This privacy policy („Privacy Policy”) is a document which determines terms and conditions on which Virtual Alchemy sp. z o. o. with headquarters in Warsaw, ul. Rakowiecka 34/2, 02-532 Warsaw, entered into the register of entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw XIII Commercial Division of the National Court Register under the KRS number: 0000951682, NIP: 5213955286, REGON: 385562142 (“Virtual Alchemy”) may collect information and data (including personal Data) concerning users (“User” or collectively “Users”). Use of services and games of Virtual Alchemy requires acceptance of this Privacy Policy by Users. In case of any doubts concerning this Privacy Policy, User is allowed to contact Virtual Alchemy by e-mail address: contact@virtual-alchemy.games or by traditional post on address: Virtual Alchemy sp. z o. o. with headquarters in Warsaw, ul. Rakowiecka 34/2, 02-532 Warsaw.
What this Privacy Policy Governs?
This Privacy Policy governs use by Users of games and all the other services provided by Virtual Alchemy, including websites, technical assistance (support), means of communication and customer services (e.g. complaints), hereinafter referred collectively to as “Services”. Use of Services requires obtaining by Virtual Alchemy specified information concerning User (“Data”), including personal Data which means Data, which on its own or in combination with other information allows to identify given User.
Who is User?
User is a natural person who uses Services provided by Virtual Alchemy. Personal Data of persons under age of 16 are subjected to particular protection, in particular its collection requires obtaining consent of statutory agent (e.g. parent, legal guardian). In the event that Virtual Alchemy obtains Personal Data of User under age of 16 in an unaware or uncommitted manner, Virtual Alchemy after receiving information in that respective area shall take all necessary legal actions (e.g. upon request of statutory agent).
From where Virtual Alchemy obtains my personal Data?
We obtain your personal Data mainly from you. You provide us with your Data to contact us by sending us an e-mail, filling in the application form in the recruitment process, and even by providing us with your business card. We also obtain your Data in connection with our business activities and the implementation of transactions in the scope of the services we provide.
Customers, contractors or business partners
If you are our client, contractor or business partner, you run a sole proprietorship or represent a company or organizational unit, we collect your personal Data mainly from you. You provide us with your Data to contact us in matters relating to the terms of cooperation, by sending us an e-mail or by contacting us by phone. We also obtain your Data in connection with our business activity as part of the performance of the contract for the provision of services or taking appropriate actions before concluding the contract.
If you are an employee of a company or organizational unit, and Virtual Alchemy processes personal Data, you have never provided them directly – it happens that your Data may be provided to us by a third party, at your request or in a company with your official duties. Your Data may be provided to us by your employer to enable us to contact you in connection with cooperation, we will undertake with the entity in which you are employed.
This collection also includes customers purchasing Virtual Alchemy products offered via online platforms. Therefore, if you are a user of the platforms on which our products are offered, it may happen that your personal Data will be provided to us by the administrator of a given platform. As a rule, this will be information provided by the user or other information taken automatically and used to operate, maintain, improve, share, create and develop all functions and services of a given product or platform.
Users of online platforms
If we receive your personal Data from an administrator of online platforms dealing with digital distribution, your personal Data will be used to execute the contract concluded with you. This includes, in particular, providing your contact details that allow us to establish and maintain contact with you in the course of cooperation. In this case, your personal Data will be processed taking into account all technical and organizational measures used by the administrator of online platforms to ensure the protection of personal Data, taking full account of their privacy policies. In order to obtain additional information on the rules of processing your personal Data by the administrator of a given internet platform, you should read the privacy policy adopted by him, including the cookie policy.
Employees and job applicants
If you are our employee or co-worker, we obtain your personal Data mainly from you. You provide us with your personal Data for the purposes necessary from the employment perspective – when concluding an employment contract, civil law contract, or by filling in a personal questionnaire. As your employer or principal, we must process your personal Data to be able to contact you and properly settle all issues related to your employment, including for tax or social security purposes. It happens that some of your personal Data will be provided to us by third parties, e.g. state authorities that will contact us as your employer or cooperating entity.
If you taking steps to establish cooperation with us and want to send us your documents in relation to such an application, or you provide them directly to us in physical form or through a third-party, we obtain your personal Data in order to be able to contact you and include you in the recruitment process. It happens that we use the help of external entities – dedicated portals dealing with recruitment or with the help of entities dealing with employee recruitment. In this case, your personal Data is provided to us by these entities, upon your consent and request.
