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CD PROJEKT RED Privacy Policy
Last updated: 21.04.2015


Hello! This Privacy Policy is where we explain to you how your personal information is collected and stored and what happens to it when you're using CD PROJEKT RED games and services. Like with our User Agreement, we've put together both a full text version and a (non legally binding) summary version to make things simple. You will need to agree to this Privacy Policy before you use a CD Projekt game or service for the first time. If you have any queries you can contact us at legal@cdprojekt.com. Here we go…

FULL TEXT

QUICK SUMMARY

1.

WHO WE ARE

1.1

We are CD PROJEKT RED, part of the CD Projekt SA group of ul. Jagiellońska 74, postal code 03-301, Warsaw, Poland. CD Projekt S.A. is the data controller under European Union data protection legislation. We will further call ourselves “CD PROJEKT RED” as CD PROJEKT S.A. is the legal entity CD PROJEKT RED is part of.

Hello, we're CD PROJEKT RED and we are based in Poland.

2

WHAT THIS PRIVACY POLICY GOVERNS

2.1

This Privacy Policy applies to: all our websites, games, forums, social media channels, customer and technical support and any other services we provide to you (we'll just call all this "CD PROJEKT RED services" for short).

This Privacy Policy explains the different kinds of information we collect from you when you're using CD PROJEKT RED. We will comply with applicable privacy laws.

2.2

Specifically, this Privacy Policy governs personal information (or, in the USA, personally identifiable information) and non-personal information (or, in the USA, non-personally identifiable information), which we collect from you when you're using CD PROJEKT RED services. ("Personal information" basically means information, which, on its own or in combination with other information, can be used to identify you).

2.3

We respect your right to privacy and will only process personal information in accordance with applicable legislation in the EU (including in particular the Data Protection and Privacy and Electronic Communications Directives), the USA (including the Children's Online Privacy Protection Act) and elsewhere.

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 13 without consent from their parent or guardian. If you are a parent or guardian and are concerned about the transfer of personal information about your child, please contact legal@cdprojektred.com.

We cannot and will not collect personal information about children below 13 without parental/guardian involvement – this is actually a legal requirement.

4

WHAT INFORMATION WE COLLECT

4.1

When you use CD PROJEKT RED services we may collect the following information, if relevant (how we use it is described later in this document):

  1. Your name
  2. Your email address
  3. Any user name (such as a forum user name) used to identify yourself in any of our services
  4. Details of your digital platform account regarding our games (such as a GOG Galaxy account, if you have one), but not any financial details
  5. Any other information with which you supply us via our services
  6. Technical details about any device which you use to access our services, including: Internet and/or network connection (including IP address); any mobile device identifier; your operating system, browser type or other software; or your hardware or other technical details. This is technical data about our users and their actions and patterns which does not provide personal information
  7. Details of your use of our services including, but not limited to: metrics information about when and how you use the services; traffic data; and your geographical location data
  8. Details about your use of social networking and our services (if you have linked our services to a social networking account). This may potentially include certain information from Facebook or other social networks (including access to your friends list as well as aggregated non-personal analytics data about our users) strictly in accordance with Facebook's and other networks' terms and conditions – in the extent necessary to provide you with all functions of CD PROJEKT RED games and services; and
  9. Other information required in order to help you with any queries or support matters.

We may collect certain information when you use CD PROJEKT RED services (more information opposite).

5

HOW WE COLLECT INFORMATION FROM YOU

5.1

We may collect and process information about you in the following ways: (a) information you give us via CD PROJEKT RED services; (b) information given when you contact us or report a problem with CD PROJEKT RED services; and (c) 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 CD PROJEKT RED services or trusted third parties connected with us for optional things like surveys or polls.

We will collect the information ourselves or via third parties when it comes to optional things like surveys.

6

COOKIES

6.1

We also collect information about you via cookies. You can find out more about this in our Cookie Policy here: link. The Cookie Policy forms part of this Privacy Policy.

Read our cookie policy too (link opposite).

7

WHERE WE STORE YOUR INFORMATION

7.1

The information we collect from you will be stored and processed in the European Economic Area. By submitting your personal information, you agree to the transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

We will store your information in Europe. We will do our best to keep this information secure.

7.2

All information you provide to us is stored on our secure servers. Once we have received your information, we will use strict procedures and security to prevent unauthorised access.

8

HOW WE USE YOUR INFORMATION

8.1

We will use the above information in the following ways:

  • To ensure that CD PROJEKT RED services are presented in the most effective manner for you and for your computer or other device from which you access CD PROJEKT RED services.
  • 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 CD PROJEKT RED services (of course, it’s optional and we will ask you for permission first).
  • To carry out our obligations arising from any contracts between you and us.
  • To allow you to participate in interactive features of CD PROJEKT RED services when you choose to do so.
  • To notify you about changes to CD PROJEKT RED services.
  • To improve or modify CD PROJEKT RED services.
  • To calculate conversion rates and other elements of CD PROJEKT RED services’ performance.

