1. WHO WE ARE
We are GOG sp. z o.o., a company incorporated in Poland (we will further call ourselves “GOG”).
You can contact us here, via email at firstname.lastname@example.org or by traditional mail: Data Protection Officer, GOG sp. z o.o., Jagiellońska 74, 03-301 Warsaw, Poland.
Hello, we're GOG and we are based in Poland. You can find our contact details here (see opposite).
2.3 We respect your right to privacy and will only process personal information in accordance with applicable data protection legislation in the EU, the USA (including the Children's Online Privacy Protection Act) and elsewhere.
We will comply with applicable data protection laws. This involves us being responsible for personal data which we use in connection with GOG services and equally our Partners (see opposite) will be responsible for personal data which they use in connection with GOG services.
2.4 GOG works with trusted partners, including our related company CD PROJEKT, developers and publishers, payment providers, customer service software providers and others („Partners”) – more on them later in this Policy.
3. PROTECTING CHILDREN
3.1 We recognise we have a special obligation to protect personal information obtained from children. We do not and will not knowingly collect personal information from any child under the age of 16. If for any reason we decide to collect personal information of children between 13 and 16 we will ask for their parent or guardian consent. If you are a parent or guardian and are concerned about the transfer of personal information about your child, please contact email@example.com.
We cannot and will not knowingly collect personal information about children under 16.
4. INFORMATION WE COLLECT
4.1 When you register a GOG account with us, you will need to provide us: (a) your username; (b) your email address; and (c) a password (which is encrypted so that we don’t have access to it). This information is necessary for us to provide you with GOG account requested by you. In your GOG account settings you can also set your date of birth, avatar, and your geographical location. This information will be protected by your GOG account password. You are responsible for keeping it safe - please don't share it with anyone.
To register a GOG account, we will ask you for and collect some basic personal information, including username and email. We need this to provide you GOG account. Keep your GOG account password safe.
4.2 When you use GOG services we may also collect the following information (how we use it is described later in this document):
- (a) Technical details about devices which you use to access GOG services, including: Internet and/or network connection (including your IP address); mobile device identifiers; your operating system, browser type or other software; your hardware details; or other technical details provided by your web browser. This is technical data about our users and their actions and patterns, which does not provide personal information;
- (b) Details of your use of GOG services including, but not limited to: metrics information about when and how you use GOG services (such as what game(s) you are playing, your current status, your interactions with others); order status, order ID; traffic data; your geographical location; your purchase history; game library; emails received; and links accessed; your preferences and choices such as subscriptions, preferred language and currency; your friend lists on GOG.COM; your communication via chat, game reviews, published posts on forum and other GOG services;
- (c) Other information required in order to help you with any queries/support you may need assistance with via the GOG forums or customer support, including communications with you; and
- (d) limited payment processing information, including as applicable your credit card number, name and email address (on a hashed/anonymised basis as applicable), payment methods, payment engine and transaction type; fraud risk score;
- (e)if you use GOG Galaxy we will also collect technical logs, information about your achievements in games you play and We may also collect additional information when you use other GOG services (see opposite). If GOG services crash, we might ask you to send us crash logs/bug reports.how long you play them; your multiplayer sessions; your activities on other platforms connected to your GOG account.;
- (f) if you use Facebook Connect we may also collect limited information through Facebook Connect such as your Facebook ID, avatar, e-mail and friend list;
- (g) if you purchase content via a third party platform which uses our GOG Direct to Account API, the platform may share data with us such as your platform ID, order details or your IP address;
- (i) any other information which you supply us via our services;
4.3 GWENT. When you sign up for, download, use or play GWENT then GOG may collect and use basic data about you and your account activity for the general operational purposes of GWENT. This data includes: (i) your email address; (ii) your name and surname; (iii) your date of birth; (iv) any username used to identify yourself as well as your avatars; (v) Gwent-ID; (vi) a log of user activity within Gwent (including login time, logout time, log of matches played, number of wins and losses and gathered experience points); (vii) a record of your in-game virtual goods and currencies; (viii) your Matchmaking Rating (MMR); (ix) IP address; (x) your country of location (identified based on IP address); (xi) any other data which you supply us via GOG services including data required to help you with any queries or support matters such as crash logs or the technical details of the device you use to play GWENT. Plus if you purchase GWENT in-game content we may collect and use: (xii) your device/platform and records of any purchases made with virtual or real currency (including transaction dates, currencies, value and the relevant purchased products). In order for you to play GWENT or access other related services, we need to process the data described above. If you do not agree to provide us with the above-mentioned data for the above purposes, you will not be able to play GWENT or use other services related to it.
