Polityka prywatności

Privacy Policy

ConsoleWay S.A., a company incorporated under the laws of Poland, with its registered office at ul. Marszałkowska 87/102, 00-683 Warsaw, Poland, entered in the Register of Entrepreneurs of the National Court Register under KRS No. 0000446450, NIP 5242756833, REGON 146490347 (“ConsoleWay”, “we”, “us” or “our”), respects the privacy of users of its games and related services.

ConsoleWay S.A. is the data controller with respect to personal data processed by ConsoleWay in connection with games published or operated by ConsoleWay through Microsoft Store, Xbox consoles and Xbox network services.

This Privacy Policy explains what information we may process, why we process it, how it may be used and what rights you have in relation to your personal data.

This Privacy Policy applies to games and related services published or operated by ConsoleWay S.A. on Microsoft Store and Xbox platforms (collectively, the “Games”).

If you do not agree with this Privacy Policy, please do not use the Games or related online services.

1. Information We May Process

Depending on the Game and the features available in that Game, ConsoleWay may receive or process limited information relating to your use of Xbox network services.

This information may include:

Xbox user identifiers, including XUID;
Gamertag and limited Xbox profile information required by the Game;
information concerning your activity within the Game;
gameplay statistics, achievements, scores, rankings and progression;
multiplayer and social interaction information where such functionality is provided;
information required to verify ownership, licenses or entitlements to the Game or downloadable content;
technical information relating to the device, operating environment, Game version, errors, crashes and network connection;
diagnostic and telemetry information necessary to maintain, troubleshoot, secure and improve the Game;
information that you voluntarily provide when contacting ConsoleWay for customer or technical support.

The exact categories of data processed depend on the functionality of the particular Game.

ConsoleWay does not receive your full payment card details or other payment credentials when you purchase a Game or downloadable content through Microsoft Store. Payments are processed by Microsoft in accordance with Microsoft's own terms and privacy policies.

2. Xbox Network Data

Xbox network services may provide ConsoleWay with limited user information where required to provide features of a Game.

Xbox network data is used only in connection with providing, operating, maintaining and supporting the relevant Game and its features.

ConsoleWay does not sell or license Xbox network user data.

ConsoleWay does not provide Xbox network user data to advertising networks, data brokers or other advertising or monetization services and does not use Xbox network user data for personalized or targeted advertising.

Xbox profile information obtained through Xbox network services is not retained beyond what is necessary and permitted by Microsoft requirements. Where applicable, locally cached profile information is refreshed when the Game reconnects to Xbox network services.

Account identifiers associated with Xbox network services will be deleted where required, including following applicable account unlinking or removal of the relevant Game or service.

ConsoleWay also processes deletion requests communicated through Microsoft in accordance with applicable Microsoft requirements.

3. Purposes of Processing

We may process personal data for the following purposes:

Providing the Game

To operate the Game, authenticate users, provide gameplay functionality, save progress, enable achievements, statistics, multiplayer functionality and other Game features.

Where applicable, the legal basis for this processing is Article 6(1)(b) GDPR, as the processing is necessary to provide the Game and related services requested by the user.

Technical operation and security

To diagnose crashes, technical problems and errors, protect the Game and its users against fraud, abuse and unauthorized access, and maintain the security and stability of our services.

The legal basis is our legitimate interest under Article 6(1)(f) GDPR in maintaining and securing our Games and services.

Customer and technical support

To respond to questions, complaints and technical support requests.

Depending on the nature of the request, the legal basis may be Article 6(1)(b) GDPR or our legitimate interest under Article 6(1)(f) GDPR in providing support to users.

Compliance with legal obligations

We may process or disclose information where necessary to comply with applicable laws, court orders or legally binding requests from public authorities.

The legal basis is Article 6(1)(c) GDPR.

4. Sharing of Personal Data

ConsoleWay does not sell users' personal data.

Personal data may be processed or disclosed only where necessary for the operation of the Games, including to:

Microsoft and its affiliates in connection with Microsoft Store, Xbox consoles and Xbox network services;
hosting, infrastructure, analytics, technical support or IT service providers acting on behalf of ConsoleWay, where permitted and necessary;
professional advisers such as legal or accounting advisers where necessary;
courts, law enforcement agencies, regulators or other public authorities where disclosure is required by applicable law.