We will use your information to run CD PROJEKT RED services and keep improving them as well as to communicate with you (e.g. with newsletters or emails).

Sometimes we may have to share anonymised, non-personal information like operating system types in order to run our services.

8.2

We might share some aggregated and general non-personal data on user behaviour (e.g. sales per region) with third party partners who work with us to provide CD PROJEKT RED services to you (for example, with payment providers) in order to support, improve or amend CD PROJEKT RED services. We may also share non-personal information with data analysis services to help us run CD PROJEKT RED services.

HOW YOU USE YOUR INFORMATION

8.3

Please remember that any communications you have via CD PROJEKT RED services (e.g. via private messages or CD PROJEKT RED forums or via social media) may reveal details about you. Also, any information you post publicly using CD PROJEKT RED services will be publicly available to CD PROJEKT RED users and others. We are not responsible for your use of any otherwise private personal information, which you make available via CD PROJEKT RED services, or the activities of other users or other third parties to whom you give or make available your information.

When you're using CD PROJEKT RED services you have the option to share your own personal information with others. Be careful about it - it's your responsibility.

9

THIRD PARTY INFORMATION COLLECTION AND EXTERNAL SERVICES

9.1

CD PROJEKT RED services may, from time to time, contain links to and from the websites or services of third parties. Our Privacy Policy does not extend to these external sites or companies, so please refer directly to their privacy policies.

You may find third party links in CD PROJEKT RED services, or we might direct you to third parties. They may collect information from you under their own privacy policies. Make sure to take a look at them.

9.2

Some services may involve interacting with trusted partners like our sister company GOG.com. For example you could set up a GOG account to access services like The Witcher forums. In order to do this, we may need to share some of your personal information with our trusted partner – however, all this is optional and will only be done with your approval. The shared information would be protected by their privacy policy.

We provide some services via trusted partners like GOG.com (our sister company) – if you use them (which is optional), we will share some information with them.

10

PUSH NOTIFICATIONS

10.1

If you use our mobile games then, with your prior approval, we may send push or local notifications to your mobile device to give you updates regarding those games. You can manage this, normally from your device’s Settings section.

We can use mobile push notifications if you approve it.

11

OTHER STUFF

11.1

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.

11.2

In the unlikely event of a reorganisation or merger of CD PROJEKT RED we may transfer personal information to an involved third party who will protect to at least the same level as we do in this privacy policy.

Regardless of any reorganisations, acquisitions, etc., your personal information will be protected the same way as it is right now. Fear not!

12

YOUR RIGHTS

12.1

You have the right to ask us not to process your personal information for marketing purposes. You can change your email settings to unsubscribe from email communications.

You have rights about how your personal information is used. Any questions, please contact us at legal@cdprojektred.com.

12.2

Depending on where you live, you may have additional privacy rights. For example, in the EU you have the right to access your personal information we possess and you may also contact us to request that we delete your personal information from our system. We will use commercially reasonable efforts to honour your request, but we may decline requests that are unreasonably repetitive, are disproportionate or infringe the privacy of others. Of course, you will be notified in advance.

12.3

Under California law, California residents who have an established business relationship with us may choose to opt out of disclosure of personal information about them to third parties for direct marketing purposes.

12.4

If you would like to exercise any of these rights or have any queries regarding them, contact: legal@cdprojektred.com

13

CHANGES TO THIS PRIVACY POLICY

13.1

We may change this privacy policy if we think it's necessary, e.g. for legal reasons or to reflect changes in our services. If so, we will make the changed Privacy Policy available online and update the “Last Updated” date.

We can change this Privacy Policy, but if we do, we will put the changed version online and normally it will take effect 30 days afterwards.

13.2

Once we change the Privacy Policy, it will become legally binding on you 30 days after we post it online. During that period, you're welcome to contact us if you have specific questions about the changes.

13.3

If you don't agree to those changes (regardless of whether you email us), then unfortunately we must ask you to cease using our CD PROJEKT RED games and services. We're sorry we have to say that, but we hope you'll appreciate that for our services to work properly we need to have everyone using it under the same rules instead of different people having different rules. That's why we encourage you to get in contact if you have queries.

Please feel free to contact us if you have any questions with regards to the changes.

14

CHANGES TO THIS PRIVACY POLICY

14.1

We'd also like to remind you that our User Agreement has more information about how we operate CD PROJEKT RED services and it has a number of sections, which apply to this Privacy Policy too. You can read it at link.

Just a reminder to check our User Agreement too.