Privacy Policy 

This Privacy Policy describes how your personal information is collected, used and shared when you visit orbitalknight.com Website or install and use Orbital Knight games.

GENERAL

Orbital Knight sp. z o.o. will collect and process your personal data in accordance with applicable Polish data protection laws and the EU Data Protection Directive (95/46/EC) and any applicable national legislation and/or regulation implementing or made pursuant to it, or replacing, re-enacting or consolidating it (including the General Data Protection Regulation 2016/679 and any applicable national legislation and/or regulation implementing or made pursuant to it).  For the purposes explained in this Privacy Policy Orbital Knight will transfer and share your personal data with other third parties which are located in countries outside the European Union (“EU”) and/or the European Economic Area (“EEA”) which may not have the same level of data protection laws as those in the country where you are located. Where your personal data is sent to a country outside the EU/EEA that is not subject to an adequacy decision by the EU Commission, your personal data is adequately protected by EU Commission approved standard contractual clauses and/or another transfer mechanism such as the Privacy Shield.

PERSONAL INFORMATION WE COLLECT

Information you provide to us. Personal information you may provide to us through the our Webside or games or otherwise includes:

·    Gaming data, such as information relating to your gaming profile and activity, including the trophy count.

·    Communications data, based on our exchanges with you, including when you contact us through the Webside and games, social media, or otherwise.

·    Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

·    Third-party services, such as the Apple Game Center, which may include profile data such as your nickname, personalized Memoji, and any other information that you add to your account profile that is made available to us based on your account settings on that service.

Automatic data collection.  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Webside or games, our communications and other online services, such as:

·    Device data, such as your computer or mobile device’s operating system and type, and language settings

When you visit the Website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

 We collect Device Information using the following technologies:

    - “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit https://www.allaboutcookies.org.

    - “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

    - “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

    - The Site is hosted on squarespace.com. For more information about use of cookies, used on squarespace.com visit squarespace.com Cookie Policy https://www.squarespace.com/cookie-policy/ and Privacy Policy https://www.squarespace.com/privacy/.

 When we talk about “Personal Information” in this Privacy Policy, we are talking also about Device Information.

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above.  For example, we use squarespace.com to power our website.  We also use Google Analytics and AWS to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here:  https://www.google.com/intl/en/policies/privacy/.  You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout. and to AWS: https://aws.amazon.com/privacy/

We also may share your personal information with that third-party services that are linked to your game profile, such as the Apple Game Center. We may use your personal information for the following purposes or as otherwise described at the time of collection: Webside and games delivery and business operations.  We may use your personal information to:

·    provide, operate and improve the our Webside and games and our business;

·    facilitate social features of the Webside and games, such as by identifying and suggesting connections with other players to improve your gaming experience;

·    communicate with you about the Webside and games, including by sending announcements, updates, security alerts, and support and administrative messages;

·    understand your needs and interests, and personalize your experience with the Webside and games and our communications; and

·    provide support for the Webside and games, and respond to your requests, questions and feedback.

To create aggregated, de-identified and/or anonymized data.  We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect.  We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you.  We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Webside and games and promote our business.  

Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.  To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.   

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

YOUR RIGHTS

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you, or otherwise to pursue our legitimate business interests listed above.  Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

MINORS

The Site is not intended for individuals under the age of 13.

CHANGES

This Privacy Policy applies to all personal data collected by us or provided by you. This Privacy Policy is subject to change and we may make any changes to this Privacy Policy as we see fit. Orbital Knight will notify you of material changes by posting them in the games, or on the websites, etc. You are encouraged to check back and review this Privacy Policy from time to time so that you will always know what personal data is collected how it is used and to whom it is disclosed. Your continued use of the game subject to this Privacy Policy will signify your acceptance of Privacy Policy changes.

Orbital Knight games 

When you install and use Orbital Knight mobile games, we can collect and process some of your data for different legitimate purposes.

You will find below explanations regarding the reasons why Orbital Knight may collect data and the legal bases Orbital Knight relies on in each case. 

Orbital Knight collects data: 

·      To provide you with the services you asked for

(e.g., knowing that you completed the first level to allow access to the second one)

·      Legal basis – such data processing is strictly necessary for the service(s) asked

·      To run analytics and understand how users interact with our product and services in order to continuously improve it

(e.g. identifying that a feature is annoying for users or that a level is too difficult for most gamers)

·      Legal basis - Express consent. Orbital Knight only processes or shares personal data collected through Orbital Knight mobile games for analytics purposes once you express your consent through the pop-up notice included in our apps.

·      To serve advertising tailored to the preference and interests of our users

and allow Orbital Knight to continue to provide free services and products

·      Legal basis – Express consent. Orbital Knight only processes or shares personal data collected through Orbital Knight mobile games for personalized advertising purposes once you express your consent through the pop-up notice included in one of our mobile games.

For all data processing activities that rely on users’ consent, you can withdraw your consent at any time from the “settings” page in our various mobile games.

Please only note that in the case where you withdraw your consent or where you refuse to consent in the first place, you will still be served with advertising but that may be less relevant to you as it will not be tailored to your interests.

What data does Orbital Knight collect from its mobile games?

For all the purposes listed above the data that Orbital Knight collect is limited to:n

·      The apps you are using

·      Your IP address

·      Your Mobile Advertising ID (Apple IDFA or Google AAID - which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings)

·      Technical information about the device you use and your connection (user agent, type of connection, timestamp)

·      Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertising served in our applications (for instance, number of ads served, potential clicks)

With who may your data be shared & why?