When you play Gwent, GOG collects basic data about you and your account activity (specific examples opposite). We need this in order to run GWENT and its related services. You can decline to provide your data but then equally you can’t play GWENT.
4.4 A quick word about bug reports and crash logs: GOG software will generate bug or crash reports regarding GOG services – these reports will not mention your personal information. You can decide whether to submit these reports to GOG.COM automatically. If you manually submit bug or crash reports to us, or if we contact you asking for feedback regarding crash or bug reports, then we may store them alongside your personal information.
4.5 A quick word about payment details (if/when you use them in GOG Services): this is a matter for the relevant payment method/platform/processor. We process only limited payment processing information on a hashed/anonymised basis as applicable. If you make any purchases within GOG Services, then we are notified by the payment processor once a transaction takes place and of course we make sure you receive your purchased item, but we will not receive any of your actual payment details
5 HOW WE COLLECT INFORMATION FROM YOU
5.1 We may collect, process and use information about you in the following ways (either directly or via our Partners as explained above): (a) information you give us via GOG services; (b) information given when you contact us or report a problem with GOG services; (c) through our API which allows third party platforms to sell content which is activated directly on GOG.COM (“GOG Direct to Account API”) and (d) we may also ask you to complete surveys that we use for research purposes, although you don't have to respond to them. We may collect this information via GOG services or trusted third parties connected with us for optional things like surveys or polls.
5.2 Facebook Connect. When you register to GOG services via Facebook Connect (of course, it's optional), Facebook will provide us with certain information about you such as your Facebook ID, avatar, e-mail, gender, location and friend list. Data is gathered strictly in accordance with the social network(s)’ terms and conditions, so check your privacy settings on Facebook.
5.3 GOG Connect. When you use our cool and optional feature GOG Connect we will be retrieving limited information from your Steam account. We explain this in more detail in section 10.3 below
We will collect the information ourselves or via third parties when it comes to optional things like surveys, GOG Connect or authentication services like Facebook Connect.
7 WHY DO WE USE YOUR DATA? (LEGAL GROUNDS FOR DATA PROCESSING)
7.1 When we process information about you, we do so as necessary to provide GOG services you use (i.e. to perform agreement between us, enable you to play GWENT), meet our legal obligations (f.ex. tax, accounting) or to fulfill the so-called “legitimate interests” of GOG or other reasons described in the “How we use your data” section. To clarify, by legitimate interests we mean lawful purposes that could be reasonably expected (like informing you about games we distribute and making sure our marketing is relevant for you, protecting the security of our websites and systems, conducting anti-cheat analysis and anti-fraud checks). When we rely on the legitimate interest, we consider and balance any potential impact on you and your rights. For other purposes we will ask for your consent and you will be entitled to withdraw this consent any time, with no impact on the validity of the processing before your consent has been withdrawn.
In essence, we process your data to provide you with GOG services, to meet our legal obligations and for other reasons that are important for us like informing you about our games and ensuring security of our website. In other cases, we will ask for your consent in advance and you will always have the right to withdraw it anytime you like.
7.2 When we transfer your data outside of the European Economic Area, we do so on the basis of a variety of legal mechanisms, as described in “Trusted Partners”.
8. HOW WE HANDLE YOUR INFORMATION
8.1 All information you provide to us is stored on our secure servers or those of our trusted partner services. We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage
All information you provide to us is stored either on our secure servers or those of our trusted partners
- (a) we will keep information that is associated with your GOG account for the duration of your agreement for the access to GOG Services (i.e. until you close your GOG account). If you choose to close your GOG account, limited data that we collect about you may still be retained for tax, legal and accounting purposes;
- (b)if you don’t have a GOG account and contact us we will retain correspondence with you as long as necessary to help you out and then for the period necessary for legal or accountability purposes;
- (c) information that you post on our public forums and your game reviews will be retained until you decide that it should be removed as well. We don’t want to interfere with your posts and expressions without your permission.
- (d) we will keep data that is associated with your GWENT account for the duration of the agreement to access GWENT services (i.e. until you close your GWENT account). Following account closure, limited data that we collect about you will still be retained for an additional few years for tax, legal and accounting purposes.
In general, we’ll store your data until you close your GOG account (or GWENT account if applicable). If you do, we may still use limited information about you for tax, legal or accounting purposes.
