRIVACY POLICY

INTRODUCTION

This Privacy Policy sets out the principles for the processing of your personal data and has been drawn up in accordance with the law, including the provisions of 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 (General Data Protection Regulation – GDPR).

We recognize that protecting your privacy is an ongoing responsibility and therefore we will update this Privacy Policy from time to time, as we undertake new activities and practices with respect to the processing of your personal data. This may include, in particular, new functionalities being added to our games.

IN WHAT SITUATIONS DO WE PROCESS YOUR PERSONAL DATA?

We process your personal data in the following situations:

you are a current or prospective client or supplier of the controller, or an employee, representative, or contact person of any of them;
you are a person who applies to the controller in one of the recruitment processes published on our website or through social media portals;
you are a visitor to our website;
you are a person who has “liked” or otherwise linked your profile to the controller’s profiles on Facebook, Instagram, Twitter, YouTube, LinkedIn, or other social media;
you are a participant in events or meetings organized by the controller.

We do not collect or process players’ personal data. Depending on the platform on which you use our games, the platform owners may collect different data about you. The only data we have access to is aggregated data in the form of sales values by geographic location (country level). You can find information about the processing of personal data by the owners of the platforms on which our games are made available by clicking the appropriate link:

Valve: https://store.steampowered.com/privacy_agreement/english/

Oculus: https://www.oculus.com/legal/privacy-policy/

Viveport: https://www.htc.com/us/terms/privacy/

Sony: https://www.playstation.com/en-gb/legal/privacy-policy/

Apple: https://www.apple.com/legal/privacy/en-ww/

Google: https://policies.google.com/privacy

WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

The controller of your personal data is Incuvo S.A. with its registered office in Katowice, at ul. Ligocka 103, 40-568 Katowice, entered in the register of entrepreneurs maintained by the District Court for Katowice-Wschód in Katowice, VIII Commercial Division of the National Court Register, under KRS number 0000642202, NIP 6342805589, with the fully paid-up share capital of PLN 7,142,252.50.

WHOM CAN YOU CONTACT REGARDING THE PROCESSING OF YOUR PERSONAL DATA?

If you have any questions about the processing of your personal data, please contact us at: privacy@incuvo.com or send a letter to the controller’s registered address.

WHAT IS THE PURPOSE OF THE PROCESSING OF YOUR PERSONAL DATA AND WHAT IS THE LEGAL BASIS FOR ITS PROCESSING?

The scope and purpose of our processing of your personal data depend on the relationship you have with us.

If you are a current or prospective client or supplier of the controller, or an employee, representative, or contact person of any of them

We process your personal data (name, surname, business contact details, tax identification number, bank account number, if applicable) for the following purposes:

in connection with the legitimate interest of the controller in the form of the possibility of defending and pursuing claims (Article 6(1)(f) of the GDPR);
performance of an agreement or taking steps at the request of a person prior to entering into an agreement (Article 6(1)(b) of the GDPR);
in order for the controller to comply with its obligations under the law (Article 6(1)(c) of the GDPR).

If you are a person who applies to the controller in one of the recruitment processes published on our website or through social media portals, or otherwise

We process the following of your personal data:

identification data, address data, data on education, work experience, contact details (phone number and e-mail) – in order to carry out the recruitment process, i.e. on the basis of Article 22¹of the Labour Code;
identification data, address data, data on education, work experience, contact details (phone number and e-mail) – in order to carry out the recruitment process for the purposes of establishing cooperation on the basis other than an employment contract, i.e. on the basis of Article 6(1)(b) of the GDPR;
other data provided by you in the recruitment documents, including your image – on the basis of Article 6(1)(a) of the GDPR, i.e. on the basis of your free and informed consent to their processing;
identification data, address data, data on education, work experience, contact details (phone number and e-mail), and other data provided by you in the recruitment documents – in order to carry out future recruitment processes on the basis of Article 6(1)(a) of the GDPR, i.e. on the basis of your free and informed consent to their processing;
identification data, address data, contact details (phone number and e-mail) – in connection with the legitimate interest of the controller in the form of the possibility of defending and pursuing claims (Article 6(1)(f) of the GDPR).

If you are a visitor to our website

We process your personal data contained in the following types of cookies:

“essential” cookies that enable you to use the website;
cookies used for security reasons, e.g. fraud detection;
“analytical” cookies, which allow us to collect information about how the website is used;
“functional” cookies that allow us to “remember” the settings you have chosen and personalize your interface;
“advertising” cookies, which enable us to provide you with advertising content that is more closely tailored to your interests.

We may process your personal data contained in non-essential cookies on the basis of your free and informed consent (Article 6(1)(a) of the GDPR), which you may withdraw at any time. Please be advised that restricting the use of cookies may affect the functionality of the website.

The data collected may include: your source IP address, the country of origin of the IP address, and the HTTP referrer (i.e. the page from which you reached us).

We also process your personal data in connection with providing you with electronic services by providing you with the opportunity to visit and use our website (Article 6(1)(b) of the GDPR).