When you consent to the collection of data for advertising and analytics purpose, we may share the data listed above with the following categories of recipients:

·      Ad Partners: that allow us to monetize the ad inventory of our apps and provide users with free products and services.

Those partners usually collect data via their own tools (Software Development Kits or “SDK”). You will find a list of our partners implementing advertising SDKs through our applications and the privacy policies of their services that describe their practices and allow you to exercise your rights directly toward them hereafter:

·      Adcolony -https://www.adcolony.com/privacy-policy/

·      Applovin -https://www.applovin.com/privacy/

·      Criteo -https://www.criteo.com/privacy/

·      Facebook -https://www.facebook.com/about/privacy

·      Fyber -https://www.fyber.com/privacy-policy/

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

·      Inmobi -https://www.inmobi.com/privacy-policy/

·      Ironsource -https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

·      Mintegral -https://www.mintegral.com/en/privacy/

·      Mopub -https://www.mopub.com/legal/privacy/

·      Oath -https://policies.oath.com/in/en/oath/privacy/

·      Ogury -https://ogury.com/privacy-policy/

·      Tapjoy -https://www.tapjoy.com/legal/tapjoy-users/#privacy-policy

·      Vungle -https://vungle.com/privacy/

·      Analytic companies: that provide us with tools and technologies that allow us to better understand how users interact with our services and will help us improve it. Those partners also usually collect data via their own SDKs. You will find a list of our partners implementing analytical SDKs through our applications hereafter:

·      Adjust -https://www.adjust.com/terms/privacy-policy/

·      GameAnalytics -https://policies.google.com/privacy email: privacy@gameanalytics.com

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

·      Mixpanel -https://mixpanel.com/legal/privacy-policy/

·      Tenjin -https://www.tenjin.io/privacy/

·      Authorities: only to the extent we are obliged to by applicable laws and regulations.

APPLE ARCADE

This section applies to the games when provided through an Apple,Inc. in Apple Arcade (“Apple”), and Orbital Knight sp. z o.o. (“Orbital Knight”, “we”, “our” or “us”) services related to the game (collectively, the “Service”), and details how we collect, use, and disclose about our users.

The Service collect only these types of data:

·        save state data, which contains non-personal gameplay data, such as character and level progression and achievement tracking (collectively, “Save Data”);

·        a local device ID specific to Save Data for internal operations of the game  (a “Device ID”)

·        anonymized gameplay data upon your consent to help us improve our games. We do not collect gameplay data from underage players.

·        When a game crash occurs we collect data related to that crash and store it locally on your device. This data is transferred to our servers upon your consent and used to help find the source of the error.

Save Data, along with a Device ID, is sent to Apple for Game Center achievements, leaderboards and to iCloud for storage. Save Data is also stored locally on your device used to access the Service. In some jurisdictions, Save Data or a Device ID may be considered personal data either because it can be combined with more specific personal data linking such data to a particular person or household or because it actually is, or is linked with, personal data associated with a particular person or household. Other uses of the data we collect include: displaying and delivering the game and content through the Service; supporting the security and integrity of the Service; and complying with contractual, legal (including requests from law enforcement or government authorities through means such as subpoenas or warrants), regulatory or audit obligations or defending our rights and the rights of others.

When a game is provided via Apple Arcade we collect your gameplay or crash data on our severs in AWS cloud. We do not share that data with other Analytic companies.

Data deletion requests

Orbital Knight

To delete user data collected by Orbital Knight, please reach out to iod@orbitalknight.com.

If you consider your rights to be violated or your data processing rules infringed, you are entitled to file a complaint with relevant supervisory authority. Default authority for such a complaint is President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), however you may also lodge a complaint with any other personal data protection authority in an European Union member state.

If you also want to request the deletion of the data that may have been collected about you or your device by our third-party partners that are acting as independent data controllers, you will find above the links to their privacy policies.

Voodoo

Voodoo does not collect any of your personal data, and only provides an SDK package to retrieve the data collected by the above mentioned third-party partners. You can still contact them to request the deletion of their accesses to the partners’ interfaces.

email: dpo@voodoo.io

General Regulation on Personal Data Protection
(RODO)

Due to processing of your personal data by Orbital Knight sp. z o.o. with its registered office in Warsaw, at Aleje Jerozolimskie 96, 00-807 Warsaw and in accordance with Article 13(1) and (2) of the General Regulation on Personal Data Protection of 27 April 2016, BlueSoft Sp. z o.o. informs that:

1. The controller of your Personal Data is Orbital Knight Sp. z o. o. based in Warsaw, al. Jerozolimskie 96, 00-807 Warsaw;

2. Your personal data will be processed solely for the purpose of managing the recruitment processes, storage and use in future recruitment processes (provided that future recruitment processes are also covered by this consent).

3. Only the Human Resources Department as well as the hiring managers will access your personal data.

4. Personal data will be stored until the end of the recruitment procedure conducted by Orbital Knight sp. z o.o.

5. Orbital Knight sp. z o.o. as the Personal Data Controller hereby informs you that on the basis of the provisions of Regulation 2016/679 of the European Parliament and of the Council (EU) of 27 April 2016 you are also entitled to:

  • access your personal data and have them rectified

  • make a reasoned written request to cease further processing of these personal data by contacting: contact@orbitalknight.com

  • transferring the data (if technically possible) to another entity by identifying the entity and contacting: contact@orbitalknight.com

  • lodge a complaint with the President of the Office for the Protection of Personal Data

  • The provision of your personal data is voluntary but necessary for the fulfillment of the above mentioned purposes.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at iod@orbitalknight.com or by mail using the details provided below:

Aleje Jerozolimskie 96, Warsaw, MZ, 00-807, Poland