Xbox network data is handled subject to the additional restrictions imposed by Microsoft and is not shared with advertising networks, data brokers or monetization services.

Service providers acting on behalf of ConsoleWay are required to process personal data only for the purposes for which it has been provided and in accordance with applicable data protection requirements.

5. Data Retention

ConsoleWay retains personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy or for as long as required by applicable law.

Retention periods may vary depending on the category of information and the functionality of the relevant Game.

Xbox profile and account information is retained only to the extent necessary and permitted under Microsoft requirements.

Information associated with technical support requests may be retained for a reasonable period necessary to resolve the request, establish a history of technical issues or defend against potential claims.

Where information is no longer required, it will be deleted, anonymized or otherwise rendered non-personally identifiable, unless continued storage is required by law.

6. International Data Transfers

Some services used in connection with Microsoft Store or Xbox may involve processing of personal data outside Poland or outside the European Economic Area (“EEA”), including in the United States.

Where personal data is transferred outside the EEA, ConsoleWay takes appropriate measures required under applicable data protection law.

Depending on the recipient and destination country, such transfers may rely on:

an adequacy decision issued by the European Commission;
the EU-U.S. Data Privacy Framework, where applicable;
Standard Contractual Clauses approved by the European Commission; or
another lawful transfer mechanism permitted under the GDPR.

7. Security

ConsoleWay applies reasonable technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, destruction or loss.

Access to personal data is limited to persons and service providers who require access for legitimate business, operational or legal purposes.

Although we take reasonable precautions to protect personal data, no electronic transmission, network or information storage system can be guaranteed to be completely secure.

8. Children and Family Accounts

ConsoleWay recognizes the importance of protecting children's privacy.

Our Games may be used through Xbox accounts subject to Microsoft's age, family and parental control mechanisms.

ConsoleWay does not intentionally request children to provide personal information directly to ConsoleWay unless this is necessary for a particular service and permitted by applicable law.

Where parental or guardian consent is required under applicable law, personal data will only be processed in accordance with those requirements.

Parents or guardians who believe that personal data concerning a child has been processed by ConsoleWay contrary to applicable law may contact us using the information provided below.

9. Your Data Protection Rights

Subject to the conditions established by applicable law, including the GDPR, you may have the right to:

request access to your personal data;
request correction of inaccurate or incomplete personal data;
request deletion of your personal data;
request restriction of processing;
object to processing based on legitimate interests;
receive certain personal data in a structured, commonly used and machine-readable format and request data portability;
withdraw consent at any time where processing is based on consent;
lodge a complaint with a competent data protection supervisory authority.

Some Xbox-related information may be controlled directly through your Microsoft/Xbox account and Microsoft's privacy settings.

To exercise your rights in relation to personal data controlled by ConsoleWay, please contact us at:

contact@console-way.com

We may request additional information where reasonably necessary to verify your identity before fulfilling a request.

10. Microsoft and Third-Party Services

Microsoft Store, Xbox consoles and Xbox network services are operated by Microsoft.

Microsoft independently determines how it processes personal data in connection with Microsoft accounts, Microsoft Store and Xbox services.

Use of those services is also governed by Microsoft's applicable terms and privacy statements.

A Game may occasionally contain links to third-party websites or services. ConsoleWay is not responsible for the privacy practices of third parties and encourages users to review the privacy policies applicable to those services.

11. Changes to this Privacy Policy

ConsoleWay may update this Privacy Policy from time to time, including where necessary to reflect changes in the Games, applicable laws, Microsoft requirements or our data processing practices.

The date of the latest revision will be displayed at the beginning of this Privacy Policy.

Material changes may also be communicated through the relevant Game or ConsoleWay website where appropriate.

12. Contact

For questions, requests or complaints concerning this Privacy Policy or ConsoleWay's processing of personal data, please contact:

ConsoleWay S.A.
ul. Marszałkowska 87/102
00-683 Warsaw
Poland

E-mail: contact@console-way.com

KRS: 0000446450
NIP: 5242756833
REGON: 146490347

13. Supervisory Authority

You also have the right to lodge a complaint with the Polish data protection supervisory authority:

President of the Personal Data Protection Office
Urząd Ochrony Danych Osobowych
ul. Stanisława Moniuszki 1A
00-014 Warsaw
Poland

Further information is available from the Polish Data Protection Office.