If you are a person who has “liked” or otherwise linked your profile to the controller’s profiles on Facebook, Instagram, Twitter, YouTube, LinkedIn, or other social media

We process your personal data for the following purposes:

name, surname, profile name on the portal, e-mail address, other user data made available by you via the privacy settings on the given portal – in order to inform you about the controller’s activities and to promote the services provided by us, i.e. on the basis of the legitimate interest of the controller, as specified in Article 6(1)(f) of the GDPR;
name, surname, contact details – in order to pursue or defend claims insofar as they may arise as a result of or in connection with your activity on the controller’s profile on Facebook, Instagram, Twitter, YouTube, LinkedIn or other social media, i.e. on the basis of the legitimate interest of the controller, as specified in Article 6(1)(f) of the GDPR.

If you are a participant in events or meetings organized by the controller

We process your personal data for the following purposes:

name, surname, contact details (phone number and e-mail), workplace details – in order to perform an agreement concluded following your acceptance of the terms of participation in the event or meeting, i.e. on the basis of Article 6(1)(b) of the GDPR;
name, surname, contact details (phone number and e-mail) – in order to pursue or defend claims insofar as they may arise as a result of or in connection with the performance of an agreement, i.e. on the basis of the legitimate interest of the controller, as specified in Article 6(1)(f) of the GDPR;
name, surname, contact details (phone number and e-mail), workplace details – for statistical and archiving purposes, i.e. on the basis of the legitimate interest of the controller, as specified in Article 6(1)(f) of the GDPR.

WILL WE PROFILE YOUR PERSONAL DATA OR MAKE AUTOMATED DECISIONS BASED ON YOUR PERSONAL DATA?

No. We do not intend to create profiles based on your personal data or make automated decisions based on your personal data.

IS IT NECESSARY TO PROVIDE US WITH PERSONAL DATA?

If you are a current or prospective client or supplier of the controller, or an employee, representative, or contact person of any of them

Providing personal data is voluntary, however, it is necessary in order to achieve the purpose of establishing or continuing cooperation with us.

If you are a person who applies to the controller in one of the recruitment processes published on our website or through social media portals

Providing personal data is voluntary, however, it is necessary in order to carry out the recruitment process in which you apply to participate. You have no obligation to provide us with the personal data processed on the basis of your consent and the outcome of the recruitment process may not be based on such a decision.

If you are a visitor to our website

We need the personal data processed based on our legitimate interest and in connection with the provision of services in order to enable us to operate www.incuvo.com.

For other personal data processed on the basis of your consent – these data are provided voluntarily.

If you are a person who has “liked” or otherwise linked your profile to the controller’s profiles on Facebook, Instagram, Twitter, YouTube, LinkedIn, or other social media;

Providing personal data is voluntary, however, it is necessary in order to provide you with access to the content published on the controller’s profiles on these portals.

If you are a participant in events or meetings organized by the controller

Providing personal data is voluntary, however, it is necessary in order to ensure your participation in the event in which you have applied to participate.

WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?

You have the right to:

request access to your personal data;
request correction of your personal data;
withdraw your consent at any time by sending an e-mail to privacy@incuvo.com. The withdrawal of consent is binding for the controller in respect of the data whose processing took place on the basis of this consent. The withdrawal of consent does not affect the lawfulness of the processing that was made on the basis of such consent before its withdrawal;
request limitation of the processing of your personal data;
request deletion of your personal data (the right to be forgotten);
portability of your personal data;
object to the processing of your personal data where it is done on the basis of Article 6(1)(f) of the GDPR (i.e. on the basis of the legitimate interest of the controller).

In addition, in case of a possible violation of data protection regulations you have the right to lodge a complaint with the President of the Office of Personal Data Protection.

HOW LONG DO WE RETAIN YOUR DATA?

The controller retains your personal data processed based on our legitimate interest:

until you object – if you successfully object to the processing and there is no other reason for us to continue processing your data; or
until the lapse of the period of the statute of limitations for our claims – if they are the source of our legitimate interest.

The controller retains your personal data processed in connection with the performance of an agreement or the submission of a request prior to its conclusion for the period necessary for the performance of the agreement or the satisfaction of the request made.

The controller retains your personal data processed in connection with a legal obligation imposed on the controller by law, for the period of time provided for by such law.

The controller retains your personal data processed on the basis of your consent until you withdraw your consent to the processing.

TO WHOM MAY WE DISCLOSE YOUR DATA?

The controller may disclose your personal data to its service providers or suppliers, such as IT service providers, hosting services providers, or marketing solution providers, who process personal data on behalf of and at the instruction of the controller.

As a result of our close cooperation with other PEOPLE CAN FLY Group companies, in justified cases, we may transfer your data to the group companies for the purpose of performing mutual cooperation agreements, subject to data confidentiality rules.

We may transfer your personal data outside the European Economic Area (EEA) – to the PEOPLE CAN FLY Group companies or to entities providing services to us (in particular cloud solutions), if it is necessary for the legitimate interests of the controller. In such a case, the transfer of data will be secured by mutual agreements based on standard contractual clauses approved by the European Commission or other mechanisms introduced in accordance with the principles established by the GDPR.