Privacy Policy
This Privacy Policy (the "Policy") applies to the Game ("Pacwyn 25 App") available on Android and iOS platforms and establishes the rules and basis for the treatment of Users' Personal Data, including its collection, analysis, storage and distribution by Pacwyn Games Spółka z ograniczoną odpowiedzialnością, KRS Number: 0001116828, NIP Number: 5253010675 and the legal address ul. Złota 59, 00-120 Warszawa, Polska.
References to "we", "our" or "us" and similar expressions refer to the company, Pacwyn Games Spółka z ograniczoną odpowiedzialnością, (hereinafter "Pacwyn"), depending on the context of the statement. References to "you", "your", "User" refer to Users of our Game.
The primary objective of our Privacy Policy is to ensure reliable protection and control over the confidentiality of Users' Personal Data, processing it strictly within the provisions of the Policy and in accordance with international data protection and privacy standards. These standards define the lawful grounds for data collection, storage, and use, as well as Users' rights regarding their Personal Data.
Before using the Game, please review this information for a deeper understanding of how Pacwyn uses your Personal Data. If you have any questions or concerns regarding this Privacy Policy, including inquiries about the protection of your rights, please contact us through Pacwyn's support service for prompt answers.
1. Terms
1.1. Personal Data – information that identifies the User as a specific individual or that can be identified for your interaction with the Game.
1.2. CCPA (California Consumer Privacy Act) – a statute of the state of California designed to enhance privacy rights and consumer protection for residents of California and the United States.
1.3. Australian Online Safety Industry Codes – a code that includes a set of standards and guiding principles developed collaboratively by industry participants in the online sphere in Australia. It covers a wide range of issues related to online safety, including data protection, content, and information security.
1.4. GDPR (General Data Protection Regulation) – a regulation that applies to the processing of personal data effective from May 25, 2018.
1.5. COPPA (Children's Online Privacy Protection Act) – a law aimed at restricting the collection of personal information from children under 13 years of age without parental consent.
1.6. ICNA (Act on Promotion of Information and Communications Network Utilization and Information Protection) – a law that establishes rules and standards for the use of information and communication networks and information protection in South Korea.
1.7. APPI (Act on the Protection of Personal Information) – a law that establishes standards for the processing, use, and protection of personal information in Japan.
2. Age restrictions
2.1. The game is not classified as a children's application, is not intended for children, and is not subject to the Children's Online Privacy Protection Act (COPPA).
2.2. Nevertheless, we strictly monitor the protection of Personal Data of all Users and attach particular importance to safeguarding the data of minors. If we discover that we have obtained personal information from an individual under the age of 13 without parental or legal guardian consent, we will take immediate action to delete such information from our servers.
3. Applicable legislation
3.1. GDPR (General Data Protection Regulation) is a European regulation that governs the processing of personal data, and applies to users located within the European Union. Pacwyn acts in accordance with the provisions of the GDPR to ensure the protection and security of users' personal data within the framework of this law. More information about GDPR can be found on the official page: https://gdpr-info.eu
3.2. The Polish Personal Data Protection Act (Ustawa o o ochronie danych osobowych) is a local Polish law regulating the processing and protection of personal data, including the provisions of GDPR. All operations with user data located in Poland are subject to this law. More information about the law can be found on the official page: https://uodo.gov.pl/en
3.3. CCPA (California Consumer Privacy Act) is a law of the state of California, USA, aimed at enhancing privacy rights and consumer protection for California residents. The CCPA applies only to users residing in the United States. Users can review their rights under the CCPA at: https://leginfo.legislature.ca.gov
3.4. Users from other jurisdictions may also be subject to local data protection laws, depending on their country of residence, and Pacwyn takes steps to comply with all applicable laws.
4. Data processing consent
4.1. By granting access to your Personal Data, you consent to their processing, including transmission, storage, and use in accordance with our security standards and Privacy Policy. We, in turn, undertake to apply all possible measures to ensure the secure processing of your data in accordance with applicable international laws and regulations.