9. HOW DO WE USE YOUR INFORMATION
9.1 We will use the above information in the following ways:
- (a) to carry out our obligations arising from any contracts between you and us, like providing access to your GOG account, providing you with the games and technical support and in general allowing to use GOG Services and its functionalities when you choose to do so f. ex. your GOG user profile, chat, forum or cloud saving and crossplay services in GOG Galaxy
- (b) to ensure that GOG services are presented in the most effective manner for you and for your computer or other device from which you access GOG services;
- (c) to provide you with information, products or services that you request from us and which we feel may interest you - in particular, we may send you newsletters or emails about GOG services, special and occasional offers like a welcome offer or provide you with ads, offers and product recommendations on the basis of your purchases or activity on our and third party websites and services, as well as about CD PROJEKT’s games and services (of course, it’s optional);
- (d) to activate content on your GOG.COM account through our GOG Direct to Account API;
- (e) to evaluate the effectiveness of our marketing actions and improve the quality of our marketing;
- (f) to notify you about changes to GOG services and our legal documents.
- (g) to improve or modify GOG services, f.ex. based on which games you like, how you play them, reported problems, your suggestions or satisfaction surveys;
- (h) to improve or modify GOG services, for example based on which games you like more and how you play them.
- (i) to calculate conversion rates and other elements of GOG.COM performance.
- (j) in connection with the services of our Partners, such as payment processors, located in and outside the European Union, but only to the extent necessary to provide those services.
- (k) to provide you with optional functionalities such as GOG Connect or authentication via Facebook account.
- (l) to create a universal user’s profile based on information about your use of GOG Services and other platforms (we’ll rely on data made available when you merge your GOG account with your account on other platforms) in order to make our Services even more interesting for you.
- (m) to protect you from an unauthorized use of your account and against fraud;
- (n) for tax, legal and accounting purposes
- (o) for the accountability purposes as defined by EU legislation (GDPR)
We will use your information to run GOG and keep improving it as well as to communicate with you (e.g. with newsletters or emails). Sometimes we may have to share anonymised, nonpersonal information like operating system types in order to run GOG services.
9.2. Whenever we’re personalizing or targeting our marketing communications, offers and adverts, we may profile your personal information. We do not make however automated decisions (f.ex. via algorithms) that could affect your legal situation. If you decide that you no longer want to receive personalized offers, product recommendations from us, or no advertising news at all, you can object to this at any time. You can also choose whether to receive marketing communication from us, including personalized and targeted marketing emails by managing subscriptions on your GOG Account Subscription page, following the link "unsubscribe" attached to our marketing emails or just contacting us directly here.
9.3 GWENT. If you sign up for, download, use or play GWENT, we will also use your data to: (i) provide access and allow you to play GWENT; (ii) ensure enjoyable gameplay through the analysis of players’ data; (iii) maintain the ranking of Gwent players, (iv) calculate conversion rates and other elements of GWENT performance; (v) maintain technical support services for game users; (vi) identify incidents of game misuse; (vii) target and personalize our marketing communication, offers and advertisements that we display on our websites and services (including in-game marketing) as well as those of third parties based on the combined data we have collected about you.
We can use your data to help us operate and improve GWENT (assuming you play it ofc – hey, it’s a great game you know :)!)
9.4 Non-personal data. We might process some aggregated and general non-personal data on user behaviour (e.g. sales per region, number of support tickets) and share it with third party partners who work with us to provide GOG services to you (for example, with games developers/publishers selling games on GOG.COM or with payment providers) in order to support, improve or amend GOG services or to help them to improve their products, which you have bought. We may also share non-personal information with data analysis services to help us run GOG.COM. Fear not, as mentioned above, everything’s anonymised, so you cannot be identified.
10. DATA SHARING
10.1 Some elements of your personal information and some information about your use of GOG Services are accessible to other GOG users. For example: other users of GOG Services will be able to see your username and avatar (if you choose to have one). We may also display other information derived from your activity on GOG Services. We do this to help GOG users to find gamers with similar tastes and to build the GOG user community. You can manage the privacy settings of your GOG user profile in your GOG account
Some information about you will be visible on GOG.COM as a part of your GOG user profile, this can be managed via privacy settings for your GOG account
10.2 GWENT. When you create a GWENT account, some basic data about you (namely your username, card collection, and statistics) will form a part of your public profile and it will be visible to everyone who views your profile. You can disable this function and manage the visibility of your profile through your GWENT account settings at any time.
Limited data about you will be visible as a part of your public GWENT profile, but it can be disabled at any time via the privacy settings in your account.
