Information on personal data processing for Users

Effective as of 01 November 2019.

Who is the data controller of my data?

The data controller of Users’ personal data is Gamekit S.A., with its registered office in Warsaw at ul. Koszykowa 61, entered into the National Court Register kept by the District Court for the capital city of Warsaw, 12th Commercial Division of the National Court Register (KRS), under KRS no. 0000698534.

How does Gamekit protect my personal data?

We have implemented technical and organisational measures to ensure the security of Users’ personal data. These measures include, among other things, access control to personal data, control of the processing of personal data, personal data anonymisation. The access to personal data is only granted to authorised Gamekit employees who are obliged to keep the confidentiality of the personal data. Furthermore, Gamekit has implemented an appropriate data protection policy.

Will my personal data be visible to other Gamekit Users and Internet users?

Users’ personal data, such as nicknames or the content of statements published on the Gamekit forum, are visible to other Gamekit Users. Furthermore, if an avatar with User’s image (photo) is added, this photo will be visible to other Gamekit Users. The data may also be indexed by Internet search engines and, as such, may also be available to persons who are not Gamekit Users.

Do I have the right to access my data?

Each User has the right to request the access to, rectification or erasure of personal data or restriction of processing concerning the data. Furthermore, each User has the right to object to the processing of data. The data can be accessed in the Account.

Why does Gamekit process my data?

Gamekit processes Users’ personal data on the basis of and in connection with the concluded contract for the provision of services electronically. The purpose of the processing of personal data is to provide Users with services, described in detail in the Terms and Conditions, and the performance of the contract for the provision of services electronically.

In order to use the Gamekit mobile application Users need to allow Gamekit to access her/his data on the mobile device, in particular Users shall allow access to:

  1. list of applications on the mobile device of the Users,
  2. statistical information about usage of applications installed on the Users’ device.

The access to Users’ data on her/his mobile device is essential to award Points. The data will not be shared with third parties and are not use for Users’ profiling.

Personal data need to be provided in order to enter into the contract for the provision of services electronically. Failure to provide personal data will prevent Gamekit from performance of services.

Gamekit also uses electronic communication tools, such as email, to inform Users about new functionalities of the Website or provide other information that may be of interest to Users. This activity is based on Article 6(1)(f) GDPR. Gamekit has assessed the impact of this activity on Users’ privacy and, having considered Users’ interests, has come to the conclusion that it will not have a negative impact on Users’ privacy. The purpose of such use of the personal data brings significant benefits to Users, enabling them to follow news and changes regarding their topics of interest. Each of Users may opt out of this type of activity by changing settings in their accounts.

If the User adds an avatar containing User’s image (photo), Gamekit will also processes the personal data. The photo may be deleted at any time.

With Users’ consent, Gamekit processes personal data to profile Users and for the marketing communication purposes. Consent to these activities is voluntary and does not affect the possibility of entering into the contract for the provision of services electronically.

How long will Gamekit store my personal data?

Gamekit will store personal data for the entire term of the contract for the provision of services. After the end of the contract, personal data will be stored until possible claims (including tax claims) become statute-barred.

Does Gamekit transfer personal data outside the European Economic Area (European Union)?

Gamekit may transfer personal data outside the European Economic Area (European Union). This will always be done under a legitimate basis, such as data transfer agreements based on standard clauses.

Does Gamekit transfer personal data to other entities (companies)?

As a rule, Gamekit does not transfer personal data to other entities, including companies. An exception to this rule may include:

  1. transfer of personal data at the request of a competent authority (police, public prosecutor’s office, courts, etc.),
  2. provision of personal data to entities that carry out marketing communication with User’s consent,
  3. game developers or other similar companies for which Gamekit performs contractual obligations.

Furthermore, the data collected by Gamekit may be accessed by external companies providing such services to Gamekit as hosting, server maintenance and database maintenance. These entities are recipients of the data, being the so-called processors acting on behalf of and on instructions from Gamekit. Gamekit ensures that these entities store data within the European Union or, if stored outside the European Union, that the data are adequately secured.

In the case of paid services, the personal data related to payments are transferred to the payment service provider. Gamekit does not have the access to the personal data provided to the payment service provider. This applies in particular to credit card data.

Gamekit also transfers anonymised cookies and other anonymised data to third parties regarding website Users. These data do not permit to decrypt the activity of a particular User on the Website, but they enable to determine Users’ geographic, statistical and demographic data. The purpose of provision of such data is to customise advertisements and other similar messages directed at Users.

What kind of personal data gamekit processes in the app?

Gamekit processes in the App the following personal data:

  1. e-mail address,
  2. date of birth in order to determine if the User is legally capable of using the App,
  3. if registered/logged via Facebook:
    1. ID
    2. Name
    3. Email
    4. First name
    5. Last name
    6. Facebook avatar/profile picture is used as Gamekit profile picture.
  4. if registered/logged via Google:
    1. Google ID,
    2. e-mail address,
    3. Public profile info.

These data are essential in order to use the mobile App.

Gamekit may also process information about the model of the device, Android ID, Android version and Appsflyer ID.

Do I have the right to data portability?

Yes. In accordance with Article 20 GDPR, every person has the right to data portability. The right to data portability means that everyone has the right to receive the personal data provided to Gamekit, in a structured format. Everyone may transmit the data to another controller. Everyone may also request that Gamekit transmit those data to another controller specified by the data subject, provided it is technically feasible.

What is profiling and what is it purpose?

Profiling is the customisation of the content of the Website and offers to the interests and preferences of a relevant User. Profiling is done automatically; however, it remains under human control.

User profiling at Gamekit is aimed at improving the quality of services provided to Users. For profiling purposes, Gamekit uses data on Users’ activities, interests and preferences on the Website and on other web pages. For profiling purposes, Gamekit also uses information and data on User-added content on the Website, posted comments, liked content available on the Website and on other web pages, and other activities of Users on the Website. These data are processed by a special algorithm. Profiling carried out by Gamekit, which has legal effects on Users, requires consent. Withdrawal of the consent to profiling does not affect the lawfulness of data processing under the consent before its withdrawal.

Can I withdraw my consent to profiling?

Consent to profiling is voluntary and can be withdrawn (revoked) at any time. It may withdrawn in the Account on the Website.

What is marketing communication?

Marketing communication is the activity carried out via email or other similar tools in order to present Users with Gamekit's and other entities’ (companies’) offers and promotions.

Can I withdraw my consent for marketing communications?

Consent to marketing communication is voluntary and can be withdrawn (revoked) at any time. It can be withdrawn by clicking the “unsubscribe me” link (or a similar link) in the email message received from Gamekit. Withdrawal of the consent does not affect the lawfulness of data processing under the consent before its withdrawal.

Do I have the right to lodge a complaint related to the processing of personal data?

Yes, each User has the right to lodge a complaint with the supervisory authority.


  1. Regulations on personal data processing are applied until: 2019-11-01