4.2. Your consent to provide Personal Data for the use of our Game is entirely voluntary and at your discretion. You have the full right to refuse to provide the requested information; however, such refusal may limit your access to certain features of the Game.
5. What personal data do we collect?
5.1. Pacwyn makes efforts to minimize the collection of Personal Data and ensure a high level of user privacy. We do not require or process the following types of Personal Data: personal identifiers such as surname, first name, postal addresses, phone numbers, payment instrument details, location data, or information regarding personal preferences such as ethnicity, religion, sexual preferences, political opinions, membership in associations, medical or biometric data, or details of legal offenses.
5.2. Data automatically collected when using the game. When interacting with the Game, certain data about the User's device is automatically captured, such as IP address for location determination, language and timezone settings, and device information.
5.3. To enhance your experience, bolster security measures, prevent fraud, and ensure that the game operates safely and in accordance with our terms of service, we may collect the following types of information:
5.3.1. Browser data (if using our website): IP address, browser type, operating system, language.
5.3.2. Mobile device data: anonymous device identifier, IMEI (International Mobile Equipment Identity), device name and model, operating system, language.
5.3.3. Security diagnostics of the mobile device, indications of a rooted device, indications of emulator usage.
5.3.4. Security settings data of the mobile device, indication of screen lock status.
5.3.5. Metadata of installed programs on the mobile device, package name, program name, program version, program hash for device identification.
5.3.6. Game Data, your interactions within the Game and with other Users through server logs.
5.4. When you install the app, we request permission to access this information. The specific data we collect can depend on the individual settings of your device and the permissions you grant when you install and use the app.
5.5. Information is provided by Users on their own initiative. Any information voluntarily provided by you, for example, during authentication and/or contacting our support service, the in-game account name chosen by each User. The in-game account name may be visible to other users and is also considered Personal Data.
5.5.1. In case of authentication via Google, we retain the following user data: Google identifier, email address, preferred language, and profile image URL.
5.5.2. When authenticating via Facebook, we retain the User's identifier on Facebook.
5.5.3. When using Apple ID authentication, we retain the User's identifier on Apple and their email address.
5.5.4. If a user logs in as a guest, no personal data is collected.
5.6. We believe that the Personal Data we work with belongs to the Users. If there are changes to the Personal Data required for the functioning of the Game, Users are obligated to notify us of these changes.
6. Promotions in the Game
6.1. Pacwyn does not distribute advertising or informational materials to users' devices. We also do not send notifications confirming the use of Game services or changes to the privacy policy. Any announcements, informational materials, updates, or changes can always be found directly within the Game.
7. Retention period for Personal Data
7.1. Users' Personal Data is stored until the User requests their deletion. Upon receiving such a request, the data will be deleted within 60 days. If no deletion request is received, Pacwyn retains Personal Data for up to 3 years for the purposes of providing services in the Game, as well as for statistical and analytical processing.
7.2. Please note that in the event of a request for deletion of Personal Data or if a User deletes the Game or their game account, Pacwyn may retain certain data if required to comply with legal requirements, fulfill obligations, resolve disputes, or prevent unlawful use of the game.
8. Protection measures for Personal Data
8.1. Pacwyn strives to ensure compliance with the storage and processing of Users' Personal Data according to GDPR and CCPA standards. As part of these efforts, we employ methods of anonymization and data encryption, aiming to maintain their confidentiality, integrity, and availability, and strengthen the resilience of our information systems. Additionally, we systematically assess the effectiveness of our security measures, following the recommendations of Article 32 of the GDPR.
8.2. Despite our data protection efforts, we cannot provide a complete guarantee against breaches in the event of external failures, such as hardware and software errors or unlawful actions. Accordingly, Pacwyn disclaims responsibility for instances of data breaches, unauthorized access, disclosure, or other actions with data carried out by third-party organizations or individuals.