For what purpose Virtual Alchemy processes Data?
Running a business
If we have obtained your personal Data in connection with the conducted business activity, your personal Data will be used for the purposes of the performance of the contract for the provision of services or by taking appropriate steps before concluding the above-mentioned contract. This includes, in particular, receiving contact details from you, allowing us to establish and maintain contact with you in the course of cooperation. We also use your address and registration Data to deliver services to the place indicated by you, issue sales documents or settle our cooperation. We also need your personal Data if you wish to exercise your rights relating to our cooperation – where applicable – protection of rights.
If you are our client, contractor or supplier, you run a sole proprietorship or represent a company or organizational unit that is our client, contractor or supplier – we also process your personal Data for tax, legal and accounting purposes. We need them in order to disclose the relevant Data in the contract or invoice, as well as – to use them in keeping our tax records. However, the processing of your personal Data will always be related to our business activities.
If you are our client, contractor or supplier, you run a sole proprietorship or represent a company or organizational unit that is our client, contractor or supplier, your personal Data will be needed in particular in order to establish and maintain contact with the entity in which you work – again, only for purposes related to our business activities.
If you are a user of the platforms on which our products are offered, it may happen that your personal Data will be provided to us by the administrator of a given platform. If you receive your personal Data from the administrator of online platforms dealing with digital distribution, your personal Data will be used for the purposes of the performance of the contract concluded with you via the platform.
Your personal Data, which we use for purposes related to economic cooperation, will not be used by us for other purposes without your consent. The exception to this is the use of your Data for marketing purposes, based on our legitimate interest. We want to maintain a relationship with you, so we want to be able to keep you informed about our new offers and promotions. If it does not suit you – you can object at any time, on the terms described below in the Policy.
Employment relationship
If you are our employee or co-worker, we use your personal Data for purposes related to your employment, including recording working time or supporting employee qualifications as part of training. As your employer or cooperating entity, we must fulfill a number of obligations – both in terms of the proper arrangement of our cooperation and in HR and payroll matters. As employers, we also have certain rights – we use your personal Data, for example, to be able to contact you or to control the effects of your work. We also need your personal Data to provide you with access to employee benefits and rights as well as benefits and support in the event of your illness or maternity, as well as in the event of an accident at work. Again, the purpose of processing your personal Data is to properly handle the employment or cooperation relationship between us and to protect your interests.
It may happen that we will also use your personal Data to provide information about you to third parties, e.g. to the bank where you are applying for a loan, to the insurer, or to a public authority that will ask us an inquiry. In these situations, your personal Data will be disclosed for your benefit, at your request or in connection with our legal obligations.
Your personal Data, which we use for purposes related to the employment relationship or civil law relationship, will not be used by us for other purposes without your consent. In particular, we will not process your Data for marketing purposes without your express consent.
Recruitment
If you apply for employment with us, we use your personal Data only for the purpose of conducting the recruitment process. We use your Data to get acquainted with your education and professional experience, assess your suitability for work with us and determine the fulfillment of the criteria we require for employment, and finally – to contact you and invite you to an interview.
If, after the recruitment, we decide to hire you, the personal Data provided during the recruitment may be used for the purposes of future employment so that you do not have to provide them again. Most often, personal Data provided by you in your CV and in the cover letter are stored in your employee file.
Your personal Data, which we use for recruitment purposes, will not be used by us for marketing purposes without your consent.
Contact
If you send us an e-mail or otherwise contact us, we use your personal Data to correspond with you and answer the questions you have asked, in accordance with the content of your inquiry or message.
If you contact us for commercial purposes (e.g. to use our services), your personal Data may then be used to send you a commercial offer but only to the extent that you request it and in relation to your inquiry.
Even if we establish communication for commercial purposes, we will not use your personal Data for
marketing purposes without your consent in relation to offers other than the one you expressly requested when contacting us.
Marketing purposes
We process your personal Data in connection with the functioning of our marketing base for our marketing purposes, i.e. as part of promoting our product and service offer. As part of our marketing, we want to be able to present you our new range of products or services, as well as new commercial or business solutions used in our business.