10.3 How you use your information. Please remember that any communications you have via GOG services (e.g. via private messages, chat or the GOG forums or via multiplayer games like GWENT) may reveal your screen name, other details about you and the content of any communications by you with other users (see further section 10.2 above re GWENT). Also, any information and content you share publicly using GOG services (e.g. on our forums or your GOG user profile) will be accessible to GOG users and others. Consider carefully with whom you share your information and avoid sharing contact or private information about yourself.
When you're using GOG services you can choose to share your own personal information with others (e.g. in chat) but it's your responsibility.
Our Trusted Partners
- Customer support partners that provide us with software and support ticket system to help us managing your customer support requests (like Zendesk Inc.);
- Advertising and advertising measurement partners to facilitate targeting, delivery and measurement of online advertising on third-party services (such as Google Adwords) or that provide us with email marketing tools (such as GetResponse);
- GOG’s subsidiaries and affiliates, including CD PROJEKT S.A, who help us providing you with GWENT and enable you to participate in Gwent esports competition;
- Anti-cheat companies: we may share the information required for our detection, investigation and prevention of cheating in GWENT.
- Third party vendors that provide us with analytical tools for GOG.COM and for GWENT;
- Third party vendors that provide us with error tracking and crash reporting tools;
- Third party platforms that may sell content which is activated on GOG.COM using our GOG Direct to Account API (more details of which can be found in our User Agreement);
- Third party network providers to optimize delivery of GOG content you requested (we share only your IP address and the identification of GOG content you wish to access);
- Data storage partners: we may store some of your information using third-party data storage services, e.g. we may use Google services to run surveys on GOG.COM;
- Our professional advisors dealing f.ex. with legal, tax, audit or accounting matters.
In general, we don’t share information about you with third parties. There are exceptions like our partners that help us do our thing. They usually help us with things like data analytics, processing payments, internal tools or running a variety of marketing activities.
10.5 During the payment process, we may also share information about you with the following categories of third partners who handle it independently as the so-called data controllers:
- payment-providers for payment processing purposes;
- banks and financial institutions to obtain payment;
- anti-fraud service providers;
10.7 Your information may be processed, stored and transferred outside your country of residence and beyond the European Economic Area (EEA) and Switzerland, such as the United States, Canada or Brazil. Privacy laws in these countries may not offer the same level of protection as in your country or in the EEA. But whenever we’re sharing your personal information outside the European Economic Area (EEA) and Switzerland, we will do so on the basis of the EU standard contractual clauses or Privacy Shield Framework which are lawful measures to transfer your data and establish adequate protection of your personal information.
11. THIRD PARTY INFORMATION COLLECTION AND EXTERNAL SERVICES
You may find links on GOG.COM that lead outside our website. Sometimes we might need to direct you elsewhere (like a developer’s website) if you want to access additional features built into your games. These sites might collect your information under their own privacy policies.
You can use GOG services to access cool stuff from GOG-approved partners. We will need to share some personal information with them (which you control). It is up to you if you want to use your GOG account for this or not.
If you’d like to use our GOG Connect feature, we’ll require access to your “Steam Data” (more info opposite). There are some legal rules that Valve requires us to follow.
12. OTHER STUFF
12.1 Please be aware that we are subject to various laws and we may be required to release personal information to comply with law enforcement or other legal requirements.
We might be required to comply with law enforcement requests to release personal information.
Regardless of any reorganisations, acquisitions, etc., your personal information will be protected the same way as it is right now. Fear not!
13 YOUR RIGHTS
13.1 You have the right to object to the processing of your personal data in certain situations f.ex.for marketing purposes at any time. You can do so by contacting us here or by changing your email settings within your GOG account. Also email communications from GOG to you will contain an optout/unsubscribe option.
Know your rights! These include the right to know how your personal information is being used, access to the data itself, the right to alter it, transfer, restrict how we use it, or just have it all deleted. Simply contact us at firstname.lastname@example.org.
13.2 Depending on where you live, you may have additional privacy rights. For example, under EU laws you have the following additional rights: ● to access information we hold about you; ● to request that we delete your personal information from our system; ● to ask us to rectify/correct your personal information if appropriate. ● to ask us to restrict processing of your data; ● to transmit your data to another entity; ● to lodge a complaint with a data protection authority. You can exercise these rights by contacting us f.ex. here or at email@example.com.
You may have additional privacy rights (see opposite).
13.3 If you have any concerns about your privacy please contact us first. If however you feel we have not dealt with your concern you can report this to your local data protection regulator or the Prezes Urzędu Ochrony Danych Osobowych ("PUODO") in Poland.
15. USER AGREEMENT
Just a reminder to check our User Agreement as well.
Last updated: 26th February, 2019