9. Data Protection Officer
9.1. To enhance control over data storage and security, Pacwyn may appoint a Data Protection Officer (DPO) responsible for compliance with data protection legislation under Articles 37, 38, 39 of the General Data Protection Regulation (GDPR). The key tasks of the DPO include:
9.1.1. Informing controllers and processors of their obligations under the GDPR regulation;
9.1.2. Monitoring compliance with GDPR requirements, including appointment, training of staff, and audits;
9.1.3. Acting as the organization's representative in regulatory authorities on data processing issues;
9.1.4. Providing consultations on data processing matters, including data protection impact assessment and prior consultation;
9.1.5. Handling and processing requests from Users related to their data protection rights and ensuring compliance with these rights according to this Policy.
10. User data storage
10.1. Local Data Storage: All personal and gameplay data collected by Pacwyn is stored on secure servers managed by our company. This data is used exclusively for analytical purposes to improve the quality and functionality of the Game. We guarantee that this data is never shared with third-party organizations and is not used beyond the scope of providing and enhancing our services.
10.2. Third-Party Services: For certain functions, our game integrates services from third-party providers such as Firebase and AdMob. While we do not directly transmit personal data to these providers, Users should be aware that interacting with these services may involve data collection by the service providers. For detailed information on how this data is collected and used, we recommend reviewing the privacy policies of the respective services, the links to which are provided in the "Integrated external services" section.
10.3. We strive to ensure maximum security and privacy of our Users' data by employing modern encryption methods and information protection at all stages of processing and storage.
11. Integrated external services
11.1. To enhance the functionality and promotion of the Game, as well as to provide services to Users, Pacwyn may integrate external services that assist us in monetization, analytics, marketing, and social integration. Such services may collect and analyze information about Users. Below is a description and links to the privacy policies of these services. We recommend reviewing the privacy policies of these services to better understand how your Personal Data will be used:
11.1.1. Google AdMob: Used for monetization through advertising. AdMob allows us to display advertisements that are relevant to our Users.
AdMob Privacy Policy.
11.1.2. Firebase: A service that allows analysis of mobile application usage, including metrics such as DAU (daily active users), MAU (monthly active users), and LTV (lifetime value of a user).
Firebase Privacy Policy.
11.1.3. Google Analytics: This service provides the ability to analyze user activity in the mobile application, track metrics including user behavior, traffic sources, content interaction, and conversions. More information about data protection and terms of service can be found by reviewing the
Google Analytics Privacy Policy.
11.1.4. External accounts Google, Facebook, Apple: These platforms are used for game authentication, allowing users to use their social accounts to log into the game. These services also provide their own authentication analytics.
11.1.6. Talsec: Specialized software designed to monitor the status of mobile devices. This service allows us to detect whether a broken phone or emulator has been used to access the game, which is important for preventing cheating and bypassing payment mechanisms in the Game. You can review the privacy policy of this service at
https://www.talsec.app/.
11.2. Integration of third-party services into the Game does not imply any affiliation between Pacwyn and such services, nor does it mean that the privacy policy of external services corresponds to the Pacwyn Privacy Policy.
12. International transfer of Personal Data
12.1. Transfer of Personal Data to integrated external services. Pacwyn guarantees the confidentiality of Users’ data. We do not engage in selling your data; however, to ensure the functionality of the Game, we need to transfer Personal Data to our partners or third-party services integrated into the Game. Access to your data by such partners is restricted and provided only to the extent necessary for their tasks.
12.2. Exchange of anonymized information. As part of our collaboration with advertising agencies, analytical services, and other external partners, we may share anonymized information with them that does not allow the identification of Users' identities.
12.3. Transfer of data upon change of Game ownership. In the event of a sale or purchase of a business related to our Game, Users' data may be transferred to the new owner as part of the assets. Such data transfer will be conducted in compliance with our confidentiality principles and applicable data protection laws.
13. Users’ rights under GDPR
13.1. In accordance with the General Data Protection Regulation (GDPR), Users of our Game have rights regarding their Personal Data that they provide for use in the Game:
13.1.1. Right to access data. Users can request access to their Personal Data that we collect and process. To do this, Users can contact Pacwyn at the email address support@pacwyn.app. We will provide a copy of the stored data, in accordance with
Article 15 of the GDPR.