For marketing purposes, we process your personal Data with reference to the so-called legitimate interest of the personal Data administrator (Article 6 (1) (f) of the GDPR). Permanent information about our activities is necessary for us and desirable to maintain the network of customers. Consequently, we have a legitimate interest in maintaining our marketing base and sending information to customers. Providing and processing your personal Data in this regard is completely voluntary and does not result from a legal obligation. You have the right to object to the processing of your Data in this regard at any time.
On what basis Virtual Alchemy processes my personal Data?
Virtual Alchemy ensures that your personal Data will be processed only in accordance with the law. This means that we will always process your personal Data on a specific basis that we will be able to demonstrate. The basis for the processing of personal Data may differ depending on the purpose for which we process personal Data. Virtual Alchemy processes Data in a manner consistent with binding regulations, this is upon separate consent of User on in situations in which such consent for Data processing is based on legal regulations binding on the territory of European Union or Member State Law. Virtual Alchemy subsequently processes Data upon: (1) consent of User (“the Data subject has given consent to the processing of his or her personal Data for one or more specific purposes”) e.g. newsletter, contact, (2) performance of given agreement (“processing is necessary for the performance of a contract to which the Data subject is party or in order to take steps at the request of the Data subject prior to entering into a contract”) e.g. product delivery or technical support, (3) execution of a legal obligation (“processing is necessary for compliance with a legal obligation to which the controller is subject”) e.g. tax settlement as regards incomes obtained upon provision of Services, (4) so called “legitimate interests” (“processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party”) e.g. marketing, Data protection, claims protection.
How long the administrator keeps my Data?
Virtual Alchemy stores Data solely for the period necessary for obtaining purpose for which Data being collected (e.g. performance of agreements, technical support). However, in some cases binding regulations or content of legal obligations requires that Virtual Alchemy is obliged to store Data for a longer period (so called “Data retention”). The above may concern settlement and tax issues or performance by Virtual Alchemy other obligations resulting from biding regulations. In each case such Data retention by Virtual Alchemy is based on appropriate legal base, this is consent of User or binding provision of law (on the territory of the European Union or Member State Law).
How my personal Data is processed and protected?
Virtual Alchemy applies all required by law security measures as regards Data. As a rule, Data is stored in Virtual Alchemy’s registered seat or on a protected server on the territory of European Union. In cases when due to a type of cooperation with partners Data are transferred outside the territory of European Union (European Economic Area), Virtual Alchemy applies all legal (e.g. agreements) and technical measures necessary for safety of Data processing.
Ensuring the highest quality of Services provided by Virtual Alchemy may be entailed with transfer of Data to third parties – so called “processor” – which is based on an appropriate processing agreement concluded between Virtual Alchemy and such partner. Virtual Alchemy transfers Data solely in the scope and for the purpose necessary for realization of aim agreed with such partner, applies all required legal and technical measures as regards protection of Data and cooperates solely with reliable and professional partners.
Virtual Alchemy also cooperates with entities which provide services connected to day-today functioning of company (e.g. legal advisors, tax advisors, hosting providers, courier companies). Virtual Alchemy shall also make available Data to entities which are entitled to such access upon separate binding legal regulations (e.g. administrative bodies).
What rights do I have in relation to the processing of my personal Data?
User at any time is entitled to exercise of the right to object (forbid) as regards processing of his/her Data, as well as use other type of rights concerning obtaining information or protection, in particular User have the right to: (1) access to Personal Data, (2) request to delete Personal Data, (3) request to rectify or correct Personal Data, (4) request to restrict the processing of Personal Data, (5) request to transfer Personal Data to another entity, (6) submit complaint to a Data protection authority – President of the Data Protection Office or other offices.
However, in some cases exercising one or more of the mentioned rights may result in limitation of possibility of use by User of one or more Services provided by Virtual Alchemy in which processing Data is required. Similarly, Virtual Alchemy may be obliged to store Data upon binding law regulations. In each case User who exercised on of his/her rights shall receive a proper response from Virtual Alchemy with indication of activities and their justification.
In cases related to mentioned rights please contact with Virtual Alchemy on the following e-mail: contact@virtual-alchemy.games or by traditional post: Virtual Alchemy sp. z o. o. with headquarters in Warsaw, ul. Rakowiecka 34/2, 02-532 Warsaw. User is also entitled to benefit from help provided by state (local) Data protection authorities, in particular upon contact with office of the President of the Data Protection Office or other offices.
Virtual Alchemy
Version 1.0, 07.02.2022