13.1.2. Right to rectification. Users have the ability to request correction or updating of their personal data. This can be done by sending a request to our email address support@pacwyn.app. We will promptly process your request for data correction in accordance with
Article 16 of the GDPR.
13.1.3. Right to data portability. Users have the right to request the transfer of their data to another service provider or service. This right is provided by
Article 20 of the GDPR. We may charge an administrative fee for performing this service and are limited by the amount of data we process.
13.1.4. Right to withdraw consent. Users may withdraw their consent for the processing of their Personal Data or receipt of electronic notifications from Pacwyn at any time. This is done in accordance with
Article 21 of the GDPR. After withdrawing consent, access to some Game features may be restricted.
13.1.5. Right to erasure of data. Users can request the deletion of their Personal Data from our systems and servers, in accordance with
Article 17 of the GDPR. To do this, please contact Pacwyn at the email address support@pacwyn.app. Data deletion will be completed within 60 days of confirming the request.
13.2. In addition to these rights, Users should understand that certain data may remain in our archives for administrative or legal purposes, even after their deletion. Pacwyn does not delete information that has been publicly posted in the Game or on platforms where the Game is hosted. It is also important to note that data already transferred to third parties may continue to circulate beyond our control and cannot be fully deleted from all sources.
14. Additional Privacy Notice for residents of Australia, California, Korea, and Japan
14.1. This additional privacy notice is exclusively for residents of Australia, California, Korea, and Japan to exercise greater control over their data and applies to Personal Data collected and processed by Pacwyn in the Game.
14.2. Residents of Australia: According to the Australian Online Safety Industry Codes, residents of Australia have additional rights regarding their personal data. These rights include: The right to know what personal data is collected about them and how it is used. The right to access their personal data and request corrections if inaccuracies are found. The right to delete personal data under certain circumstances, including when the data is no longer needed for the purposes for which it was collected. The right to non-discrimination for exercising their rights regarding personal data. To request access to your data or its deletion, please contact us at: support@pacwyn.app.
14.3. Residents of California: According to the California Consumer Privacy Act (CCPA), residents of California have additional rights regarding their personal data, including the right to know what personal data is collected, the right to delete personal data, and the right to non-discrimination for exercising their rights. To request access to your data or its deletion, please contact us at: support@pacwyn.app.
14.4. Residents of Korea: Under the Personal Information Protection Act (PIPA) and the Act on Information and Communications Network (ICNA), users from the Republic of Korea have the right to access, correct, delete, and object to the processing of their data. We are committed to ensuring the security of your data and taking measures to prevent data leaks. To manage your data, please contact our support department: support@pacwyn.app.
14.5. Residents of Japan: Under the Act on the Protection of Personal Information (APPI), residents of Japan may request disclosure of collected data, as well as its correction or deletion if the data is incorrect. For more information or to request changes to your data, please email us at: support@pacwyn.app.
15. Privacy Policy update
15.1. Pacwyn reserves the right to regularly review and update the Game's Privacy Policy to enhance the level of protection for collected Personal Data and comply with legislative standards such as GDPR and CCPA. All changes and updates to the Policy will be published directly in the Game and on the platforms where the Game is hosted.
15.2. Individual notifications about any changes to the Policy will not be sent to Users via email or through the in-game notification system. By continuing to use the Game after changes to the Privacy Policy are made, you confirm your agreement with the new version of the Policy.
15.3. The current version of the Privacy Policy, available in our systems and on our platforms, is the valid and enforceable version at the time of Game use.
16. Users' feedback
16.1. Users can provide public and private feedback and comments about the Game. Pacwyn values feedback and advice about the Game, as this type of feedback helps us address user requests, improve Game functionality, and create new products and options that meet user needs.
16.2. Pacwyn respects your privacy and commits not to disclose your feedback and advice without your permission. With your consent, we may publish your opinion, which may include personal information or links to your profile. If you need to make changes or delete your feedback, please contact us via email: support@pacwyn.app.
Last updated: 2024/09/12